OpenNotes partnered with The Light Collective—a national patient advocacy organization—to jointly submit public comment to the Office of the National Coordinator for Health Information Technology (ONC) on the Proposed HTI-1 Rule on Health Data, Technology, and Interoperability.
The Light Collective is a non-profit patient advocacy organization representing the collective rights, interests, and voices of patient communities in health technology. Comment submitted by The Light Collective and OpenNotes were written jointly based on a shared vision to improve transparent communication between clinicians, researchers, technologists, and patients and the public.
ONC’s HTI-1 proposed rule “seeks to implement provisions of the 21st Century Cures Act and make updates to the ONC Health IT Certification Program… with new and updated standards, implementation specifications, and certification criteria. Implementation of the proposed rule’s provisions will advance interoperability, improve transparency, and support the access, exchange, and use of electronic health information.” More information about the HTI-1 proposed rule can be found on the ONC website.
The joint comment by The Light Collective and OpenNotes called on the ONC to consider the following approaches for fair Certification Program Updates and Algorithm Transparency by:
- Clearly explaining use cases
- Clearly defining the 8 types of risks and harms that would disqualify an IT developer from certification
- Creating independent governance and accountability for the institutions supporting these exchanges
- Involving patient and clinician stakeholders in the co-design of algorithm transparency initiatives
- Ensuring systems are audited to check for use of banned surveillance tracking technologies
- Applying transparency in algorithm design and use
- Providing patient-facing resources on how to evaluate and understand algorithmic decision-making
- Incorporating the principles of patient-centric (or human-centered) design to ensure the usefulness and safety of design in health IT systems
A more detailed copy of the comments submitted jointly by The Light Collective and OpenNotes can be read in its entirety here. The deadline to submit public comment was June 20, 2023.
