SUBJECT: ONC Strategy on Reducing Regulatory and Administrative Burden Relating to
the Use of Health IT and EHRs
Dear Dr. Rucker:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we
appreciate the opportunity to comment on Office of the National Coordinator for Health Information
Technology’s (ONC) Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of
Health IT and EHRs.
We refer ONC to the comments submitted by the Alliance of Specialty Medicine, as well as the Physician
Clinical Registry Coalition (PCRC). The AANS and the CNS are active members of both of these
coalitions and support the positions expressed in each of their comment letters.
In addition to those comments, we urge ONC to consider the following recommendations:
- Clinical Documentation: ONC should require qualified EHRs to offer simple export of data in a
standardized electronic format for purposes of prior authorization, transfer of care, and patient
request. Insurer and self-insured employers subject to federal regulation should be required to
accept documentation in standardized electronic format for purposes of prior authorization and
related appeals.
…
Read full letter here
