Comment Letter

Neurosurgery Comments on HIT Proposed Rule

  • Quality Improvement and Patient Safety

Micky Tripathi, PhD, MPP
National Coordinator
Office of the National Coordinator for Health Information Technology
Department of Health and Human Services
Attention: HTI-1 Proposed Rule (RIN 0955-AA03)
Mary E. Switzer Building
330 C. St S.W., 7th Floor
Washington, D.C. 20024

RE: Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing (HTI-1) Proposed Rule

Dear National Coordinator Tripathi,

The Alliance of Specialty Medicine (the “Alliance”), representing more than 100,000 specialty physicians from sixteen specialty and subspecialty societies, is deeply committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we write to provide feedback on ONC’s HTI-1 proposed rule.

ONC’s HTI-1 proposed rule seeks to implement provisions of the 21st Century Cures Act and make updates to the ONC Health IT Certification Program (Certification Program) to better support the access, exchange, and use of electronic health information among healthcare stakeholders. Overall, the Alliance supports ONC’s goal of advancing interoperability, enhancing health IT functionality, improving transparency, and reducing burden and costs— particularly among patients, clinicians, and other end users of certified EHR technology (CEHRT). However, we are concerned that the rule does not address certification criteria needed to support electronic prior authorization requirements recently proposed by CMS.

Click here to read the full Neurosurgery Comments on HIT Proposed Rule.