Response to ONC’s Proposed 10-Year Roadmap to Interoperability

In June 2014, the Office of the National Coordinator of Healthcare IT (ONC) released “Connecting Health and Care for the Nation: A 10-Year Vision to Achieve an Interoperable Health IT Infrastructure. This paper describes ONC’s broad vision and framework for interoperability and asked for comments from the public. The deadline was April 3, 2015. While billed as a “call to action,” it calls for a continuation of the approach we have pursued since 2004 and for interoperability to be achieved in steps: partially by 2017, more by 2020 and total interoperability by 2024. On behalf of Health Record Corporation, I submitted the following critical response and recommended we change course and go down a decidedly different path, one that enables us to achieve interoperability today.

The proposed ONC Roadmap falls far short of what we need. It continues down the same path we’ve been on for more than ten years, a path that has cost taxpayers more than $28 billion without achieving interoperability. And there is no guarantee that we’ll achieve interoperability by following this same path for another ten years!

That pace is simply intolerable. We need nationwide interoperability now, today, so we can help care providers stop making mistakes that kill more than 400,000 patients a year, harm rather than help another million and, together, waste between $300 billion and $800 billion per year. And they want it too, having spent hundreds of thousands—and in many cases millions—of dollars and endless hours installing EMR systems with the expectation that they would thereby enjoy interoperability.

The fact is we can achieve interoperability today if we change course and take a different path, a path that breaks the complex issue of interoperability into its two parts.

The first deals with basic interoperability at the micro level. It is to enable care providers to access a patient’s complete, lifetime medical record anytime, anywhere a patient requires care. We can do this today and should get on with it. It is the low-hanging fruit and will have an immediate and significant human and financial impact. Better information in the exam room will enable providers to reduce mistakes and unnecessary tests, and deliver better, coordinated, lower-cost care.

The second is to solve an array of macro population health issues involving big data and genetics that are far more complex and probably will take years to achieve significant results. These are referred to in the Roadmap as “advanced interoperability” issues.

The big mistake we’ve been making for ten years is that we have tried to solve all the issues and problems relating to interoperability and advanced interoperability, simultaneously, and we have tried to tie everything into the basic EMR systems providers have adopted. By now, instead of insisting that we continue down this “primrose” path, we should acknowledge that it doesn’t work and change course.

At the micro, provider-patient level, we keep trying to enable providers to access a patient’s records from all her providers on the fly, but trying to do so has created even more complex problems that we then must solve, such as how to manage non-standardized data; how to ensure that the records “pushed” or “pulled” from one provider to another belong to the patient being cared for and include all of—and only—that patient’s records from all her providers; how to solve the legal issues surrounding consent and the transmission of records across state lines; how to ensure that patient records are secure, private and unbreachable; and how to financially sustain the exchange of records.

By taking a different approach, we can avoid all these issues and achieve interoperability at the micro level today! And that’s what we do with MedKaz®, our patient-focused personal health record system. We aggregate a patient’s complete medical record from all her providers, plus the MedKaz application, on a device the patient owns, carries with her on a keychain or in a wallet, and gives to any provider who treats her anytime, anywhere. With only two or three clicks, her provider can sort and search for specific records to understand and coordinate her care—even without Internet access. Following each visit, he updates her MedKaz for her—we pay him to do so.

We solve the technical data issues by turning every patient record, including paper, into searchable pdf documents that the provider or patient can read in a browser; the patient identification problem by including the patient’s picture on her MedKaz; the legal issues by giving the patient possession of her records and requiring her password to open her MedKaz; the security and privacy problems by encrypting her records and storing them on her MedKaz, not on our server; and the financial sustainability issue by adopting a self-financing subscription business model.

At the macro, “advanced interoperability” level, we do not require the patient-specific information a care provider requires to treat a patient. Instead, we need the ability to de-identify and manage big data. This places an entirely different set of requirements on our provider EMR systems and may take longer than is required to achieve provider-patient interoperability.

In short, by separating the interoperability problem into two pieces, we can solve them more easily and at their own pace. We can have micro-level interoperability today, even while we strive to achieve advanced interoperability tomorrow and the next day.

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