This minimizes the friction of adoption and makes the best choice "mindless." In this case, if HEBD produces systems or workflows that are more onerous than existing ones, it will result in delaying or resistance to adopting these principles. 2. [...] What are the exemplars and lessons you would share with ONC in your comments? Gather SDOH data from patients and incorporate that into clinical decision-making. [...] What are the leading barriers to health equity and health equity by design that you experience in your efforts? How do you think ONC can help? [...] Lack of data Not enough data based on occasional pilot programs or innovative ideas (without implementation testing), and they are doing so before the basic foundations are in place. [...] Lack of interoperability The exchange and attainment of health information external to one’s own health system is still lacking. [...] Some reasons are because of information blocking, but also due to interoperability being cumbersome, costly to health systems, and adds burden to clinicians that is greater than the added value to clinicians/patients in most circumstances. Things like ability to close the referral loop, communicating with all other members of the health care delivery system, prior authorizations are still a ch [...] lack of service availability (either in general, at reasonable cost, and/or in geographic proximity to the individual) and 2. [...] The same is true for the vast majority of services that we refer to. [...] The HTI-1 algorithmic transparency rule is positive but does not address the totality of possible pitfalls and most users are not sophisticated enough to interpret the information about the algorithm and bias. 5. [...] Consider how HEBD training will be provided for clinicians and patients. Training people to use the system being designed should be part of the design of the system. 6.
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