Feedback on Governance Proposal for the Nationwide Health Information Network
Trust and interoperability are the most important characteristics of a sustainable environment for digital health information exchange and should be established through sound governance principles and mechanisms. Health care providers have ethical and legal responsibilities to protect a patient's health data, and they will need some assurance that entities with whom they share patient data will handle that data responsibly and in compliance with the law. Interoperability ensures that data sent by a provider can be understood and appropriately used by the intended recipient.
In general, governance of health information exchange through the Nationwide Health Information Network should have the following characteristics:
• Well-defined and bounded mission.
More specifically, governance of the Network should include the following three components:
• Clear goals and objectives;
• Mechanisms and processes for the development, oversight, enforcement and coordination of policies, standards and services; and
• A set of policies, standards and services that are necessary to support the clear goals and objectives intended to be achieved
That attached document are the detailed comments CDT submitted regarding HHS' initial proposal for governance of the Nationwide Health Information Network.