Re: HHS-ONC-2018-022 – Request for Information Regarding the 21st Century Cures Act
Electronic Health Reporting Program
Dear Dr. Rucker:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) appreciate
the opportunity to respond to the Office of the National Coordinator for Health Information
Technology’s (ONC) request for information (RFI) regarding the Electronic Health Record
(EHR) Reporting Program established by the 21st Century Cures Act (the Cures Act). The
Coalition is a group of medical society-sponsored clinical data registries that collect and analyze
clinical outcomes data to identify best practices and improve patient care. We are committed to
advocating for policies that encourage and enable the development of clinical data registries and
enhance their ability to improve quality of care through the analysis and reporting of clinical
outcomes. Most of the members of the Coalition have been approved as qualified clinical data
registries (QCDRs) or are working towards achieving QCDR status.
Section 4002(c) of the Cures Act requires the Secretary to develop an EHR Reporting Program
and establish reporting criteria for such a program through a public, transparent process. The
Cures Act requires that these reporting criteria address security, interoperability, usability and
user-centered design, and conformation to certification testing, as well as other categories as
appropriate, which may include those suggested in the statute. The Coalition is particularly
interested in the interoperability category (including information blocking), as well as the
inclusion of a category regarding submitting, editing, and retrieving data from registries such as
clinician-led clinical data registries, as suggested in the Cures Act.
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