HHS and ONC sought public comments through a Request-For-Information (RFI) on the EHR Reporting Program established as Section 4002 in the 21st Century Cures Act and codified as Section 3009A in Title XXX of the Public Health Service Act (PHSA). Below is the letter and comments eHI's Policy Steering Committee submitted.

October 17, 2018
 

Don Rucker, MD
National Coordinator
Office of the National Coordinator for Health Information Technology (ONC)
U.S. Department of Health and Human Services (HHS)
Attention: EHR Reporting Program Request for Information
Mary E. Switzer Building, Mail Stop: 7033A​
330 C Street SW
Washington, DC 20201
 

Dear Dr. Rucker:

Enclosed are the focused comments of the eHealth Initiative (eHI) on the Request for Information (RFI) Regarding the 21^st Century Cures Act Electronic Health Record Reporting Program. eHI offers the expertise of our unparalleled multi-stakeholder membership to you as this process continues forward. We are the only independent non-profit, multi-stakeholder coalition dedicated to improving the quality, safety, and efficiency of healthcare through the use of technology and health information. eHI’s work and its membership have built needed coalitions and advanced the health IT field at critical junctures. We look forward to doing so once again.

The RFI seeks input on the EHR Reporting Program established as Section 4002 in the Cures Act and codified as Section 3009A in Title XXX of the Public Health Service Act (PHSA). HHS and ONC seek public comments on a great breadth and depth of issues including:

• Cross-Cutting Priorities:  Priorities at the intersection of health IT product-related reporting criteria and health care provider reporting criteria; and

• Reporting Criteria Categories: Specific categories of prescribed Cures Act EHR reporting criteria (interoperability, usability and user-centered design, conformance to certification testing and other categories as appropriate to measure performance of certified EHR technology).

Nearly 50 questions are posed in this RFI whose answers -- as processed by ONC -- will have far-reaching impacts on health care and the health system as a whole. The information gathering and synthesis required to answer these RFI queries and to put consensus into action, eHI believes, will be a longer-term collaborative process, as suggested. Our organization has been a long time, prominent health IT leader and a historical fulcrum for convening critical consensus-based discussions. We offer eHI’s nationally recognized leadership, expertise and multi-stakeholder forums as this process progresses and would be honored to participate in the ONC criteria development process going forward.  Given the broad landscape of issues raised in the RFI, eHI is in a unique position to offer on-going insight.

A timely example of this eHI capability is the work of eHI expert workgroups, which include:

• Value & Reimbursement
• Technology and Analytics
• Workflows to Improve Provider and Patient Experience

The workgroups’ mission includes looking at closing gaps in data, removing barriers to sharing information, educating patients and providers about consent to share data, incentivizing data sharing, remote patient monitoring and patient engagement. Many of these same issues are addressed by ONC’s RFI. On-going eHI workgroup dialogue and products --including best practices and recommendations for policy and industry -- will enable our organization to have valuable insights for ONC on the road ahead.

In addition, eHI’s extensive eHealth Resource Center -- a clearinghouse of success stories, reports, surveys and other material -- can provide important context and guidance as ONC moves forward on issues related to this RFI. This information hub can be accessed at: https://www.ehidc.org/resources.

Lastly, as ONC lays out further requirements and an implementation roadmap for the 21^st Centry Cures Act Electronic Health Record Reporting Program, eHI urges you to recognize we are in a time of both great progress and tremendous regulatory overlay relating to health IT and EHRs.  Acknowledging this reality, eHI recommends a careful, focused and efficient approach that builds on and utilizes existing initiatives and success, rather than duplicating or hindering current work. ONC should create high-value, additive policy and practice. Fundamentally, a focus on identifying and ensuring that gaps are filled should be the ONC approach in evaluating comments received on the RFI. Related to this, we urge ONC to pay careful attention to feedback from providers and developers on issues related to design and implementation of the 21^st Century Cures Act Electronic Health Record Reporting Program.

eHI looks forward to working with you and other key federal government players on these issues.

If you have any questions or need clarification, please contact me at jennifer.covich@ehidc.org

Sincerely,

Jennifer Covich Bordenick
Chief Executive Officer
eHealth Initiative