January 18, 2005
David J. Brailer, MD, PhD
Office of the National Coordinator for Health Information Technology
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW, Room 517-D
Washington, DC 20201
Dear Dr. Brailer:
The organizations listed below are pleased to submit this collaborative response to the Request for Information issued by your office. This submission represents an extraordinary diversity of stakeholders who share a commitment to improving the health care system through more effective use of health information. These thirteen major health and technology organizations have endorsed a “Common Framework” to support health information exchange in the United States while protecting patient privacy. We have identified the vital design elements – of standards, policies, and methods – for creating a new information environment that would allow health care professionals, institutions, and individual Americans to exchange health information in order to improve patient care.
Together and individually, we are committed to collaborating with your office and the many other dedicated and creative partners to achieve the vision of a more effective and connected health care system. Thank you for the opportunity to provide this contribution to the national dialogue on this vital topic.
Sincerely,
The American Health Information Management Association
The American Medical Informatics Association
The American National Standards Institute, Healthcare Informatics Standards Board
The Center for Information Technology Leadership
The Connecting for Health Steering Group
The eHealth Initiative
The Healthcare Information and Management Systems Society
Health Level Seven, Inc.
HIMSS EHR Vendor Association
Integrating the Healthcare Enterprise
Internet2
The Liberty Alliance Project
The National Alliance for Health Information Technology
January 17, 2005
David Brailer, MD, PhD
National Coordinator for Health Information Technology
Department of Health and Human Services
Hubert H. Humphrey Building, Room 517D
200 Independence Avenue, SW
Washington, DC 20201
Attention: NHIN RFI Responses [Federal Register: November 15, 2004 (Volume 69, Number 219)]
Dear Dr. Brailer:
On behalf of AHIMA’s 50,000 members, I want to thank you for providing an outstanding opportunity for the healthcare industry to gather and organize its collective intelligence and begin mapping out a course of action for achieving widespread exchange and interoperability of health information. As an active participant in the preparation of the attached Collaborative ONCHIT RFI Response, I believe we have produced a body of work that truly represents strong industry consensus regarding the issues surrounding your vision for a NHIN.
AHIMA is intensely interested in and dedicated to the development of a NHIN and I feel strongly that our members-specially trained health information management professionals- possess the education, experience and credentials that make them an important asset to any local, regional, or national health information exchange development or process. HIM professionals are enthusiastically engaged in a number of activities essential to achieving a fully functioning healthcare data network and environment and their work has influenced these recommendations. These activities include:
- Hands-on experience in the development and implementation of electronic health records in healthcare facilities across the country
- Projects related to consistent vocabularies, terminologies, classifications and mappings that will serve or facilitate standards and guidelines so that data can be uniformly exchanged and used
- Privacy and security implementation efforts as well as activities that address discrimination issues that may occur if healthcare data is misused causing an erosion of consumer trust
- Preemption issues, currently addressing data privacy barriers and possibly interstate data exchange
- Workforce promotion to ensure we have the academic programs, educators, and professionals necessary to facilitate all of the changes outlined in your RFI and detailed in our response
- The Commission for Certification of Health Information Technology
Along with our healthcare industry partners who have joined together to produce this response, we commend your efforts and stand ready to work with you every step of the way to see this vision realized. If I can be of assistance in any way, please do not hesitate to call me.
Sincerely,
Linda L. Kloss, RHIA, CAE
Executive Vice President and CEO