By ADRIAN GROPPER, MD

Our aptly named Office of the National Coordinator needs your help. Congress wants to know if the regulations are working to enable interoperability and reduce information blocking. So, ONC wants us to “Help Inform the Department of Health and Human Services’ (HHS) Measurement of Interoperability” and has produced a helpful 19-page description of the issue. This interesting issue also made it to last week’s most august Joint HIT Committee for some lively discussion.

The only reasonable way to measure something is to consider the denominator as well as a numerator. Without the denominator to indicate the scope of what’s being measured, the numerator is likely to be misleading. With respect to interoperability, the denominator is simply all transactions that move individual-level patient data in or out of an institution.

Data moves in or out of an institution for different reasons and in different ways. The reasons include HIPAA Treatment, Payment, or Operations (TPO), to business associates, under patient authorization (regardless of whether it’s opt-in or opt-out), for research (e.g.: the Precision Medicine Initiative), and de-identified (to various data brokers and analytics services).

The ways that individual-level data moves is via analog fax, paper and film, digital media, or digital network. Measurement of interoperability would do well to consider all of these transports as part of the denominator.

We can define a data sharing transaction and hopefully allow a patient to request notification of that transaction. As individuals, we expect an accounting for data movement from our banks, email, and package services and we should expect the same for our health records. Specifically, I would define the following essential elements of a personal health data transaction:

Transaction Receipt and Notification

• Resource (medication, problem, demographic, note, order, etc…HL7 coded, if possible)

• Transport (fax, paper, film, digital device, digital network)

• Client / Requesting Party (by institution, app, or individual name)

• Date /Time (for any single client or requesting party, a monthly notice might be sufficient)

• API Class (is the specific Resource also available through a patient-directed interface?)

• Fee (who paid how much for this transaction or a link to the appropriate contract)

For a description of the API Class see https://thehealthcareblog.com/blog/2016/02/22/apple-and-the-3-kinds-of-privacy-policies/

Establishing the denominator from the transaction receipt perspective works whether or not an individual patient chooses to supply an email address for notification. The mere fact that such a notification is available improves transparency, cybersecurity, and trust.

As Bob Wachter has said, http://www.clinical-innovation.com/topics/analytics-quality/wachter-transparency-inexpensive-and-effective-tool transparency is an essential step to health system improvement. Let’s start with a transaction receipt and notification whenever our personal data is shared.