The National Committee on Vital and Health Statistics (NCVHS), an advisory board to the U.S. Department of Health and Human Services (HHS), said the concept of metadata in EHRs is so new and untested that it would be a mistake to require tagging in EHRs in Stage 2, which could start as soon as 2013. HHS, through its Centers for Medicare and Medicaid Services (CMS), is expected to finalize rules for the second stage of the federal EHR incentive program by the middle of next year.
"Although metadata tagging has the potential to increase the reliability, dependability, and trustworthiness of health information exchanges by including metadata descriptors about the data being exchanged, this approach is not in current use and there are no accepted standards for metadata tags," the NCVHS said in a letter to the Office of the National Coordinator for Health Information Technology (ONC). "We believe that the adoption of a series of standards for metadata tagging via formal regulations is premature and contrary to the practice of first testing and demonstrating how such standards (and the technical assumptions that go along with them) will actually work."
ONC, also a branch of HHS, defines metadata as "data about data," or "data that provides more information or detail about a piece of data." ONC is offering guidance to CMS during the development of Meaningful Use regulations
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The NCVHS said that it would make more sense to wait until standards have been set and thoroughly tested via demonstration projects to identify and mitigate any unintended consequences. According to the letter, "The nation cannot afford to risk the important progress made thus far on the adoption and meaningful use of electronic health records and health information exchanges by diverting valuable resources towards the implementation of new, yet to be tested, standards under an overall metadata tagging approach that, we believe, is not mature for regulatory adoption."
Additionally, the committee expressed concern that healthcare providers and others in the industry already have too much on their plates in the next few years. Even as providers seek Medicare and Medicaid bonus payments for Stage 1 Meaningful Use now through 2014, they also have to adjust to tougher HIPAA privacy standards; switch to ANSI X12 version 5010 electronic transactions by Jan. 1, 2012; adopt ICD-10 coding by October 2013; and deal with various reform efforts under the Patient Protection and Affordable Care Act. "Introducing yet to be tested standards in the midst of these initiatives would pose significant challenges and risks to the health care industry," the letter said.
The reservations echo those expressed last month by a private organization, the College of Healthcare Information Management Executives (CHIME), to HHS secretary Kathleen Sebelius. CHIME told the secretary that more work needs to be done to verify proposed metadata standards before they can be broadly implemented across the healthcare provider community.
In August, ONC solicited comments on a set of metadata standards by issuing an advanced notice of preliminary rulemaking, a prelude to a formal regulatory proposal. ONC was guided by a December 2010 report from the President's Council of Advisors on Science and Technology (PCAST), which called for the creation of a universal exchange language to support secure exchange of health information across institutions. PCAST said that federal officials should incorporate this language into the latter phases of Meaningful Use.
ONC sought answers to 20 specific questions about elements of metadata in electronic health information and signified that HHS was contemplating including metadata rules in Meaningful Use Stage 2. ONC said the "immediate scope" of its notice was the association of metadata with "summary care records," or how patients get a summary of their records from a provider's EHR, either on paper or through an electronic transmission to a personal health record.