In My SKIM of the Metadata ANPRM, I made the mistake of assuming it applied to Metadata used for Health Information Exchange. After all, the title is: Metadata Standards to Support Nationwide Electronic Health Information Exchange. In my SCAN of that document, I found this on Page 13:
As a feasible first step, the HIT Policy Committee suggested that ONC focus on facilitating the development and adoption of a minimal set of standards for metadata that could be “wrapped around” or attached to a summary care record when a patient seeks to download their health information from, for example, a health care provider’s patient portal or when a patient directs his or her health care provider to transmit his or her health information to a personal health record (PHR). Generally speaking, the term “metadata” is often used to mean “data about data” or, in other words, “data that provides more information or detail about a piece of data.”In the ANPRM, the standard identified for the purpose of downloading PATIENT SUMMARY data is CDA Release 2.0, and I can wholeheartedly support it for that purpose. In fact, the S&I Framework CDA Consolidation Project and Transfers of Care project both use the same standard to convey summary information. So no "wrapping" is even necessary.
There's more needed, (e.g., requirements on what must be present, and vocabulary), but this is a good first step. I'd suggest they look at what is already being done today (using the HITSP C32 Version 2.5) to fill in those gaps (see C83 page 27 Personal Information and C80 page 26 Personal Information)
Now that I understand what David McCallie was trying to tell us, I get it. Thanks David.