Lantana Consulting Group submitted comments on March 18, 2016 in response to the Office of the National Coordinator’s (ONC) request for feedback on the 2017 Interoperability Standards Advisory (2016 Advisory). ONC’s consideration of public comments informs the development of the 2017 Advisory and prompts dialogue, debate, and consensus among industry stakeholders. Lantana’s response outlined suggestions for both terminology and content standards.
Our key recommendations for the 2017 Advisory include:
- Change “Draft Standard for Trial Use (DSTU)” to “Standard for Trial Use (STU)”.
- Adopt a three-level definition for the status of the Standards Process Maturity: (1) Final, (2) Standard for Trial Use (STU), and (3) Ballot in Development.
- Publish mature standards in a separate document. The 2016 advisory includes both emerging and mature standards. We recommend that ONC separate promising standards for adoption and mature standards.
- Create separate clinical and technical review processes when standardizing vocabulary for clinical concepts.
- Integrate clinical context into vocabulary standards, as described by the information model.
- Add simple and complex coordination of care activities and use cases.
- Recommend that Federal programs require QRDA Category III Release 1.1 STU – Balloted (March 2016).
- Consider adding FHIR-Based Clinical Quality Framework (CQF on FHIR) – Balloted (May 2016), which is an emerging alternative standard.
Lantana has engaged in standards development and deployment for over ten years. We appreciate the opportunity to respond and contribute to this draft of the 2017 Interoperability Standards Advisory.
For the full draft of our comments, click here.