TAB A -- Health Data Standards Principles
The HHS health data standards efforts are based on the following principles:
- Health data should be more consistent across programs, payers, and other data holders; users should not be comparing "apples to oranges" when using data from different sources.
- Public and private sector health data should be of value to multiple users. As we move to more shared data standards, data collected once can be used for multiple purposes, dramatically reducing administrative burdens.
- Improvements in the collection and use of health data must be accompanied by assurances of privacy and security appropriate to an electronic environment.
- All interested parties -- private sector, states, consumers, federal agencies -- should collaborate in the evolution toward more shared data standards.
- Data standards are voluntary. Data standards efforts must move as a public- private partnership, with HHS facilitating evolution toward common data standards.
- The federal government can and should play three important roles in this voluntary process:
- create a national forum allowing interested parties to collaborate;
- participate fully with private standards development organizations and other interested groups in the voluntary effort to develop uniform health data standards; and
- to the greatest extent possible given its business needs, choose health data standards for its own health information systems that are compatible with state and private sector business needs and standards.
HHS efforts are wholly compatible with, but also move beyond, the principles set forth in "A Process for Government Selection of Standards for Its National Information Infrastructure (NII) Activities," June 29, 1995 draft (hereafter, the NII Report). The NII Report addresses standards selection internal to the federal government. While a portion of our efforts are aimed at improving the policy coherence of internal federal standards, in the health arena the line between internal and external data is porous, at best. In deciding how best to organize internal federal health data standards efforts, the need for coordination with our external data partners must always be kept in mind. Thus, the issues of interoperability and consensus development addressed here are broader than those addressed in the NII Report. We build on those principles and extend the effort to external interoperability issues.
This effort relies heavily on interdepartmental working groups, both as a matter of principle and as a practicality. As noted in the NII Report, selection of federal data standards should proceed through such inter-departmental working groups (called "affinity groups" in the NII Report), which "require representation from experts familiar with the technology and the extant standards...". Part of our effort involves reorganizing and consolidating multiple existing groups across agencies, and creation of an organizational framework that provides policy coherence across the groups and Departments.
Scope of This Effort
Finally, a brief observation on the debate about what constitutes electronic data interchange (EDI) and how EDI efforts should relate to broader efforts to coordinate health data standards. In recent months there has been some discussion about what types of electronic health information transactions should be labeled EDI for purposes of adoption by the federal government of uniform implementation conventions. The recently proposed revisions to the FIPS-161 brought this debate into focus.
Some argue that EDI refers only to those electronic transactions which are defined by ANSI X.12 and typified by a simple financial transaction where the receiving computer interprets the information transmitted and acts on it (by deducting an amount from an account, for example). Others contend that any transaction which involves the electronic transmission of health data from one computer system to another is part of EDI, including those transmitted under standards other than ANSI X.12 and typified by clinical laboratory test results which the receiving computer may or may not be able to interpret without human intervention. Significant HHS data interchange activities fall into the latter category.
We believe that defining EDI to exclude core electronic health data interchange activities of HHS would not be productive and would slow, rather than accelerate, progress toward the long-term goal of greater interoperability. Further, to separate commercial transactions from the more clinically oriented purposes of data interchange such as quality assessment and utilization review ignores two of the most significant trends in health care delivery today -- the drive to reduce administrative burden by increasing reliance on multiple uses of information collected once, and the drive to link clinical and quality indicators more effectively to the payment process. For these reasons, HHS supports the adoption of uniform implementation conventions for the full range of EDI standards for health data.