[This Transcript is Unedited]

Department of Health and Human Services

National Committee on Vital and Health Statistics

Subcommittee on Standards

December 2, 2014

US Department of Health and Human Services
Hubert H. Humphrey Building, Room 705-A
200 Independence Avenue, SW
Washington, DC


Standards – Projects and Work Plan


Agenda Item: Standards – Projects and Work Plan

DR. SUAREZ: We are going to call the meeting to order. The Standards Subcommittee of the National Committee will be meeting. Our agenda primarily focuses on really going over our plan for 2015. That is primarily the goal of this session. We will talk about what we are going to be doing throughout the year and then specifically highlight some of the points that we are going to be addressing in February, since February is just around the corner. That is our main purpose of the meeting.

I don’t know if, as a matter of course, we should go around and do introductions again.

MS. JACKSON: I think those who were not at the table can identify. Otherwise, we already have who has been at the table.


DR. SUAREZ: I think we are set to go. As I mentioned earlier this morning when we were talking about the Affordable Care Act Review Committee, we put together a series of slides. They were in your packet. We are going to go through some of those slides now, the ones that we did not go through this morning, and cover a few of the items with respect to our 2015 plans for the Standards Subcommittee.

I will start on page two. Page two is basically the outline of the material. We can probably skip that and really get into the first part of this. I think it is always good to, as we get to the end of the year, look back and review some of the important accomplishments and achievements that we had. These next two slides tried to do that, summarize basically the main outcomes or outputs and deliverables from our subcommittee.

During the year, we convened two major hearings, one in February focusing on the topic that you see on this slide, operating rules, ICD10, plan ID, pharmacy prior auth. In June, we had our larger hearing covering several additional topics, including the DSMO report, virtual cards, coordination of benefits, attachments, UDI. We also, throughout the year, prepared and submitted eight different letters of recommendation to the Secretary of HHS dealing with the topics that you see here. It is interesting that one of the letters, the one coming out of the February meeting dealt with several issues in one single letter, whereas, some of the other letters were more single issue letters or single topic letters. I think they reflected, basically, all of the topics that we covered during the two main hearings that we held during 2015.

On slide four, we also highlight the completion of our 11th HIPAA report to congress. We also note that we were named – the National Committee was named the Affordable Care Act Review Committee by the Secretary of HHS. The subcommittee helped develop a charter for the review committee and sort of develop this work plan and process plan for 2015.

We also had the opportunity to present the work of the subcommittee to various audiences, national audiences, including other FACAs and other national events. We certainly continued to work on our sort of convergence and harmonization and collaborative work with other NCVHS subcommittees and other FACAs as well. It was really a busy year.

I am going to skip to slide number nine now – sorry, number eight, which highlights the topics that we identified as the ones that we want to cover or plan to cover in 2015 as a subcommittee. We are on slide number eight. The main items here are, first of all, start Affordable Care Act Review Committee process and initial deliverables. We talked already about what we will be doing in June of next year with respect to the Review Committee and, between now and June, of course, the work in preparation for that first sort of launching and the first review committee hearing. Take action on operating rules for the remaining transactions. That is one item that we have outstanding for 2015.

Follow up on topics that we covered in 2014, including several topics, ICD10 attachments, and then having some placeholder for possible topics such as follow ups on virtual cards, plan ID, UDI, and administrative transactions. Some of these are more placeholders. They may not come up in specific hearings during the year, but we wanted to still keep it as a placeholder for possible topics. These are certainly topics that while we addressed them in 2015, it doesn’t mean that they are done and over with. I think this is all part of the journey and the process that we follow. We will keep an eye on them.

Next steps on population health and public health standards is another one of the topics. We will talk more about each of these items in a minute. There is this new topic that we wanted to bring forth to the National Committee. That is standards for transparency in healthcare. Again, we have a couple of slides to talk about it. We will cover it in just a couple minutes here.

