Re: Advancing Interoperability and Health Information Exchange
Dear Dr. Mostashari,
The undersigned organizations appreciate the opportunity to submit comments to the Office of the
National Coordinator for Health Information Technology (ONC) and the Centers for Medicare &
Medicaid Services’ (CMS) Request for Information (RFI) on Advancing Interoperability and Health
Information Exchange.
As the nation’s healthcare system is undergoing a transformation in an effort to improve quality, safety,
and efficiency of care, the undersigned organizations support ONC and CMS’ goal to advance
interoperability and health information exchange (HIE). We believe that these efforts can improve care
coordination and support new service delivery and payment models. Our comments are presented in the
order in which they appear in the RFI.
I. Background
The undersigned organizations value ONC and CMS’ goal to achieve widespread interoperability and the
electronic exchange of information. However, because eligible professionals (EPs) and eligible hospitals
(EHs) are working hard to be compliant with stage 1 of the CMS Electronic Health Record (EHR)
Incentive Program, we encourage CMS and ONC to focus on remedying current challenges within the
program rather than proposing new criteria that may hinder the progress made by providers and hospitals
thus far. We are greatly concerned that changes are being sought without considering how providers,
especially specialists, have fared with meeting the criteria used in stages 1 and 2 of the EHR Incentive
Program. Information needs to be collected, through validated survey methodologies, on how providers
are performing before making recommendations for new criteria or increasing reporting thresholds in
stage 3 or future iterations of the program. Examples of challenges currently facing EPs in the EHR
Incentive Program include the absence of requirements to meet specific needs of certain specialties, the
difficulty for many solo and small group practitioners and physicians, some of whom are key providers in
underserved areas, or who may be in and near retirement, to invest in and adopt EHRs, and the lack of
valuable quality measures for specialists.
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