The HIMSS Electronic Health Record Association (EHRA) has expressed concerns about the proposed interoperability and AI transparency rule (HTI-1) from the Office of the National Coordinator for Health IT (ONC). EHRA believes that the proposed rule is too aggressive, burdensome, and not aligned with other HHS requirements. EHRA is asking ONC to make changes to the proposed rule, including extending the timeline for implementation, reducing the burden on software developers and providers, and aligning the proposed rule with other HHS requirements.
The HIMSS Electronic Health Record Association (EHRA) has expressed concerns about the proposed interoperability and AI transparency rule (HTI-1) from the Office of the National Coordinator for Health IT (ONC).
EHRA is particularly concerned about the following:
- The timeline for implementation is too aggressive.
- The requirements are too burdensome for both software developers and providers.
- The proposed rule is not aligned with other HHS requirements.
EHRA is asking ONC to make the following changes to the proposed rule:
- Extend the timeline for implementation.
- Reduce the burden on software developers and providers.
- Align the proposed rule with other HHS requirements.
EHRA believes that these changes will make the proposed rule more feasible and effective.
Here are some additional details about EHRA’s concerns:
- The timeline for implementation is too aggressive. The proposed rule requires software developers to implement several new features by December 2024. EHRA believes that this is too aggressive of a timeline and that it will not give software developers enough time to develop and test the new features.
- Requirements are too burdensome for both software developers and providers. The proposed rule includes several new requirements that will be burdensome for both software developers and providers. For example, the rule requires software developers to collect and report data on the use of their algorithms. This will be a significant burden for software developers, and it is not clear how the data will be used.
- Lack of alignment with other HHS requirements. The proposed rule is not aligned with other HHS requirements. For example, the proposed rule requires software developers to collect and report data on the use of their algorithms. However, other HHS requirements do not require this data to be collected or reported. This lack of alignment will make it difficult for software developers to comply with the proposed rule.
EHRA believes that the proposed rule has the potential to improve interoperability and AI transparency in healthcare. However, EHRA is concerned that the proposed rule is not feasible or effective in its current form. EHRA is asking ONC to make the changes outlined above to the proposed rule.
In addition to the above concerns, EHRA also believes that the proposed rule does not go far enough in addressing the need for interoperability and AI transparency in healthcare. EHRA believes that the following additional changes should be made to the proposed rule:
- The proposed rule should require software developers to make their algorithms more transparent. This could be done by requiring software developers to provide documentation on how their algorithms work, and by requiring software developers to allow users to audit their algorithms.
- The proposed rule should require software developers to make their algorithms more interoperable. This could be done by requiring software developers to use open standards for their algorithms, and by requiring software developers to allow their algorithms to be used with other software.
EHRA believes that these changes would make the proposed rule more effective in improving interoperability and AI transparency in healthcare.
