ONC Data Interoperability Draft for Social Services and Medical Providers Open for Public Comment

In the most recent step to set standards for configurable application programming in health and social services, the Office for the National Coordinator for Health Information Technology (ONC) released its much-anticipated draft strategic plan for interoperable health data use. The Interoperability Standards Advisory (ISA) is intended to help everyone, from patients to medical and social providers, promote whole person care. Among several changes in the draft is the documentation of social determinants of health (SDoH).

The ISA draft represents input from about 25 federal agencies, with public comment open until March 18, 2020. The draft is the culmination of an ONC effort to expand public health and health research interoperability, one goal of which was to enhance referrals for better care coordination and better public health reporting. The new ISA draft expands on this original intent.

Key Standards Include SDoH Measures

There are several significant proposed changes in the latest ONC ISA draft, including:

1: The addition of four new SDoH measurements

These include food insecurity, housing insecurity, transportation insecurity, and drug use. Studies show that SDOH impacts up to 80% of an individual’s health, so more refined insight is expected to help providers better manage services and support of care coordination.

2: Managing referrals for better care coordination

Referral improvement, ranging from services addressing medication needs to follow-up care coordination, has a specific sub-section in the new ISA draft. The recommendations are built around several “referral pain point” initiatives to create a common IT platform, according to ONC. These include the ONC led 360X Project (system integration) and Health Level 7 (international standards for health data sharing).

3: Clinical notes interoperability

Configurable data platforms can benefit from enhanced documentation and communication related to a patient’s health and SDoH factors. The ONC ISA standard offers a new sub-section on incorporating clinical notes into health IT systems.

4: Improved cognitive status

Such traits also have a new, expanded sub-section for documentation and information sharing.

5: Expanded patient-reported outcomes

With more patients relying on mobile devices to manage and share their health status, the ISA recommendations propose making it easier for patients to participate share information, a vital factor in care coordination and tracking SDoH.

ONC Faces Both Support and Opposition

As reported by Eccovia Solutions more than a year ago, there are emerging pros and cons surrounding data sharing and interoperability. Much of ONC’s interoperability efforts are modeled under standards envisioned in the 21st Century Care Cures Act. The ONC ISA goal is to enable provider and patient data exchange networks through numerous existing and new data networks. With the release of the new standards, proponents and critics of the ONC ISA initiative have clarified their positions.


1: Better data sharing can help solve some of the most persistent challenges in health care identified by the 21st Century Cures Act. These include rising healthcare spending, working to improve poor outcomes, responding to an uptick in mental illness and substance disorders, and improving access to care and access to technology.

2: Access to a universal, comprehensive patient/client record reflecting the actions and decisions of providers from medical to social services provides proactive opportunity. Goals such as patient empowerment and the transition to value-based care rely on interoperability and data sharing.

3: The proposed ISA standards will reduce regulatory and administrative burdens. Information duplication is the bane of medical and socials service providers. Without access to a common record, providers have to start from scratch, ordering repeat screenings and conducting interviews/histories that are likely already on file in a siloed database. Such duplication is also frustrating to and hard on patients. The draft also provides a development standard for private enterprise.


1: Standards to ensure that the draft goals while ensuring patient/client data security is lacking. Some industry executives believe any new standards should be delayed until better assurances about data privacy are offered. Balancing the easy access to such sensitive data with tight security standards will take more time. The Health Innovation Alliance has gone so far as to recommend that the ONC interoperability rules be scrapped and rewritten.

2: The willingness of patients to download and manage their medical service data is over-estimated, calling the stated goals of the ONC initiative into question. Elderly, chronic, and low-income patients who account for most of the expenses in the service and medical care arena are less likely to be as connected.

3: Creating common data platforms need to be phased in over time. The comprehensive draft recommendations and accompanying timeline, it is feared, will create a burden on providers and vendors.


Despite such differences of opinion around the ONC ISA draft document, the strategy is well-intentioned. Ultimately, ONC seeks to promote health and wellness through better care coordination and improve the patient/client experience. The agency also aims to build a secure, data-driven culture through interoperability, and connect healthcare data through a common IT platform that can be adapted to each user. How these concerns are resolved will be worth paying attention to as the issue moves forward.

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