Re: HHS-OCR-0945-AA00 – Request for Information on Modifying HIPAA Rules to
Improve Coordinated Care
Dear Mr. Severino:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) appreciate
the opportunity to comment on the Office for Civil Rights (OCR) Request for Information on
Modifying HIPAA Rules to Improve Coordinated Care (HIPAA RFI).
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.
Clinical data registries uniformly collect protected health information (PHI) from their
participating health care providers (Participants) and must adopt policies and procedures to
comply with the HIPAA Rules in doing so.
The Coalition greatly appreciates OCR’s attention to promoting information sharing. In
conjunction with the Office of the National Coordinator for Health Information Technology
(ONC) rulemaking to implement the information blocking requirements in the 21st Century
Cures Act, the Coalition looks forward to working with OCR to promote information sharing and
interoperability and reduce regulatory and administrative burden.
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