I want to make this assertion boldly and clearly available for:
- Communication to HHS in the next few weeks while RFI is open
- A peer-reviewed publication to scale the dissemination of this message
- Providing a basis for AI development for prescriptive analytics
- Providing a basis for EBMonFHIR as a key foundation
Let me know if you want to join a co-authoring group, especially with #2 in mind. Perhaps we start with the HEvKA StatisticsOnFHIR Working Group meeting (Mondays at 2 pm Eastern) as the focused meeting time
for developing this message. Being a co-author for this one means an expectation of active participation in the next 2 weeks to shape a substantial manuscript, perhaps drafting text or finding strong references to back it up. (As this email may be seen by
hundreds of people, I want to be clear I am looking for active co-authors, not a long list of ‘supporters’)
A standard machine-interpretable way to define the evidence used for prescriptive analytics should improve transparency, accuracy, precision, explainability, reduced bias, validity, trustability, efficiency,
and reproducibility.
An outline for making the argument could be:
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AI is now expected to be used in nearly every cognitive function.
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AI has established acceptable performance for descriptive analytics, diagnostic analytics, and predictive analytics in many contexts, but the use of AI for prescriptive analytics in healthcare triggers alarms for ethical, legal,
and social concerns regarding trustability for both internal and external validity.
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The evidentiary basis for diagnostic analytics and predictive analytics is pattern matching, and this is why AI has scaled to perform better than human cognition for these areas.
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The evidentiary basis for prescriptive analytics is critical appraisal of findings from controlled observations with deep understanding of the methods for obtaining these findings.
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Using pattern matching to approximate the evidentiary basis for prescriptive analytics is exponentailly problematic because:
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It introduces confounding bias by converting large numbers of chance associations (findable with big data analytics) into misleading findings from ‘uncontrolled’ observations.
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It exacerbates the extensive problem of reporting bias in conventional scientific publications, by using the pattern of language in study reports instead of the data of study findings.
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For AI to provide prescriptive analytics with the smallest possible degree of bias, the AI needs a data source with a precise, unambiguous expression of the findings from controlled observations.
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For AI to provide prescriptive analytics with recognition of the potential for bias, the AI needs a data source with a precise, unambiguous expression of the methods of obtaining these findings.
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A precise, unambiguous form of expression is not truly precise or unambiguous unless there is global agreement on its interpretation – hence the need for a standard.
- A standard machine-interpretable way to define the evidence used for prescriptive analytics should improve transparency, accuracy, precision, explainability,
reduced bias, validity, trustability, efficiency, and reproducibility.
-
A standard machine-interpretable way to define the evidence used for prescriptive analytics EXISTS, in early-maturity form as standards go, with the EBMonFHIR specification.

Brian S. Alper, MD, MSPH, FAAFP, FAMIA, FGIN
CEO, Computable Publishing LLC
bal...@computablepublishing.com
Making Science Machine-Interpretable
http://computablepublishing.com
Lead,
HEALTH
EVIDENCE KNOWLEDGE ACCELERATOR
President, Scientific Knowledge Accelerator Foundation
Read about The
Mission Change of a Lifetime
"It only takes a pebble to start an avalanche."
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