We also have, as other topics, the administrative transactions used in healthcare reform. As we know, there has been a couple of important transactions being used in health reform. It will be important as we are in the middle of the second round of enrollment process to look at how those transactions are working for health reform. Administrative transactions in other settings like long-term care and behavioral health is something that we mentioned earlier this morning as well.

Then this whole area – two areas of the next generation of transactions that are needed, really, to support health reform. The traditional claim, while it will continue to exist, of course, would need to be supplemented with other types of transactions that would help support a payment reform and care delivery reform.

Wrapping all of this around the eHealth roadmap, which I know we have done a number of things about it and we have been working on it off and on, we know that CMS has done some work about it as well. CMS just, of course, announced there was going to be a planned eHealth Summit this coming Friday. It had been postponed for the spring of next year. I think that is part of what we will be carrying into 2015.

Let me get into some more specifics. With respect to hearings and roundtable, these are our initial plans basically. We would be planning to hold a hearing in February covering basically topics such as certainly the operating rules for the remaining transactions, transactions in health insurance exchanges, just about in time after the end of the enrollment process, ICD10 maintenance process – so now that we would be looking at the transition to ICD10, there are some important questions and points of discussion regarding maintenance process of ICD10 and then some of the codes that have been frozen while we finish the transition – and a couple of other possible topics, including health plan compliance certification. We might, depending on how things evolve, see that there is a final rule out before the hearing. We might have something to say about or talk about. If not, then we will postpone that until we see the final rule around it.

That is our plan for the February hearing. The June hearing I mentioned already. This will be the Review Committee hearing. We talked about it earlier this morning. Additionally to the work of the Review Committee, we might be asked to review attachments again because there might be some final recommendations around the standards for attachments coming out of the standards development organizations, the updated versions of the standards for attachments. We might be asked to consider including that in the June hearing.

For the later part of the year, we have – either in the September or the November timeframe – possible hearing or it could be even a roundtable around these other topics, including the topic of transparency in healthcare, population health management, and public health standards. We will mention them again in some more details in a minute. That is our layout for the work plan for 2015 at this point.

I am going to skip all the way to slide – I think it is 20 something. It is 22. We are getting there. We talked about all the Affordable Care Act Review Committee already and the hearing. I mentioned the other important topic we will be addressing or we plan to address in 2015 is the next activity that we will be doing on population health and public health standards. Just a point of comment, there has been significant support throughout the public health sector on the series of recommendations that the National Committee made to the Secretary in June 2014, the letter that we put together with a series of recommendations around enhancing and advancing the public health information infrastructure. There has been strong support throughout public health.

Really, the next step on that is what can we do to help operationalize those recommendations really? What are some of the actionable activities that can be undertaken to help operationalize – help those recommendations to really happen? We will be working with HHS and the public health organizations to identify and define these actionable next steps.

We do expect that there will be a significant push in 2015 to enhance public health information infrastructure. You heard the presentation about the surveillance system and surveillance strategy at CDC. There are certainly a lot of expectations around increased exchange of electronic information with public health, whether by virtue of Meaningful Use or other function. Certainly, we see that this is going to continue to be a significant topic in 2015.

The two proposed activities in this regard in 2015 are the following. First of all, we think it would be important to organize a second hearing, public health or population health standards hearing, that would focus on the state of implementation of the public health electronic information exchange standards, including some of the things that were mentioned, Vital Statistics Standards, and build on the topics that we talked about in 2014 – actually, the November 2013 meeting where we discussed the public health information infrastructure. That is one of the activities. The timeframe for this, as is noted here, is really more like Q3 or Q4 of 2015. This will be the latter part of the year.

The second activity is something in partnership with population health and privacy, to organize what we see could be a workshop or roundtable on population health management that would allow us to bring – sort of serve as a forum to discuss both electronic standards and best practices for population health management. Certainly, it has been noted throughout health reform, population health management is really a foundational component and critical element of the success of health reform. This built on the work of NCVHS in this area. I think there are a number of strong possibilities of partnership with national foundations to discuss this and perhaps come back with some possible observations and, certainly, recommendations. Again, the timeframe for this would be also Q3 and Q4 of next year.

