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Sept 12 -- The Office of the Secretary (OS), Department of Health and Human Services, invites comments to OMB by October 14, 2022 regarding the National Survey of Health Information Exchange Organizations (HIO).

Electronic health information exchange (HIE) was one of three goals specified by Congress in the 2009 Health Information Technology for Economic and Clinical Health (HITECH) Act to ensure that the $30 billion federal investment in certified electronic health records (CEHRTs) resulted in higher-quality, lower-cost care. In subsequent rulemaking and regulations, ensuring that providers can share data electronically across EHRs and other health information systems has been a top priority.

Beginning prior to HITECH, there has been substantial ongoing assessment of trends in the capabilities of health information organizations to support clinical exchange. These surveys have collected data on organizational structure, financial viability, geographic coverage, scope of services, scope of participants, perceptions of information blocking, and participation in national networks and TEFCA. While past surveys assessed HIOs' capacity to support HIE in a variety of ways, they did not closely examine how HIOs support public health exchange. Each of these areas of data collection will be useful to constructing a current and more comprehensive picture of HIOs' role in addressing public health emergencies.

The most recently conducted survey, in 2019, was funded by ONC (OMB # 0955-0019). The 2019 national HIO survey sought to assess the existing capabilities, and examine the evolution, of these organizations. However, the pandemic has created an urgent need to capture measures of current exchange capabilities among HIOs and to ask new, targeted questions specifically about health information exchange relevant to COVID-19 and public health reporting more broadly. The revised survey will therefore report on the capacity of these organizations to aid in specifically supporting response to the COVID-19 pandemic and future public health emergencies. The survey will also determine how HIOs capture demographic data so that ONC can assist in addressing disparities that were exasperated by the pandemic.  

We have revised the survey to better understand the role of HIOs in supporting public health reporting and response to the pandemic.  HIOs, given their unique role in convening data across stakeholders in their region, may be able to support linking data from disparate sources together to help monitor the use of strategies to prevent and treat COVID-19. HIEs may also be able to leverage clinical and demographic data they have access to with other data to monitoring community/state-level vaccination rates, transmission rates and breakthrough infection rates among subpopulations (e.g., immunocompromised), along with supporting providers meeting public health reporting requirements via electronic means (rather than paper-based).

The newly revised survey will provide insights that will help us determine the extent to which HIOs are positioned to meet COVID-19 and other public health information sharing needs. The survey assesses the geographic coverage of HIOs, HIOs engagement with federal, state and local public health entities; and their capabilities to support public health reporting and exchange of information.  Barriers HIOs have encountered in providing these capabilities to frontline clinicians and public health agencies is also measured.  Today there is no data source that comprehensively measures the status of these critical capabilities across HIOs.

There is an array of policy efforts that are primed to leverage the results from the survey.  For example, ONC’s Health IT Advisory Committee Public Health Data Systems Task Force is working to address issues with data exchange between public health data systems and clinical data sources.  The task force has recommended key data types to be updated to use published standards and implementation guides and that the deployment of these prioritize demographic and social determinants of health. The HIO survey results will help inform prioritization and selection of data types and standards. Furthermore, the CARES Act’s STAR HIE Program has dedicated $5 million to improve the capacity of a select set of HIOs to support public health agencies’ response to public health emergencies and pandemics. In January 2021, the STAR HIE Program expanded to provide additional awards to amplify immunization information sharing collaboration. Initial investments seek to guide us on how to best support vaccine-related efforts. The HIO survey results will identify how progress made under the STAR HIE Program can be best leveraged to enhance public health related HIE for HIOs across the country. To guide these efforts, it is critical to assess the current state of HIOs, which are uniquely positioned to expand to meet public health information sharing needs.

The ultimate goal of our project is to administer a survey instrument to HIOs in order to generate the most current national statistics and associated actionable insights to inform policy efforts. The timely collection of national data from our survey will assess current capabilities to support effective electronic information sharing within our healthcare system related to COVID-19 and other public health relevant data.

Our survey will accomplish this goal by asking HIOs to report current activities in the following domains:

-- Public health information sharing capabilities, with a specific focus on COVID-19 response
-- Implementation of and use of standards to enable exchange and interoperability, with a focus on lab interoperability critical to the pandemic response
-- Information blocking practices undertaken by provider organizations and health IT developers, including those related to laboratories that could hamper efforts to get timely results for pandemic response
-- Planned responses to TEFCA, and current engagement with inter-HIO and national network connectivity
-- HIO sustainability and related demographics that capture the role of HIOs in supporting exchange and interoperability through their provision of various services and engagement with various types of stakeholders and participants, along with delivery system reform efforts (e.g. MIPS)

By developing a survey instrument addressing these domains, collecting national data from a census of HIOs, and analyzing the data to identify important new insights, the proposed project fills a critical gap in current knowledge and will provide policymakers with actionable results to inform progress towards greater interoperability and exchange of clinical data, with a focus on COVID response.

ONC HITECH Programs: https://www.healthit.gov/topic/onc-hitech-programs
HHS submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202206-0955-002 Click IC List for survey instrument, View Supporting Statement for technical documentation. Submit comments through this site.
FR notice inviting comment: https://www.federalregister.gov/d/2022-19583 (While FRN was posted Sept 12, submission to OMB made Sept 14. 30 days=Oct 14)
For AEA members wishing to submit comments to OMB, the AEA Committee on Economic Statistics offers "A Primer on How to Respond to Calls for Comment on Federal Data Collections" at https://www.aeaweb.org/content/file?id=5806

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