EHNAC Responds to ONC RFI on Governance of a Nationwide Health Information Network

The Electronic Healthcare Network Accreditation Commission (EHNAC), a non-profit standards development organization and accrediting body, recently submitted detailed comments on the Request for Information (RFI) on Governance of the Nationwide Health Information Network (NwHIN). The RFI was published on May 15, 2012 in the Federal Register by the Office of the National Coordinator (ONC) for Health Information Technology.

“Our organization has worked for many years in support of health information technology and electronic healthcare exchanges that are secure, practical and sustainable, and that address stakeholder needs,” says Lee Barrett, executive director of EHNAC. “Our comments reflect the thorough analysis and discussion among EHNAC commissioners and members. We believe that a governance framework for health information exchange must achieve a correct balance between guidance and flexibility, constraints and enablement—regulation may not be the appropriate framework to achieve such governance.”

EHNAC’s primary concerns are that the current proposal included in the RFI does not contain enough specificity to be carried out effectively or “aggressively advance the progress needed,” and that the “validation” mechanism as proposed may actually impede the adoption of implementation of NwHIN.

On behalf of its members and contributing stakeholders, EHNAC recommended that ONC take an approach that:

• Makes explicit which electronic exchange methodology and framework within the NwHIN is under consideration as the subject of any “condition of trusted exchange,” and specifies that an objective, third-party, national certification/accreditation organization(s) be designated to provide this level of review.
• Assists with industry development of specifications, procedures, and the security and privacy framework necessary to assure that exchange networks meet the standards and provide for interoperability between entities.
• Acknowledges two classes of recognition and oversight—namely certification and accreditation to include auditing—and makes clear the roles, functions and responsibilities for which kinds of products, organizations and other entities require either certification or accreditation.

The full comments are available on EHNAC’s website at http://www.ehnac.org/files/PDF/Governance_RFI_062712_Final.pdf.

About EHNAC

The Electronic Healthcare Network Accreditation Commission (EHNAC) is a voluntary, self-governing standards development organization (SDO) established to develop standard criteria and accredit organizations that electronically exchange healthcare data. These entities include electronic health networks, payers, financial services firms, health information exchanges, medical billers, outsourced services and e-prescribing solution providers.

EHNAC was founded in 1993 and is a tax-exempt 501(c)(6) nonprofit organization. Guided by peer evaluation, the EHNAC accreditation process promotes quality service, innovation, cooperation and open competition in healthcare. To learn more, visit www.ehnac.org or contact info@ehnac.org.