Those are the two public health and population health-related activities. This new topic that we have been approached to address is the healthcare transparency. What this means – what this is about is really the fact that one of the core foundational elements, also, of health reform is the concept of transparency. It is really considered a critical element in achieving the goals of health reform. Much talk has been done around the topic at various levels and in different domains, including transparency on quality and performance, on service availability, on cost, on pricing. All of these are “transparency” topics – the privacy and the security implications for some of the transparency information. There is a lot of discussion around this.

Really, the challenge is there are limited gains and limited accomplishments across this transparency topic and limited standards, really, as part of the reason why there are limited gains around transparency. The question about what is the actual standard or set of standards that are being used to achieve transparency, whether it is price transparency or cost or quality or performance.

One example of transparency is the current experience with insurance exchanges and certainly the concept of price transparency, having the price right there in front of people for the specific levels of coverage or service coverage, but then there is the expectation that there is need to do more about price transparency all the way down to individual procedures and other things. Actually, we were approached by industry to help lead the discussion or a discussion on transparency and explore some of the best practices and possible standards that could be recommended for the industry to follow in achieving transparency in healthcare.

Many of you saw recently the call for ideas from Secretary Burwell on increased transparency. Just only a week ago or so, a message came out from the Secretary soliciting ideas for an increased level of transparency. The proposed approach that we have here is to convene some sort of an activity where there is a workshop or a hearing or roundtable on the topic of transparency in healthcare, again focusing primarily on what are the current practices, what are the standards, what are the gaps, and what are the opportunities for improving and advancing the issue of transparency and health here. This would also be something that we would look to do in the second part of the year, not necessarily during the first part of the year.

There are all sorts of additional topics that we are bringing in and kind of mixing throughout the year. The eHealth Roadmap and working with CMS to define possible next steps – again, a summit in 2015. This would not be something that NCVHS would be doing, actually. This is more partnering with CMS. CMS has been leading the convening of this summit. This will be something we can work with them.

I mentioned administrative transactions using health reform. We have already incorporated or included this in the February hearing looking at enrollment eligibility and other transactions. This will be one of the topics for Q1 hearing. I mentioned administrative transactions in long-term care and behavioral health. I think this will be considered part of the Review Committee activities, checking into how these transactions are working for long-term care and behavioral health and other healthcare settings.

The entire discussion on the next generations of transactions to support health reform, we did not really propose any concrete activity around it, but I think we will be working with industry on looking at how to define some of those new transactions that would support the various emerging payment reform models.

Putting all of this together into a matrix, here, you can see what we have done. In quarter one, the topics for the subcommittee discussion will be those that I have mentioned already, operating rules, having initial discussions on transparency, planning our Review Committee hearing in June, and then working with CMS on the Roadmap Summit. The actual hearing, you can see this in the topics. This is sort of bringing all of the information into a metric. Again, as a subcommittee, not only do we actually convene the hearing and work on the preparation for the hearing, during the time between hearings, we also work on other topics like planning and discussion of other topics. That is what the first role is really here, a series of topics that we will be discussing during the year, in between hearings and in between NCVHS meetings. The actual activities, you see it in the second row.

The letter and reports you see in the third row. We don’t expect, certainly, to have any letters for the February meeting of the National Committee, but in the second quarter, in the May timeframe, we would expect to have a letter from the February hearing. In quarter three and four, we would have – in quarter three, in September, we expect to have a letter from the Review Committee hearing in June.

I think that is basically the last slide. I will stop here. Terry, do you want to add anything?

MS. MTUI: A question from one of our online listeners. What does take action on operating rules for remaining transactions mean? The ACA says these are to be implemented by the end of 2015. Payers need lots of time to do that. Will that 12/31 due date change? Or when will we get our final marching orders?

DR. SUAREZ: Great question. I am not the Speaker of the House to be able to actually say anything about the changing of any deadline that is in statute. Indeed, the deadline that is written in the statute is for the remaining transactions to begin to be implemented on January of 2016. In fact, the regulations were supposed to adopted early next year or January of this year.

