This week’s preview of a soon-to-be-proposed health care metadata rule — in government parlance, an advance notice of proposed rulemaking, or ANPRM — some believe to be a glimpse of the upcoming meaningful use stage 2 regulation. Certainly, the ONC’s call for encryption of any personally identifiable data to be encrypted in transit is a sign that this rule can plug-and-play with HIPAA covered entities.
“The immediate scope of this ANPRM is the association of metadata with summary care records,” the ONC stated in the document. “More specifically, in the scenario where a patient obtains a summary care record from a health care provider’s electronic health record technology or requests for it to be transmitted to their personal health record. Public comment, however, is also welcome on the use of metadata relative to other electronic health information contexts.”
Summary of care metadata — or metadata for medical records in general — isn’t a hot dinner conversation topic among average patients, even those who seem to keep a second home at Best Buy, geeking out on the latest technology trends. It might seem like an afterthought to even technically versed hospital IT types, a barely noticeable slice of giant data systems moving records, medical imaging and lab results through the network.
But in the data standards community, metadata’s a big topic of discussion: It’s a security vulnerability, it’s a way to confirm who’s seen and edited a record and a routing mechanism in some cases. Taken all together, metadata could be a linchpin of health data exchange — and the whole ballgame when it comes to physician buy-in to it.
More robust metadata can also give physicians a more accurate picture of the sequence of events in a patient file. It also give patients and their attorneys more data points — read: more ammunition — in the e-discovery process to convince juries that malpractice took place, Harvard School of Public Health professor and attorney Michelle Mello said last week at the World Congress 3rd Annual Leadership Summit on mHealth in Cambridge, Mass.
So while metadata isn’t the first thing you might think of when you get up in the morning, rest assured it’s on the ONC’s mind, at this point in time. The federal HIT coordinator’s struggling to develop standards that will be running on your network. It will be something you’ll be implementing and dealing with on behalf of physicians, patients, payers and if you’re unlucky, attorneys for years to come. If you’re a stakeholder in health IT, you’ve got until late September to register your comments. Maybe you ought to look over the rule and register your two cents’ worth.
If you’re actually working on a hospital network as you’re reading this, you can add some real-world implementation knowledge to what is clearly still being drawn up in a theoretical world. The ONC could use feedback like that, right now.