CDC Issues RFI for Real-world Testing of Health Information Technology

Noam H. Arzt, Ph.D.In October the Centers for Disease Control and Prevention (CDC) issued a Request for Information (RFI) for a Natural Test Collaborative (NTC). Through a series of questions, the RFI seeks opinions and information about "The development of a national testbed (notionally called the National Test Collaborative (NTC)) for real-world testing of health information technology (HIT)" and "Approaches for creating a sustainable infrastructure" to achieve it.

The scope of the questions is somewhat confusing and quite broad, starting with Clinical Decision Support (CDS) and electronic Clinical Quality Measures (eCQMs) but quickly expanding to Electronic Health Records (EHR) and interoperability (not precisely defined).

The context for this RFI is equally confusing. It appears that on the one hand this is an extension of a CDC project called Adapting Clinical Guidelines for the Digital Age which started with an RFI in 2016 (see HLN's response) and culminated in a five-day meeting whose purpose was to share ideas about how clinical guidelines could be better applied to patient care (see meeting summary). This would explain the initial scope as being related to CDS/eCQMs. On the other hand, there is some indication that CDC issued this RFI on behalf of itself and other sister agencies within Health and Human Services (HHS) because it had the administrative infrastructure and experience to issue it via FedBizOps more nimbly than other parts of the Department.

I find it odd that CDC did not even mention the National Institute of Standards and Technology (NIST) in its background information in this RFI, especially given that NIST is its major partner not only with respect to CDS testing but also interoperability testing to support Meaningful Use. These are the closest thing to a national test bed in HIT that we have.

I also find it odd that CDC did not mention the SMART project or its application sandbox as a prime example of an open source test bed. But the prospect of a national test bed for all health IT seems complicated, costly, and probably ill-advised. It is more realistic and feasible for CDC and HHS to better understand what is already in play and build on the experience of others. Health IT development and support is so distributed in the United States that standards for testing may be ambitious enough.

Responses to the RFI are due by 10am ET on December 20, 2018.