Data Portability Requirements for EHRs

Transcription

1 Data Portability Requirements for EHRs Robert Rogers Chief Technology Officer Open Source EHR Summit and Workshop Gaylord National, National Harbor, MD October 18,2012

2 Disclaimer Application Matrix, LLC is not a legal firm, and does not provide legal advice or counseling. Consult your attorney before making any records retention/disposition decisions.

3 Data Portability Questions* (March 2012) 1. Is EHR technology capable of electronically providing a sufficient amount of a patient s health history using export summaries formatted according to the Consolidated CDA 2. Is it necessary to migrate all of the data in a provider s EHR #1 to EHR #2 3. What additional standards and guidance would be necessary to meet market needs for data portability 4. Could a specific set of patient data be used as a foundation for an incremental approach to improve data portability for the situation *Federal Register / Vol. 77, No. 45 / Wednesday, March 7, 2012 / Proposed Rules

4 Why Data Portability Records lifecycle is decades long Archival preservation Software systems require upgrade, replacement, consolidation, segregation Meaningful use is accelerating these processes Parallel coexistence and serial reuse Cloud computing De-identified health research data

5 Data Portability Comments* (Sept 2012) Medical record retention laws, as well as those governing fraud and abuse investigations, largely determine the amount and type of information that must be retained, and therefore, needs to be portable. There may be other reasons for retaining longitudinal information on patient care, such as clinical trial participation, post approval study requirements and other clinical reasons. Many commenters stated that some data loss is inevitable The Consolidated CDA is designed to be a summary and would not capture longitudinal patient information, administrative billing data, or other necessary data *Federal Register /Vol. 77, No. 171 /Tuesday, September 4, 2012 /Rules and Regulations

6 Issues to be Addressed Content Classifications, controlled vocabularies, etc Structure Data type, schemas Technology Messaging, authorization and authentication, storage Organization Process, procedures, workflow, roles

7 Data Portability Certification* Enable a user to electronically create a set of export summaries for all patients in EHR technology formatted according to the standard adopted at (a)(3) that represents the most current clinical information about each patient and includes, at a minimum, the Common MU Data Set and the following data: 1. Encounter diagnoses 2. Immunizations 3. Cognitive status; 4. Functional status; and 5. Ambulatory setting only. The reason for referral; and referring or transitioning provider s name and office contact information. 6. Inpatient setting only. Discharge instructions. *Federal Register /Vol. 77, No. 171 /Tuesday, September 4, 2012 /Rules and Regulations

8 Digital Curation Ensures Long-Term Information Quality and Usability Preservation Services: Protection Authenticity Availability Audit Logs Security (Access control) Confidentiality (encryption & key mgmt) Digital Auditing Non-repudiation Disaster Recovery/Business continuity Ingestion Transformation Provenance Preservation Objects Discovery Physical Migration: Media migration Self Healing Systems Logical Migration: Emulation Transformation Encapsulation Audit log, trail, & metadata Virtualization Cloud Digital Preservation: Unique attributes of the Cloud Cloud Archive Services Virtualization

9 Digital Curation Lifecycle Model Source: Digital Curation Centre dcc.ac.uk

10 Technology Futures Cloud Computing Infrastructure as a Service (IaaS) Platform as a Service (PaaS) Software as a Service (SaaS) Private Cloud Public Cloud Hybrid Cloud

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12 Summary The new data portability certification is a start in the right direction. Issues of long-term preservation, authenticity, and curation demand more specialization than general IT services Cloud-based services are disruptive new technologies to be investigated after virtualization Maintaining information coherence over long periods is key