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HIT Policy CommitteeHIT Policy Committee

Nationwide Health Information NetworkNationwide Health Information Network

Governance WorkgroupGovernance Workgroup

Recommendations to HITPC on Nationwide Health Information

Network Governance

John Lumpkin, MD, MPH, Workgroup Chair

Robert Wood Johnson Foundation

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Workgroup Members

Members: Laura Adams Rhode Island Quality Institute

Christine Bechtel National Partnership for Women & Families Carol Diamond Markle Foundation

Linda Fischetti Department of Veterans Affairs

John Glaser Siemens

Leslie Harris Center for Democracy & Technology

John Houston University of Pittsburgh; NCVHS

Michael Matthews MedVA

John Mattison Kaiser Permanente

Girish Kumar Navani eClinicalWorks

Tim OReilly OReillyMedia

Wes Rishel Gartner 2

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Chair: John Lumpkin, Robert Wood Johnson Foundation

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Discussion Topics

Workgroup Status

Recommendations

Appendix (separate deck) Governance principles and functions

NW-HIN as preferred approach

Federal, ONC and shared responsibilities

Conditions of Trust and Interoperability Validation

Public comments

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Workgroup Status

October 2010: Phase 1 recommendations

NW-HIN* governance principles.

NW-HIN governance objectives and functions.

November 2010: Preliminary findings and recommendations

NW-HIN governance functions and objectives. Governance roles and responsibilities.

December 2010: Final recommendations

Principles

NW-HIN as preferred approach

Federal leadership and shared responsibilities NW-HIN Conditions of Trust and Interoperability (NW-HIN COTIs)

NW-HIN Validation

Oversight

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* The nationwide health information network is in the process of being

renamed. The acronym NW-HIN is used solely for convenience.

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Recommendations to HITPC

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Recommendation 1: Nine Sound Principles for

NW-HIN Governance

1. Transparency and openness

2. Inclusive participation and adequate representation

3. Effectiveness and efficiency

4. Accountability

5. Federated governance and devolution

6. Clarity of mission and consistency of actions

7. Fairness and due process

8. Promote and support innovation

9. Evaluation, learning and continuous improvement

See Appendix slides 4 8 for more details

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Recommendation 2: NW-HIN as Preferred Approach

The NW-HIN should be an environment of trust and

interoperability for exchange based on NW-HIN

Conditions of Trust and Interoperability (COTIs):

Should be the preferred approach for exchange of healthinformation nationwide.

Should be supported by the federal government with strong

incentives to vigorously promote adoption.

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See Appendix, slides 15 17 for more details

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Recommendation 3: Federal Leadership and

Shared Responsibilities

Federal leadership The federal government should :

Establish fundamental conditions for trust and interoperability and

utilize its full range of authorities to assure compliance.

Recognize existing state authorities across all relevant domains

and facilitate coordination and harmonization with states andother entities as needed.

Federal agencies should participate fully and directly in NW-

HIN and its governance.

Federal information exchange should be conditioned upon

compliance with NW-HIN requirements. Shared responsibilities:

Reflecting governance of governances, other entities should

have specific appropriate roles within the framework.

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Recommendation 4: NW-HIN Conditions of

Trust and Interoperability (NW-HIN COTIs)

ONC should establish conditions to assure trust and

interoperability, optimizing broad stakeholder input,

including consumers.

NW-HIN COTIs should provide a baseline and address

need for variability. Some are required and apply across all NW-HIN scenarios.

Others may be required in particular circumstances.

The Governance rule should:

Establish an initial set of NW-HIN COTIs. Establish a process for adding and modifying NW-HIN COTIs

Should provide maximum flexibility for innovation and adaptation.

See Appendix slides 24 27 for more details.

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Potential COTIs: Example Topics

Privacy

Fair information practices

Consent

Purposes for exchanging

through NW-HIN,secondary use, re-

identification

Security

Encryption

Identity proofing

Authentication

Auditing

Participant access policies

Interoperability Level of conformance

Other Policies To promote information sharing

Factors that should preclude anentity from NW-HIN

Technical requirements Secure transport

Data lookup and retrieval,

Notification of availability of new /updated data

Subject-data matching capabilities

Data content

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Recommendation 5: NW-HIN Validation*

ONC should establish a mechanism to verify that NW-HIN COTIs are satisfied.

Balance assurance with cost and burden of validation

Leverage existing validation methods, processes and entities

where appropriate.

NW-HIN validation should be required when exchanging

in NW-HIN environment and asserting NW-HIN

compliance.

There should be various methods of NW-HIN validation:

Appropriate to specific NW-HIN COTIs and the level ofassurance needed.

See Appendix slides 29 33 for more details.

* Validation generally refers to the process of verifying compliance and may include a broad array of

possible methods (e.g. self attestation, testing, certification of systems, accreditation of entities, etc.11

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Recommendation 6: NW-HIN Oversight

ONC should oversee NW-HIN governance and assure

accountability

Coordinate between Federal Agencies, state entities and

validation entities.

Monitor and highlight innovation

Address governance barriers

Provide ongoing evaluation and continuous improvement

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DiscussionDiscussion

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