RE: 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT
Certification Program Proposed Rule (RIN 0955-AA01)
Dear Dr. Rucker:
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 ONC and the Centers for Medicare and Medicaid Services
(CMS) 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 accelerate game-changing innovation aimed at minimizing errors, improving care
coordination, reducing clinician burden, lowering costs, and enhancing consumer experience. The
Alliance strongly supports these goals and has no doubt that many of the proposals in the ONC rule will
accelerate progress towards a more interoperable healthcare system. However, if the numerous new
and complex requirements set forth in this rule are implemented too rapidly, it will result simply in a
proliferation of poorly functioning products as the industry shifts its focus to solely satisfying the
parameters of this rule rather than developing features that serve markets such as specialty medicine.
Furthermore, the Alliance also has serious concerns that if 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 and to provide clinicians
with information that will lead to more appropriate and efficient care, then it is critical for both CMS and
ONC to carry out these reforms carefully and gradually. If the infrastructure is not first in place to
minimize these risks, then this surge of data will simply overwhelm patients and the clinicians who care
for them and potent
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Read full letter here
