Chris,

Funny you should mention [way way below] standardizing electronic
medical records. The National Committee on Vital and Health Statistics
released their latest recommendations on this topic this past
February.

Following is a cut-and-paste from  www.ncvhs.hhs.gov/020227lt.htm.
You'll note about a third of the way down that "NCVHS recommends that
HL7 be recognized as the core PMRI standard and that DICOM, NCPDP
SCRIPT and IEEE 1073 be recognized as standards for specific PMRI
market segments."

                    Dave Feinberg
                    Rensis Corporation
                    206-617-1717
                    [EMAIL PROTECTED]


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February 27, 2002

The Honorable Tommy G. Thompson
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C., 20201

Dear Secretary Thompson:

As part of its responsibilities under the Health Insurance Portability
and Accountability Act of 1996 (HIPAA), the National Committee on
Vital and Health Statistics (NCVHS) was called upon to "study the
issues related to the adoption of uniform data standards for patient
medical record information [PMRI] and the electronic exchange of such
information." NCVHS presented the results of studying these issues in
a report to the HHS Data Council on August 9th, 2000 (enclosed). This
report provided a framework to accelerate the development of PMRI
standards and a set of guiding principles for the selection of
specific PMRI standards. This letter sets forth recommendations for
the first set of PMRI standards, which are limited to PMRI message
format standards.

Standards for PMRI are important because they will facilitate
significant improvements in the quality of patient care, promote
patient safety, control rising healthcare costs, enhance the
productivity of clinical research and strengthen the nation's ability
to identify and respond to healthcare emergencies. They are critical
to the creation of a National Health Information Infrastructure.


Process to Select PMRI Message Format Standards

NCVHS used the following process for the selection of PMRI message
format standards to obtain industry input from standards development
organizations (SDOs), healthcare information system vendors, health
care organizations and professional societies, and other users of
these standards. First, the Committee adapted the PMRI guiding
principles to make them more appropriate for the selection of message
format standards. Next, the Committee incorporated the revised guiding
principles into a questionnaire that was designed to help NCVHS
evaluate the PMRI standards candidates in an objective manner.
Finally, the Committee compiled, analyzed, and reviewed the SDOs'
responses to the PMRI questionnaire. Additional information and
perspective about the candidate PMRI standards were obtained via
direct testimony from healthcare information system vendors and other
users of these standards. This process continued from December 2000
through February 2002.


Guiding Principles Used as Criteria for Selection

NCVHS recommendations for PMRI message format standards are selected
from the responses to the PMRI questionnaire of six SDOs:

  ASTM (American Society for Testing and Materials)
  DICOM (Digital Image Communications)
  HL7 (Health Level Seven)
  IEEE (Institute of Electrical and Electronic Engineers)
  NCPDP (National Council for Prescription Drug Programs) and
  Object Management Group, Healthcare Domain Task Force

The Committee emphasized the following four criteria derived from the
PMRI guiding principles: the degree of market acceptance of the
standard; the extent to which the standard enables interoperability
between information systems; the ability of the standard to facilitate
the comparability of data; and the aspects of the standard that
support data quality, accountability and integrity. The criterion of
market acceptance is helpful because it identifies those PMRI message
format standards that are implementable, cost-justified and flexible
enough to meet the needs of most of the relevant marketplace.


Recognition of Current Standards and Incentives for Emerging Standards

NCVHS has recognized the important role played by PMRI standards
currently used by the healthcare industry. Because it has taken years
for several of today's standards to achieve broad market acceptance,
they are based on older conceptual models. Those models do not
uniformly provide the high degree of interoperability and data
comparability that are necessary to support significant improvements
in healthcare cost, quality and productivity. To promote more rapid
realization of these benefits in accordance with the prior
recommendations in the PMRI report, NCVHS is recommending that HHS
provide specific incentives to accelerate the development and early
adoption of emerging PMRI standards as well as recognize current
standards.


Recommendations Encourage HHS Guidance and Incentives Rather Than
Mandates

NCVHS recommends that HHS set forth guidance for industry use of PMRI
message format standards and migration to new versions, rather than
create new federal regulations. NCVHS also recommends that the
Secretary direct government agencies to follow this guidance by
becoming early adopters of emerging PMRI standards, thereby serving as
an example and as an incentive to the industry. NCVHS further
recommends that HHS use its healthcare market position to promote and
encourage the use of PMRI standards.


NCVHS Recommendations for Specific PMRI Message Format Standards

NCVHS recommends that HL7 be recognized as the core PMRI standard
and that DICOM, NCPDP SCRIPT and IEEE 1073 be recognized as
standards for specific PMRI market segments. The recommendations for
all of these PMRI standards are set forth in a framework identifying
which version of the standard should be considered as retired,
current, or emerging.


Core PMRI Message Format Standards

Retired Standards

NCVHS recommends that HHS recognize the following PMRI message
format standard as retired.

  Health Level Seven (HL7 v2.1)

HHS Guidance to Government and Industry--Users should specify that no
new products using this version of the HL7 standard be purchased or
developed. Vendors and users should plan to upgrade any system using
HL7 v2.1 to a current version of HL7.


