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Association Comments on Interoperability Proposed Rules

In June 3 letters, America’s Essential Hospitals encouraged the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) to consider the regulatory burden that new interoperability requirements would place on essential hospitals.

The letters were sent in response to proposed rules on interoperability released in February by the agencies.

The CMS rule, if finalized, would revise the Medicare hospital conditions of participation (CoPs) to require hospitals share data with other providers and facilities when a patient is admitted, discharged, or transferred. The rule also would make public a list of hospitals and other providers engaging in “information blocking.”

America’s Essential Hospitals urged CMS not to add health information exchange requirements to the Medicare CoPs and to ensure:

  • security and privacy of data disseminated through application programming interfaces; and
  • provider directories contain meaningful information that will facilitate health information exchange.

The ONC rule, if finalized, would define the types of data providers and other entities must exchange to avoid information blocking penalties and delineate seven exceptions to the term “information blocking.” The proposed rule includes provisions related to substance use disorder and prescription drug monitoring programs (PDMPs).

America’s Essential Hospitals urged ONC to:

  • keep randomized surveillance requirements in place to ensure information technology products remain compliant with certification requirements;
  • revise its electronic health information (EHI) export certification criterion to ensure certified electronic health record technology (CEHRT) is capable of exporting data without excessive burden;
  • provide a transition period from the data export to the new EHI export criterion;
  • develop standards to integrate PDMPs into electronic health records and ensure clinicians can access PDMPs with minimal workflow disruption;
  • work with policymakers to clarify and lift restrictions related to substance use disorder confidentiality requirements to facilitate related health information exchange;
  • work with providers to incorporate the most relevant prescribing guidelines into electronic health records and clinical decision support tools;
  • delay implementation for the information blocking provisions of the proposed rule;
  • exclude health care providers from the definition of health information network;
  • narrow the definition of EHI used in determining what constitutes information blocking;
  • exclude price information from the definition of EHI; and
  • consider technological barriers that inhibit the segmentation of confidential patient data from the rest of a patient’s medical record in implementing its exceptions to information blocking.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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