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Comment to ONC recommending RDF to help "standardize the standards"

From: David Booth <david@dbooth.org>
Date: Fri, 01 May 2015 17:18:40 -0400
Message-ID: <5543EDB0.4070808@dbooth.org>
To: "its@lists.hl7.org" <its@lists.HL7.org>, w3c semweb HCLS <public-semweb-lifesci@w3.org>
FYI, here is a comment that several members of the Yosemite Project 
steering committee submitted to the ONC today, regarding the ONC's 2015 
Interoperability Standards Advisory:
The content of the comment is also included below, in case you are 
reading offline.  Although this comment has already been submitted and 
cannot be changed, for the benefit of future work please feel free to 
add comments to the document, comment here, or comment privately.

The ONC's 2015 Interoperability Standards Advisory (which our comment 
addresses) is available at

David Booth


Comment on the 2015 Interoperability Standards Advisory

Submitted by members of the Yosemite Project Steering Committee

Yosemite Project Mission:
Semantic interoperability of all structured healthcare information

Problem: Healthcare standards are silos
The 2015 Advisory lists a patchwork of "best available" standards for 
clinical data interoperability.   This is an important step.  However, 
while each standard enables a level of interoperability within each 
domain, taken together the standards are silos: each standard is defined 
by different data formats, different data models and by different 
vocabularies that are not always interoperable. For example, many of 
these standards include overlapping concepts that are defined 
differently and in incompatible ways.  Therefore implementers are 
required to create their own workarounds to bridge these standards and 
overcome the incompatibilities. However, because implementers use 
different approaches, data still lacks interoperability between 

It is time to standardize the standards.  This will involve two steps: 
the first is technical and the second is social.  The first step is to 
adopt a universal information representation for healthcare standards, 
and this is the step that this comment addresses. This universal 
information representation is crucial to enable the meaning of the data 
to be exposed in a uniform way across all required data domains and use 
cases.   This will allow the meaning of any piece of any clinical data, 
expressed in any ONC-endorsed standard, to be accurately determined. 
The second step is to converge on a standard set of clinical concepts 
and related assertions that are shared across standards and that can 
support cross-cutting use cases so common in medicine.  Although this is 
a social process of agreement, and not directly addressed by this 
comment, this social process will be greatly facilitated by use of a 
universal information representation.

Suggestion 1:  Recommend a universal information representation
The ONC should add a recommendation for a universal information 
representation that can accurately capture the meaning of any healthcare 
information, spanning all ONC-mandated standards, regardless of the the 
data formats, data models,  or vocabularies prescribed by those standards.

Suggestion 2: Recommend RDF as the best available universal information 
The ONC should recommend Resource Description Framework (RDF) version 
1.1 as the best available candidate for a universal information 
representation, to meet the need described above.  RDF is a standard 
produced by the World Wide Web Consortium (W3C) that has been used in a 
wide variety of domains -- including biomedical research -- for over 10 
years.  RDF -- and the RDF family, including RDFS, OWL, SKOS, etc. -- 
has already been used to express the meaning of medical vocabularies, 
such as SNOMED CT and ICD-11, but its use needs to be extended to all 
healthcare standards, to provide a common semantic foundation across all 
healthcare standards.  Over 100 healthcare thought leaders and 
technologists have already expressed their view that RDF is the best 
available candidate for this purpose.  (See http://YosemiteManifesto.org/ )

Signed by the following members of the Yosemite Project Steering Committee

David Booth, PhD, is a senior software architect at Hawaii Resource 
Group and at Rancho BioSciences, using Semantic Web technology to make 
clinical healthcare data interoperability between diverse systems. He is 
also leading a joint HL7-W3C effort to defined an RDF ontology for FHIR. 
  He previously worked at KnowMED, using Semantic Web technology for 
healthcare quality-of-care and clinical outcomes measurement, and at 
PanGenX, applying Semantic Web technology to genomics in support of 
personalized medicine. Before that he worked on Cleveland Clinic's 
SemanticDB project, which uses RDF and other semantic technologies to 
perform cardiovascular research. Prior to that was a software architect 
at HP Software. He was also a W3C Fellow from 2002 to 2005, where he 
worked on Web Services standards before becoming involved in Semantic 
Web technology. He holds a Ph.D. in Computer Science from UCLA.

Conor Dowling is CTO of Caregraf, which uses Semantic Web technologies 
to help health-care providers gather and analyze the information they 
create during the course of a patient’s care. He is a specialist in 
clinical-data analytics with a focus on how the definition of clinical 
know-how and institutions shapes the description of patient care.

Michel Dumontier, PhD, is an Associate Professor of Medicine at Stanford 
University in the Stanford Center for Biomedical Informatics Research. 
His research focuses on methods to integrate large, heterogeneous 
clinical and biomedical data for discovery. His research interests 
include (1) developing novel therapeutics for rare and complex diseases, 
(2) elucidating the mechanism of drug-induced side-effects, and (3) 
optimizing multi-drug therapies to minimize undesirable side effects.

Claude Nanjo, MA MPH, is a Software Architect at Cognitive Medical 
Systems. He is also an active contributor to a number of HL7 and S&I 
clinical modeling initiatives including Health eDecision (HeD), the 
Clinical Quality Framework (CQF), and Fast Health Interoperability 
Resources (FHIR). At both Cognitive Medical Systems and Zynx Health, 
Claude has been involved in a number of research projects exploring the 
intersection between Clinical Decision Support and the Semantic Web. 
Prior to joining Zynx Health, Claude was engaged in research developing 
machine learning solutions to mine information on the Web.

Josh Mandel, MD, is a physician and software engineer at Children's 
Hospital Informatics Program at Harvard-MIT interested in improving 
clinical care through information technology. After earning an S.B. in 
computer science and electrical engineering from the Massachusetts 
Institute of Technology and an M.D. from the Tufts University School of 
Medicine, he joined the faculty of the Boston Children's Hospital 
Informatics Program and Harvard Medical School, where he serves as lead 
architect of the SMART Project (http://smartplatforms.org). Josh has a 
special interest in tools and interfaces that support software 
developers who are new to the health domain.

Rafael Richards, MD MS, is a Physician Informaticist in the Office of 
Informatics and Analytics at the Department of Veterans Affairs.  He is 
currently the co-director of the VA-DoD interoperability research 
collaboration lab.  Prior to this Dr. Richards was an Assistant 
Professor in the Division of Health Science Informatics at Johns Hopkins 
University. Rafael's current interests and activities are in data 
standards, medical device data integration, and modernizing VA databases 
to enable enterprise data federation with Linked Data sources. Prior to 
medicine, Rafael earned as B.S. Engineering from Swarthmore, M.S. 
Applied Mathematics from Lehigh University, and worked several years in 
industry in scientific software applications with IBM and in the UK 
office of Wolfram Research on Mathematica. Rafael is an invited expert 
in the Semantic Web in Healthcare and Life Sciences of W3C.
Received on Friday, 1 May 2015 21:19:08 UTC

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