In any case, to answer the question, I think what the intent is, first of all, is to receive the recommended operating rules from the operating rule authoring organization or authoring entity. The operating rule authoring entity is working and finalizing the operating rules for the remaining transactions, except for one, which we don’t have a standard yet. It wouldn’t make sense to put operating rules in it. That is attachments. Attachment is one of the remaining transactions, but the other remaining transactions are the healthcare claim, the enrollment transaction, the prior authorization – in any case, there are five with attachments.

We will be receiving, as a national committee, the recommended operating rules for the transactions. What we would do is we would evaluate those recommendations from the authoring entity. In February, during the hearing, we will invite testimony about them, and then we would make recommendations for the adoption. From there, the Department of Health and Human Services would need to prepare regulations to adopt those standards. In the regulations, there will be a compliance data, which I would expect would not be effective date, I guess – the effective date when the operating rules would be expected to be used. I don’t expect that day will be 1/1/2016. The regulations may not be finalized by June of next year. There would not be enough time.

I cannot speak for the Department or for CMS with respect to any timeline or anything like that. That is the process that we would follow as a national committee. We would receive the recommended operating rules, we evaluate them, and then have the hearing in February to hear testimony about those, and then make recommendations to the Secretary and the Secretary will take the next step of considering those recommendations. If so, preparing regulations to adopt them.

MS. DUETSCH: I just wanted to say that we have a very ambitious plan here. We recognize it. We had a lot of discussion on that. It takes a lot of work for the members of the subcommittee and then, in turn, the members of the full committee to go over our recommendations. We are looking forward to having a very productive year ahead. We are very eager to have you all help us in the process. Thank you.

DR. MAYS: I like your work plan. I agree that it is ambitious. I have a few questions and a few suggestions. On 22 when you talk about public health, can you tell me what organizations you are thinking about specifically where it says working with HHS and public health organizations? I just want to get a sense of whether we should be suggesting some more. That is question one.

Question two, on 23, I kind of have the same questions about the national foundations. We have kind of struggled with some of those. You used the word partnerships. Some of them, it is hard to have a partnership with a foundation. I am just trying to get a sense of that and which ones you are thinking about, whether we should suggest any others.

Transparency, when you were talking about that, I just want to say that I think it should include access to data about quality and performance. I think the workgroup might be helpful to you there. That has become, for consumers, a big issue. What happened here? What is the service like? All the data that they are getting ready to collect about patient satisfaction and some other things, people are asking whether or not they are going to be able to get those. I would raise that.

My other one is on page 26, I just wanted to get a sense, under the administrative transactions for behavioral health, whether you are going to think about the same day billing problems in Medicare, whether or not that is one of the things that you are thinking about. You can bill on the same day for both behavioral health services and physical health services. It really is a big problem.

The last one is whether or not you can put into February for us to have the discussion we talked about earlier on the issues.

DR. SUAREZ: Definitely. Let’s start with 22. The public health organizations noted there are actually the members – among the members of JPHIT. We have been and I have been bringing this up periodically. We have been discussing at JPHIT what specific, actionable activities and recommendations can JPHIT, for example, make back to us with respect to operationalizing the recommendations from that June letter. That is one of the groups that we are working with as a subcommittee. We have this series of recommendations that we made. What would be some of the things that organizations like ASTHO and NACCHO and APHL and CSD and all the other partners in JPHIT could provide, in terms of, again, actionable activities? Those are the public health organizations we have been working with. If you have additional ones, we can certainly –

DR. MAYS: I was going to suggest if APHA isn’t in there that you get that.

DR. SUAREZ: APHA is not in there.

DR. MAYS: They have a HIIT that is done by a colleague. They are kind of looking for issues to take up. They are fairly big.

DR. SUAREZ: Absolutely. Great suggestion. The next one is 23, here, partnership and then you were talking about the national foundations, right?

DR. MAYS: Yes.