Current Standards

NCVHS recommends that HHS recognize the following HL7 versions and
transaction sets as the current PMRI message format standard.

Health Level Seven (HL7 v2.2, v2.3, v2.4, and later v2.x)
This includes standards for the following transaction sets:
  Order Entry
  Scheduling
  Medical Record/Image Management
  Patient Administration
  Observation Reporting
  Financial Management
  Patient Care

HHS Guidance to Government and Industry--HHS recognition of HL7
versions 2.2, 2.3, 2.4 and later v2.x, as current standards means that
vendors and users of these versions will not be asked to migrate to
newer versions until the more advanced version is fully implementable
with the supporting implementation guides and conformance tests.


Emerging Standards

NCVHS recommends that HHS recognize the following PMRI message
format standard as an emerging standard based on its potential to
provide superior levels of interoperability and data comparability.

Health Level Seven (HL7 version 3)
This includes standards for the following transaction sets:
  v3 Administrative Management
  v3 Health and Clinical Management
  v3 Infrastructure Management

Recommendation to HHS--NCVHS recommends that HHS provide
incentives to accelerate the development and early adoption of HL7
version 3 standards. These incentives should include but not
necessarily be limited to the funding of publication of version 3
implementation guides and the development of conformance tests, and
the early adoption of version 3 standards by government agencies.

HHS Guidance to Government and Industry--After the implementation
guides and conformance tests are available and early adoption of HL7
version 3 proves to be successful, additional HHS guidance to the
industry will be forthcoming.


Market Segment PMRI Message Format Standards

Current Standards

NCVHS recommends that HHS recognize the following as current PMRI
market segment message format standards based on their market
acceptance, ability to address specific market segment needs, and
their cost effectiveness.

Digital Imaging and Communications in Medicine (DICOM)--This standard
supports retrieval of information from imaging devices/equipment to
diagnostic and review workstations, and to short-term and long-term
storage systems.
NCPDP SCRIPT Standard--This standard communicates
prescription information between prescribers and pharmacies. These
transactions include new prescriptions, prescription refill requests,
prescription fill status notifications, and cancellation
notifications.

HHS Guidance to Government and Industry--New users should adopt the
latest versions of the DICOM and NCPDP SCRIPT PMRI market segment
standards whenever possible.


Emerging Standards

NCVHS recommends that HHS recognize the following as an emerging
PMRI market segment message format standard based on its potential for
vendor acceptance and its anticipated ability to address specific
market segment needs.

IEEE 1073 (1.1.1, 1.2.1, 1.3, 2.1.1, 3.2)--This is a set of medical
device communications standards also known as ISO 11073 standards.
These standards communicate patient data from medical devices
typically found in acute- and chronic-care environments (e.g., patient
monitors, ventilators, infusion pumps, etc.).

HHS Guidance to Government and Industry--Users should consider
becoming early adopters of the IEEE 1073 medical device communication
standard. HHS should encourage government agencies to pilot the use of
this standard where appropriate.


Harmonization among PMRI Message Format Standards

NCVHS recommends that HHS encourage PMRI SDOs to share their data
elements and data definitions with the U.S. Health Information
Knowledgebase (a metadata registry). Additionally, HHS should
encourage PMRI SDOs to continue their collaboration to reduce or
eliminate duplicate or inconsistent data elements especially those for
patient information. Furthermore, HHS should encourage PMRI SDOs to
harmonize their data elements and data definitions for future versions
so that they are consistent with the HL7 Reference Information Model
(RIM).

NCVHS also recommends that HHS provide funding to support PMRI
SDO collaborative efforts toward harmonization.


PMRI Standards for Future Consideration

In this letter, NCVHS has limited its PMRI-specific recommendations to
message format standards. The Committee plans to further investigate
medical terminologies and code sets and will be forwarding additional
recommendations to you. The Committee will also consider PMRI
standards for clinical documents and the content and structure of
patient records.

NCVHS wishes to thank you for the opportunity to submit these
recommendations within the framework of the Administrative
Simplification Provisions of HIPAA.

Sincerely,

/s/

John Lumpkin, M.D., M.P.H.
Chair, National Committee on Vital and Health Statistics

Cc: HHS Data Council Co-Chairs

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----- Original Message -----
From: "Christopher J. Feahr, OD" <[EMAIL PROTECTED]>
To: "Jan Root" <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>
Cc: <[EMAIL PROTECTED]>
Sent: Saturday, May 11, 2002 5:32 PM
Subject: Re: Data Downloads from DDE Applications

            <snip>

Virtually all types of providers have a need to share information
amongst themselves and to aggregate information about TREATMENT
across the healthcare industry.  So while we would all benefit from
standard medical record structures, etc., I don't think we want 15
different provider groups "standardizing" medical record formats
individually.  I'm not even sure which existing SDOs would want to
tackle national EMR standardization.  Does anyone know who might be
working on EMR standards now?

            <snip>







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