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    January 2, 2024 

    The Honorable Micky Tripathi, Ph.D.
    National Coordinator for Health Information Technology
    Office of the National Coordinator for Health Information Technology
    330 C Street SW, 7th Floor
    Washington, DC 20201

    The Honorable Chiquita Brooks-LaSure
    Administrator
    The Centers for Medicare and Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Re: 21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking (RIN – 0955-AA05)

    Dear National Coordinator Tripathi and Administrator Brooks-LaSure:

    On behalf of our member medical group practices, the Medical Group Management Association (MGMA) is pleased to provide the following comments in response to the Office of the National Coordinator for Health Information Technology’s (ONC’s) and Centers for Medicare and Medicaid Services’ (CMS’) proposed rulemaking on establishing disincentives for healthcare providers that have committed information blocking. MGMA appreciates the agencies’ attention to information blocking as our members are dedicated to promoting interoperability and appropriately sharing health information to enhance patient care.

    With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 group medical practices ranging from small private medical practices to large national health systems, representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following policy recommendations.

    MGMA members are committed to utilizing health information technology (IT) to reduce administrative burden and advancing the provision of high-quality, cost-effective care. We have supported efforts to increase the flow of health information throughout this nation’s health IT ecosystem and understand the potential for improvement that interoperability brings. While we recognize the need for ONC and CMS to establish appropriate disincentives for providers who commit information blocking under the 21st Century Cures Act, we harbor significant concerns with the proposed rule and its impact on medical groups. MGMA offers the following recommendations to help support medical groups advance interoperability.

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