RE: Interoperability and Patient Access Proposed Rule (CMS-9115-P)
Dear Administrator Verma:
On behalf of more than 100,000 specialty physicians from 15 specialty and subspecialty societies, and
dedicated to the development of sound federal health care policy that fosters patient access to the
highest quality specialty care, the undersigned members of the Alliance of Specialty Medicine (the
“Alliance”) appreciate the opportunity to comment on the agency’s Interoperability and Patient Access
proposed rule. The Alliance applauds both CMS and Office of the National Coordinator for Health
Information Technology (ONC) for its cross-agency effort to seriously advance interoperability among
health care providers, payers, and patients, and to help patients become more engaged partners in their
care by enhancing access to data.
Both rules aim to stimulate game-changing innovation that is intended to minimize errors, improve care
coordination, reduce physician burden, lower costs, and enhance consumer experience. The Alliance
strongly supports these goals and has no doubt that the CMS rule will improve patient access to
information and further engage patients in their health care. However, the Alliance also has serious
concerns that if this data is unleashed too rapidly and without adequate standards, parameters, and
context, it will be uninterpretable to patients and at considerable risk for misuse. If the goal is to make
patients better healthcare consumers, then it is critical for both CMS and ONC to carry out these
reforms carefully and gradually to ensure that data can be shared with patients in a meaningful and
usable format. If the infrastructure is not first in place to ensure these protections, this surge of data
will simply overwhelm patients and the physicians who care for them and potentially be misapplied in
ways that impact coverage, access to care, and the physician-patient relationship.
…
Read full letter here
