CHA has submitted comment letters in response to two proposed rules — one from the Centers for Medicare & Medicaid Services (CMS) and the other from the Office of the National Coordinator for Health Information Technology (ONC) — intended to improve the interoperability of health information. CHA has also prepared a letter template that members can use to support CHA’s policy positions with hospital-specific examples. CHA urges members to use the letters in drafting their own comments, which are due by 2 p.m. (PT) June 3.
CHA shares the ONC and CMS goals of improved interoperability and patient access to health information. However, CHA’s draft letter raises a number of concerns for the agencies’ consideration, intended to ensure that implementation of the proposed policies does not create additional regulatory burden in the health care system. Of note, CHA opposes CMS’ proposed revision to the Medicare and Medicaid Conditions of Participation that would require electronic patient event notifications, and instead urges the agency to consider alternative mechanisms for promoting admission, discharge, and transfer notifications.
CHA also expresses concerns that the ONC’s proposed definition of electronic health information (EHI) under the information-blocking provisions goes beyond what Congress intended under the 21st Century Cures Act, and urges the agency to limit the information in the definition of EHI to the data classes and elements required for certification under the U.S. Core Data for Interoperability. Specifically, CHA opposes the inclusion of payment and price information within the definition of EHI and believes overregulation in this area could impede emerging private sector efforts to promote price transparency.
CHA’s draft letter also comments on CMS’ proposals requiring health plans to share patient health information through a standardized, open application programming interface (API), the ONC’s proposed updates to certification criteria for electronic health records, and other proposals. In addition, CHA responds to CMS’ request for information on advancing interoperability across the care continuum.