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Wednesday, April 13, 2011

Comments on Goal V of the ONC HealthIT Strategic Plan

This is the last post of the series on the ONC Health IT Strategic plan.

I posted Comments on Goal IV of the ONC HealthIT Strategic Plan a few days ago. John Moehrke covered Goal III quite well in his post at the end of March.  My thoughts on Goal IIappeared the same day, just before the ACO rule was announced, just in case you missed them.  And my comments on Goal I appeared the day before that.

Goal V: Achieve Rapid Learning and Technological Advancement
Overall, this goal is probably the furthest off and the weakest written.  There's too much focus on the Federal sphere and not enough outside of it.
A. Lead the creation of a learning health system to support quality, research, and public and population health
Strategy V.A.1: Establish an initial group of learning health system participants.
Two items jump out: "The learning health system’s success will depend in part on the participation of a select number of institutions that collect and use large amounts of health care data." and "Several federal organizations are already fostering learning systems scaled to their own agencies, and some of these agencies will be key initial members of this group."
While the Federal sector is clearly important, many other organizations should be able to contribute to this effort.  The qualification of "a select number of institutions that collect and use large amounts of health data" ignores smaller providers.  There are a number of initiatives that include these providers in efforts to collect and use large amounts of health data.  State HIE initiatives should be included so to see how HIE technologies can support the learning health system.  The FDA, CDC and ASPE efforts, while important, are rather narrowly focused efforts that ignore the potential of other, non-federal contributors to this effort.

Strategy V.A.2: Develop standards, policies, and technologies to connect individual participants within the learning health system.
Another quote in this section stands out: "In order to make the learning health system a reality on a national scale, standards, policies, and mutually reinforcing technologies must be put in place to ensure that data collected at the point of care can be accurately de-identified, aggregated, analyzed, and queried for population health studies and quality improvement."
I don't see the rationale.  The Learning Health System needs to be national in scope, but specific learning efforts could be regional in scale and more quickly executed upon.  There should be mechanisms to support both, and to foster communications between regional efforts.

Strategy V.A.3: Engage patients, providers, researchers, and institutions to exchange information through the learning health system.
I can see obvious benefits for researchers and institutions in participation.  But, what's in it for me as a patient?  When will I get lower cost or better care as a result in the near term?  What would a physician get from participation beyond a nebulous future beneficial result for their patients?  The Learning health system needs to look at innovation in the arenas of both patient and provider engagement.  One quick thought that occurs to me on provider engagement:  Healthcare providers all have continuing education requirements.  Would there be a way to report results produced by the learning health system to providers, or to encourage providers to engage patients that the learning health system is seeking that would include an educational component fulfilling some of these education requirements.  This is the kind of innovation that a learning health system needs to think about first.

B. Broaden the capacity of health IT through innovation and research

Strategy V.B.1: Liberate health data to enable health IT innovation.
This is a pretty good section.  Data liberation is just at the beginning stages as part of Meaningful Use stage 1, and will improve through subsequent stages.  Open government initiatives to consolidate data silos and make aggregated data accessible will certainly be valuable here.

Strategy V.B.2: Make targeted investments in health IT research.
Many of the investments discussed in this section have already been made.  There are certainly a few generously funded activities.  I'd be interested in seeing a broader approach to some of the research.  Which will produce better results?  Four $15M grants, or 120 $500,000 grants?  Innovation occurs in many ways, and a bigger net may gather more fish.

Strategy V.B.3: Employ government programs and services as test beds for innovative health IT.
Eating your own dog-food is a well established principle used by many innovative IT organizations.

Strategy V.B.4: Monitor and promote industry innovation.
Another quote "The government facilitates and monitors the health IT industry and stays abreast of innovation’s impact on federal policies and programs in order to further promote innovation within the industry. Such activity is conducted primarily through panels, conferences, white papers, and similar outreach efforts."
Monitoring includes attending health IT industry activities, not just hosting them.  There is quite a bit of activity going on in Health IT in standards organizations like HL7 and IHE that could use more input and feedback from ONC. Just as ONC needs to engage patients where they are, they should also be engaging providers and the health IT industry where they are.  Even though I'm pretty close to DC, attending ONC sponsored activities is not something I can always fit into my travel budget.  But I do attend quite a few other industry events.  I think one of the challenges here is that ONC doesn't want to show favoritism to any one organization -- fine, spread the wealth like CDC and VHA do.  Everyone will benefit.

Strategy V.B.5: Provide clear direction to the health IT industry regarding government roles and policies for protecting individuals while not stifling innovation.
I'm curious about IOM rather than FDA leadership in this area, especially with respect to patient safety.  I'm not sure why IOM was chosen to lead this activity, rather than the FDA; who has been addressing these issues for quite some time.