SUBJECT: HHS-ONC-2018-022 – Request for Information Regarding the 21st Century
Cures Act Electronic Health Record Reporting Program
Dear Dr. Rucker:
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the
opportunity to comment on this request for information (RFI) regarding the Electronic Health Record
(EHR) Reporting Program.
The EHR Reporting Program was established under Section 4002 of the 21st Century Cures Act (Cures
Act) and is intended to provide publicly available, comparative information on certified health information
technology (HIT) that will inform the purchasing and implementation decisions of certified HIT users. The
Cures Act requires that these reporting criteria specifically address security, interoperability, usability and
user-centered design, and conformation to certification testing, as well as other categories as
appropriate. The Cures Act also suggests several other categories for consideration, including, but not
limited to: enabling users to order and view results of laboratory tests, imaging tests, and other diagnostic
tests; exchanging data with clinical registries; accessing and exchanging data from medical devices,
health information exchanges, and other health care providers; and accessing and exchanging data held
by federal, state, and local agencies. Importantly, the statute also requires that ONC establish these
reporting criteria through a public, transparent process that reflects input from developers and end users
of certified HIT. This RFI represents a first step toward developing these criteria and implementing the
statute.
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