DR. SUAREZ: I just actually – as I was coming here, I just saw the Robert Wood Johnson Foundation is convening a second summit on transparency coming up next year, early next year or sometime next year. Specifically, that particular one is going to be talking about the balance between transparency and privacy. That is the kind of organization or foundation that we were thinking about considering partnering, the Robert Wood Johnson Foundation, who has been working in this field of transparency, the Commonwealth Fund, and some of those organizations that would be interested in a roundtable discussion around transparency and standards.

DR. MAYS: You may just need another term. There are these rules. We work with some of the foundations. Partnership is hard for them. They have these rules. I am just warning you. I don’t want you to send something and you get a no and it is just because it is the language issue.

DR. SUAREZ: Thank you for that catch. The first partnership is okay. The word partnership works here because this is partnering with the subcommittees. It is the second partnership word that is a problem.

DR. MAYS: Yes. Alliance, collaboration –

DR. SUAREZ: Better word. Thank you. Absolutely.

Then the next question was on 26. On 24, we will be adding –-

MS. GOSS: She actually wanted transparency, which was Slide 24, 25. I knew I wanted to add something to her comment about the working group on data access and use.

DR. SUAREZ: Yes, that is where I was going — 24. On 24, you suggested adding access to data regarding quality and performance. I think absolutely. That is part of the goal really is to try to have better understanding of what would be not just the standards for releasing or making available data, but improving the access to that data. But improve the access to the data that is in a standardized way, otherwise, people will be comparing apples to oranges, as they say. Absolutely. That will be one.

Just to — the last comment maybe, on Page 26, long-term care and behavioral health. I think you bring an excellent point. That is actually — certainly, part of what we are looking at as part of the review committee is how is the standard working for organizations like behavioral health. This is clearly one of the topics that we will be including and thank you for highlighting specifically that point.

I think we had Bruce and Bill. Alix, I do not know if you want to highlight.

MS. GOSS: Mine is specifically on something Vickie said. It is in regards to the word standards and the transparency concept of the new workload that we are going to pick up. It seems to me that standards could maybe be better described in this case as needing some underlying principles, which seem to go back to what Vickie was saying. But I also see it linking over to our privacy and confidentiality. We talk about standards. I am thinking the nuts and bolts for the subcommittee like the transport data content format standards. But in order for us to do that effectively, I think we have to start with the principles. I am thinking this is a good point of further convergence and maybe it is not just something — maybe it in one of these where we all work together to create the initial framework and then there are separate pieces of work that go out to the subcommittees or the working groups and they need to come back in an iterative process to morph this.

We have been doing the standards work for a while and having hearings and hearing feedback and I think maybe this is an opportunity for us to even apply some of our own lessons learned.

DR. SUAREZ: Great point. I think when I was approached and brought this up to Jim and to Larry, I think there was a consensus that this is really not a standards only kind of activity. This is truly a National Committee topic. I think Larry said it in a nice note saying I look forward to hearing about what the Standards Subcommittee had discussed about this. I think that is what we will be attempting to do is really making this truly a national — not all the topics — nowadays more and more all national committee topics, but this particular one is a much higher level topic. I agree. Thank you for that.

DR. COHEN: I could pick up on Alix’s theme. Slide 23. The theme about having subcommittees lead work, but converge with work of all subcommittees. Could you expand on what you mean by population health management? Who would you invite, what it would cover, and what specific kind of standards and how that does integrate or converge with some of the work that we are leading in the subcommittee.

DR. SUAREZ: I think generally the idea had been to bring together different organizations that perform population health management from different perspectives. The definition. I think we actually had a definition of population health management at some point. I think conceptually it is really covering the series of activities that organizations where they are in the private sector within a health care provider system, an ACO, a patient-centered medical home, even a health plan. And then on the public sector in public programs including the VA and Medicare and others and certainly the public health agencies. The activities that they do to manage the health of their populations that they are responsible for. Again, each one has its own way of thinking about it and interpreting it. But in some ways, there are opportunities to really highlight what are the practices and approaches that ACOs are taking to achieve population health management, which is a major responsibility in their health reform. What are the activities that health integrated delivery systems are doing to achieve that even if they are not an ACO? What are some of the activities that health plans are doing to do that as well?

