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    January 28, 2019  

    Donald Rucker, MD
    National Coordinator for Health Information Technology
    Office of the National Coordinator for Health IT  
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building
    200 Independence Avenue, SW Washington, DC 20201

    Re: Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Heath IT and EHRs 
    Dear National Coordinator Rucker:

    The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to publication of the “Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Heath IT and EHRs.” MGMA supports the efforts of the Office of the National Coordinator for Health Information Technology (ONC) to facilitate the deployment and utilization of effective health information technology (IT) across providers and other stakeholders. 

    MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 45,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.

    As a strong advocate of increased patient safety and improved efficiencies in ambulatory care settings, MGMA has long promoted the adoption of effective, efficient, and affordable health IT. In addition to the clinical benefits associated with health technology, we believe the more efficient availability of clinical data can be leveraged to improve administrative processes resulting in an overall reduction in practice costs.  

    Passage of the bipartisan 21st Century Cures Act (CURES) creates the opportunity to define and promote the development of improved use of health IT. At the same time, there is an opportunity to leverage health IT to reduce the many clinical and administrative burdens that plague our healthcare system. However, before we can achieve these benefits of health IT, significant modifications to government policy in the areas of quality reporting programs, IT certification protocols, IT standards, and other policy need to occur. ONC’s draft report serves as a roadmap for opportunities to reduce clinical and administrative burdens. This roadmap contains four parts: 1. clinical documentation; 2. health IT usability and the user experience; 3. EHR reporting; and 4. public health reporting. With the release of this draft document, ONC has outlined a blueprint that we hope will accelerate adoption of a more effective and efficient health IT environment for physician practices.

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