The Certification Commission for Healthcare Information Technology
Testimony at the Hearing on Functional Requirements for
The Nationwide Health Information Network
National Committee on Vital and Health Statistics (NCVHS)
July 26-27, 2006

Opening Comments

Good morning, chairman Cohn, members of the Committee, and fellow participants.  My name is Don Mon, vice president for practice leadership at the American Health Information Management Association (AHIMA) and industry liaison for The Certification Commission for Healthcare Information Technology.  It is the latter role in which I articulate CCHIT’s responses to the questions you’ve posed.  Thank you for allowing us this opportunity to provide input on issues related to the Nationwide Health Information Network.

Please be aware that, because of the timing of CCHIT Commissioner meetings, the response time was not sufficient for us to develop a position and take it to the full Commission for formal approval.  Therefore, the statements below represent the “initial thinking from CCHIT’s leadership” rather an official position by the full Commission.

Let me preface my remarks by explaining the certification process and the timeframes within the contract that CCHIT has with the Office of the National Coordinator (ONC) with respect to network components.  CCHIT will not certify network components before 2008, the third year of its ONC contract.  (In the first two years, CCHIT will certify ambulatory and inpatient EHR systems respectively.)

To certify network components in 2008, CCHIT must first assemble work groups comprised of volunteer industry experts in 2007.  These work groups will develop certification criteria for network components throughout 2007, and begin testing components for certification in 2008 or beyond.  It is the members of these work groups who would normally scan the industry, engage in collaborative projects—for example, coordinating certification with the harmonization of standards with HITSP—and evaluate the requirements you’ve posed in the questions below.

Obviously, given the timeframes for certifying network components, these work groups do not currently exist.  Therefore, CCHIT is unable to provide you with definitive responses.  However, we can give you our initial impressions from the staff and leadership of CCHIT.  Our initial input may evolve over time, and we may have different input for you once the work groups have been assembled.

1.   What are the “minimum but essential” network functional requirements for the initial roll out of the NHIN, i.e. the functions for the nationwide network itself, not for specific edge systems or entities?

As there are 1,139 functional requirements listed, it is more feasible for CCHIT to focus on the following domains which can be considered “minimum but essential” rather than identify a number of individual requirements.

  • Security, privacy, and confidentiality:  Controls for who has access to the record, who has accessed the record, and what was accessed, consistent with CCHIT’s Security and Reliability certification criteria, including authentication, authorization, auditing.
  • Patient identification:  In a NHIN environment, it will be extremely crucial that patient records are matched correctly before health information is exchanged
  • Completeness of the record:  Includes issues such as what data were sent, and whether there were subsequent updates to the health information by the data source (provider, consumer, etc.)

The above are the most essential requirements.  CCHIT recognizes that there are many more domains that are important to the operations of the NHIN.  The above requirements will be especially important if PHRs are considered, as they clearly appear to be, edge systems to the NHIN.

2.   For specific edge systems or entities, what functions would be ‘minimum but essential’ for linking to the network?

Minimum but essential functional requirements would be those consistent with CCHIT’s published certification criteria for ambulatory EHR systems, as well as emerging criteria for inpatient EHR systems.

3.   Where possible, please organize your suggestions by functional category from the June NHIN Forum document [see attached powerpoint].

No suggestions at this time.  CCHIT may offer suggestions once the work groups have been assembled.

4.   Please reference the draft NHIN discussion template developed by the NCVHS Ad hoc Workgroup on the NHIN to establish the context of your suggestions [see attached powerpoint].

No suggestions at this time.  CCHIT may offer suggestions once the work groups have been assembled.

5.   The Health Information Technology Standards Panel (HITSP) is identifying standards for the NHIN and for specific use cases.  In addition to HITSP’s considerations, are there other standards that you would like to bring forward for consideration to support the functional requirements you are recommending?

HITSP has done well to review the myriad standards that are relevant to their respective use cases.  At this time, CCHIT does not have other standards to bring forward for consideration.

However, there is request for clarification among the functional requirements.  Line 324 mentions “fully qualified PHRs.”  It is not clear what is meant by fully qualified PHRs, nor what is done to qualify them.  CCHIT raises this issue because there has been much discussion regarding whether PHR systems ought to be certified.  In conjunction, it also elevates the visibility of HL7’s efforts to develop a standard for PHR-EHR health information exchange.