February 27, 2026
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Re: MGMA Response to HHS Office of the Secretary NPRM, Health Data, Technology, and Interoperability: ASTP/ONC Deregulatory Actions to Unleash Prosperity
Dear Dr. Keane:
The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the Health Data, Technology, and Interoperability: ASTP/ONC Deregulatory Actions to Unleash Prosperity proposed rule, published in the Federal Register on December 29, 2025. With a membership of more than 70,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups comprising more than 350,000 physicians. These groups range from small independent practices in remote and other underserved areas to large regional and national health systems that cover the full spectrum of physician specialties.