And then bring the perspective of public health. How can some of those practices supplement or integrate with the work that public health is doing in the populations that public health agencies cover? That is generically what the idea would be.

The way I would think of it is really bringing in for testimony if it was a hearing perhaps. Again, this could be a different mechanism, a roundtable, a workshop rather than a hearing. But it would be inviting all the constituents from public health agencies and public programs all the way to health systems and ACOs and health plans to talk about their practices on population health management. Identify what are some of the key standard elements in terms of use of data, use of health information technology to achieve population health management. That is as much as I think we have really thought through the details about this opportunity. It is certainly something to discuss as a full group.

We do not necessarily have to finalize everything today of course or tomorrow. We have time to continue discussing this as a possible activity for later next year. But it is something that we wanted to bring up as an opportunity for us to cover.

DR. COHEN: I think you are right. We have not really worked with the direct care providers to understand where they are in terms of their data needs and their activities that would help fill a gap in the niche when I look at the Full Committee. We have folks working in different pieces. If that is the focus, I think that could be very productive. Cool.

One other question. This is sort of a non-standards question. It has to do with since you are on JPHIT on the steering committee or whatever, I feel like we need to respond to them officially. What do you think we should do?

DR. SUAREZ: Yes. Normally as a National Committee, we receive these types of letters. In the past, we have received these types of letters. What we do is we first discuss it as a group. My suggestion as we were talking outside is really bring this up. This is much more of a population health discussion with the involvement of us here in standards. But the fact that the letter had the name of Larry going to Larry, but then copying me was more of a courtesy because I am a member of the JPHIT board. They copied my name in there.

But it was not intended to come to the Standards Subcommittee as a Standards Subcommittee activity. It was really intended to come to the National Committee for discussion. I think, as you highlighted earlier, Bill actually mentioned it too, this should be discussed first within the subcommittee, and then once the subcommittee determines what is the opportunity, a simple message back could be drafted and sent to JPHIT. I think it will be appropriate to certainly send a letter back or communication back to JPHIT. But after we have that discussion on the Population Health Subcommittee, perhaps tomorrow morning if you have some time. I think that is the response that we would see happening.

I am not aware of what action is the Health IT Policy Committee or Health IT Standards Committee taking on this same letter that they received as well. This is the procedure that we usually follow ourselves here in the National Committee. That would be my suggestion as we discuss it tomorrow and then decide what kind of response we can craft.

DR. STEAD: Awesome job of putting forth opportunities ranging from vision development to nuts and bolts. I guess from my perch, it would be helpful to know what your thoughts are about rate and pace. It seems to me that in taking on the review committee that is a major new developmental activity that in many ways the June hearing for all practical purposes will be an additional two-day meeting of the Full Committee to the degree we can calendar it and get us there. It is a major new activity for the year. Maybe it will be less major downstream, but it seems to me from all of us for 2015, it is a major new activity.

It seems to me somehow our plan has to reflect carving out some additional bandwidth from that if we are not going to lose traction on some of the — have the focus to get traction on the other things. It seems to me it would be helpful if — suppose it did not all fit in 2015. How would you actually envision laying it out or how would the subcommittee envision laying it out over three years? Maybe there are initial conversations around transparency this year. Maybe some of those are at the level of the Full Committee because it is a Full Committee question whatever subcommittee works it. Then where does one get to hearings to — enough of a definition of transparency that would even know how the standards or whatever are plugged in. And then what kind of hearings maybe downstream of that. That may be a three-year project to the first deliverable or not. I do not know. It would be nice to have that lens on some of this that might help us as we begin to try to harmonize the plans. That would be one thought that in a way is trying to organize things on the table that we know when we are eating what over time.

