Responses to the NwHIN Governance RFI

The proposed framework for governance and operations of the Nationwide Health Information Network (NwHIN) that the Office of the National Coordinator of Health IT (ONC) has described in the recent request for information (RFI) elicited a great deal of stakeholder input. (You can read the through all of the responses at regulations.gov HERE). Many industry stakeholders were concerned that the process was moving too quickly and a lighter approach should be considered.

A sampling of the thrust of some of the comments are;

AAFP We need strong integration of the Direct Project standards with certified electronic health record systems and a well developed trust framework.

AHA ONC should focus on establishing a governance framework, but should not formulate regulations on "conditions of trusted exchange" (CTEs)

CCHIT NwHIN governance by a public-private entity would be a more effective approach in establishing trust, gaining wide adoption, and allowing for multi-stakeholder representation.

eHealth Initiative Heavy regulation under a national governance structure should be avoided.

HIMSS EHRA Initial focus should be on developing a governance mechanism, rather than specifying CTEs, which should be created by a public-private governing body.

If you saw Dixie Baker's excellent presentation to the HIT Standards Committee you will see that the NwHIN Power Team had some similar concerns. One thing that was very wise of the ONC was using the RFI process (which I thought would be an Advance Notice of Proposed Rulemaking) which allows for broad stakeholder input and the ability for greater flexibility in the rulemaking process. The ONC now has an opportunity to craft a much better proposed rule in collaboration with the exchange community.