Posted on Monday, October 24th, 2011 Filed Under: Health Information Exchange, eHealth Initiative

eHI Comment Letter on Metadata Standards

A common theme in discussions about the use of health information technology (HIT) and health information exchange (HIE) is the technical challenge of actually sharing data. Lacking a set of national or universally-recognized standards, various data sharing solutions have been adopted, leading to a fragmented picture of HIT adoption nationally. In an effort to address this challenge, the federal government is supporting efforts to identify standards that, collectively, will support national health information exchange. One of ONC’s current initiatives includes the use of “metadata” to support HIE.

Metadata is commonly referred to as “data about data”. Metadata allows data users to “tag” data elements for later search and/or retrieval. In the context of HIT, metadata would allow providers to locate information within a patient’s electronic health record without having to access the entire health record. This would help providers identify only the information relevant to their interests, rather than having to slog through a complete record to find a single test result or clinical marker that they are seeking.

In early August, ONC released an advanced notice of proposed rulemaking (ANPRM) concerning the use of metadata standards to support health information exchange, specifically regarding the metadata used in the sharing of summary of care records. The ANPRM sought comments on proposed metadata standards for patient identity (demographic information such as name, DOB, address, etc.), provenance (data describing the source of the information), and privacy (whether the record has information that might call for special handling due to privacy requirements).

eHI submitted a comment letter to ONC where we re-stated our view that the appropriate use of metadata can play a major role in enhanced data usefulness and liquidity. We also agree with the intent to consider the application of metadata to facilitate queries of documents within the context of a use case. Our view also is that the use of metadata in pilots or demonstrations, followed by evaluation and dissemination of the results, will add real world insight that will highlight areas for modification.  These steps are important prior to implementation of metadata standards on a larger scale in the future.  We think that a preferred approach builds on current standards and technology, such as the use of industry-recognized options to provide a robust approach to meta-tagged data.  We also urge an approach that builds on the availability of standards-based health information exchange, using Integrating the Healthcare Enterprise (IHE) profiles, to provide for effective queries of distributed healthcare information.

For the future, we look forward to the development of a metadata vocabulary, and the establishment of a governance process for that vocabulary to ensure consistency across the industry.  Moreover, we look forward to the continued progress of our federal agencies toward realizing the goal of a healthcare system in which information is exchanged among affiliated and unaffiliated providers and their patients through the use of interoperable standards.

eHI’s comments on the ANPRM on metadata standards can be found here.

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