A second thought was almost might be trying to layer something back on the table is where we really do stand with the idea of the eHealth roadmap because the mental model that I carried away from the conversations we had of that maybe two years ago. I no longer remember exactly. It was that we really would get — we would lay out how we would get in my words beneficial occupancy of related standard activities that came together in critical milestones that collectively got us a step in recent performance.

I would advocate that that — I would rather not have that crowded out in some way if there was a way to avoid that. I think that is still a really important thing to do. Those are two ideas that maybe compete with themselves, but I just put them out there for you.

DR. SUAREZ: Thank you. Excellent points. A couple of reactions to that. Certainly, it is an ambitious agenda just to point with respect to the review committee, the good news is that we have been doing that already. The only thing we are adding is one additional day for the hearing. But every June we actually do this type of a hearing that convenes and talks specifically about the status of the standards. We do not cover all the standards in one single hearing. This will be the one hearing where we would be talking about all of it to set the baseline really as we move along. No disagreement. This is an ambitious agenda.

What is interesting is we know a lot more about what we are going to do in February and in June because of these two activities. After June, we have an open space. We do not have any pressing priorities really. Clearly, all of these are priorities, but we have an opportunity to say in the second part of the year, we can take on something else. We have done the hearing in February and the review committee hearing in June. In September and in November and through the second part of the year, we really do not have any other topics except for the ones that — that is why we plotted it that way, certain entire plans for the subcommittee. We said this is what we think we can do in February. This is what we can do in June. And then what can we do in the next six months or the second part of the year? We added the topics of transparency and population health. That is part of it.

With respect to the eHealth roadmap, we really realized, as we were getting into this, that this was going to be a major topic. There are a lot of roadmaps that have been written recently including the ten-year vision roadmaps for interpretability. The roadmap for health information exchange. These are major efforts.

We really saw the opportunity to partner with CMS in pursuing that. Clearly, we have not really moved farther into developing that. I agree. I think that would be one area where we can certainly focus our attention to.

DR. STEAD: That is a very helpful clarification. Knowing that we still have — we are still going to have the privacy and subcommittee plan and knowing that we are still going to have the population health plan. As we think about creating a harmonized plan for helping Debbie create or helping us or however we do that, it may well be that what you are saying is you have really heavy lifting in the first half of the year that may well crowd out a lot of other activity. We may then want to be sequencing some of these other things into the second half rather than filling the white space all from standards as we just think about the fact we are working increasingly as one committee. I am just trying to think about how we harmonize it. I would love to see us somehow get it into almost working a three-year roadmap as a whole committee if there was a way we could ever get to that.

DR. SUAREZ: Definitely. As a Standards Subcommittee, we offer a standard template to do that. I think the ideal mapping is to take this chart, for example, and instead of the rows being the topics, could the rows be in the subcommittee activities or conceptually the subcommittee domains, not to call it subcommittees, but the domains. What is standards doing in quarter one? What is privacy? What is population and what is data access? If we all produce a table like this, it will be easy to create a larger, more comprehensive table for the entire subcommittee for 2015 and then we can actually expand it to 2016 and 2017 and try to look at a longer-term plan. I think that is a really great idea to move forward.

DR. COHEN: Do we all have Word versions of this?

DR. SUAREZ: We will send you the Word version. We will send you the Word version because even the Power Point version — this is a Word table that is — we will send you the Word version of the table.

MS. KLOSS: Bill really introduced the topic I was wanting to raise. In five minutes, we are going to turn our attention to privacy. We are going to see some great ideas also. And then in the morning, we will layer on the population. And then I think we will have to step back and look at this, not only in terms of member resources, but in terms of staff resources and the reality that we will have a little bit of committee rebuilding new members, new chair, other things happening next year that take also some time.

When I look at this list — I am a member of the subcommittee and I think it all needs to be done urgently. As I look at it, I think there are two things on here that are really must do with the cornerstone certainly being great success with the launch of the review committee.

Even though we have done this before, we have not done the pre-work of developing the evaluation criteria, which I think is going to be something that the whole committee could kick off as a group.

