Lantana Consulting Group submitted comments on July 31, 2017 in response to the Office of the National Coordinator’s (ONC) request for feedback on the Proposed Interoperability Standards Measurement Framework. Our key recommendations:
- Create a partnership with an organization that surveys the industry on data collection and reporting
- Indicate whether the standard was implemented as intended and if not, the nature of the deviation based on assessment of testing and validation.
- Roll out the framework with a roadmap and timelines for optional and mandatory adoption
- Tie the framework to recurring CEHRT regulations or certification criteria to reduce burden on the reporter
- Form a Technical Expert Panel, as defined in the CMS MMS Blueprint, to gather stakeholder input for measure selection