And then your quarter one state of the standards for the things that are still needing to move to adoption and new operating rules. Those two projects need to get done. I am assuming that we are going to forego the HIPAA report to Congress next year.

DR. SUAREZ: I would expect that that would be the case. Yes.

MS. KLOSS: And then the things that you identified in quarter three and four really could probably benefit from some Full Committee dialogue, as we have said, and then decide how it parses out. Is that right?

DR. SUAREZ: You are absolutely right. Those are the two priority activities, the must-do activities. The others are topics that we have identified as opportunities to continue advancing the work that we have been doing in the past.

Here is one suggestion. As we hear the presentation from Privacy and then tomorrow from Population, I will be happy to on the fly create a chart that highlights the work of each of the domain areas. And then during tomorrow’s discussion as a full group, we can plot things in a presentation format. I will use this type of table. Instead of the rows being only standards, it will be the standards, population, privacy, and data access. On data access, we will talk, I suppose, after tomorrow afternoon, but at least those three domains we can talk about them and see how they plot. Even add next year like 2016 timeframe as well so we know what things can be plotted into 2016 activities. I will be happy to as we go into the next presentation.

MS. KLOSS: We just really have about 45 minutes tomorrow to bring all three together, which is not — so it is helpful if we start by this idea of layering on and then see where we are at.

MS. JACKSON: It is in your agenda. It is in your booklet where I tried to lay out the 2015 for the year — quarters with all the subcommittees. Some of that is in there and then we can feed into something that can do a much better graphic and chart with.

DR. MAYS: Maybe one of the things for us to think about because if you look at our productivity over the last year, it really has been because of the extra things that we have gotten like either a person, someone who has come in as a consultant or something. Maybe as we do some of these items because you are talking about all these partnerships or collaborations.

Maybe we also should be thinking about if there are people who might join to actually help. Because when you talk about the behavioral health stuff, it is probably possible that we can get SAMHSA to the table to help. I think some of us need to — because otherwise we are going to make a decision and it is going to be the freak out of what we have and how much we all cannot keep piling our plates up. It was great when you watched the toolkit and everything else because of these individuals. It was just one sometimes. One person made such a big difference. Let’s try and see if we can do that and then to note that if we get A, then we can do A, B, and C. If we don’t, then think some other ways about how to get all this work done.

DR. STEAD: I resonate back with Linda’s point in the discussion earlier. That as a Full Committee, we have actually got to come — somehow we have to come to an agreement on the measurement criteria for the effectiveness and evaluation. What happens if we do not come to agreement on that in February? Is June a drop-dead date for the hearing or can that hearing be in the fall if it has to be? What if we have to have an initial hearing around effectiveness and how you measure effectiveness of the standards?

DR. SUAREZ: That is a great idea, too. We do not live through traditions. We do not stick with it has to be in June. It can certainly be considered to be moved if we think it is —

MS. DEUTSCH: There is a statutory requirement.

DR. SUAREZ: Terry is mentioning that we probably missed already a statutory requirement, which was starting April of last year or this year. Anyway, there is some interest and opportunity in having it in June. But if it happens to be something that the committee feels —

As you pointed out, Bill, there are two different concepts about metrics we are talking about. We are talking about metrics to evaluate the standards that are in place. Separately, we are talking about metrics to evaluate health reform. That is totally different. That is a different measure. Much bigger topic, I would argue. The metrics for evaluating, not to minimize them, but the metrics for evaluating the standards are things that are going to be less significant in terms of its impact I suppose than the ones dealing with the metrics we evaluate the Affordable Care Act. They are both together. I just wanted to clarify that.

We feel that it would be possible to work through between now and June of next year the details about the evaluation criteria given that we have already actually identified guiding principles around it. But we will see how it evolves between now and February when we will be coming to the National Committee to talk about it.

Any other questions? Any other comments? Thank you very much. I think, Linda, you are next. The Privacy Committee. It is four o’clock. I do not know how we are keeping up with the time here, but it is perfect timing. Thank you.

(Whereupon, the subcommittee adjourned.)