June 20, 2023
Micky Tripathi, Ph.D., M.P.P.
National Coordinator for Health Information Technology
Office of the National Coordinator for Health Information Technology
Department of Health and Human Services
330 C Street SW
Washington, DC 20201
Re: RIN: 0955-AA03, Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing
Dear Dr. Tripathi:
On behalf of our member medical group practices, the Medical Group Management Association (MGMA) thanks you for the opportunity to provide comments on the Office of the National Coordinator for Health Information Technology’s (ONC’s) Notice of Proposed Rule Making on Certification Program Updates, Algorithm Transparency, and Information Sharing (“proposed rule”).
With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups in which more than 350,000 physicians practice. These groups range from small private practices in rural areas to large regional and national health systems, and cover the full spectrum of physician specialties and organizational forms, making MGMA well-positioned to offer the following feedback.
While many aspects of the proposed rule make appropriate updates to important ONC-administered health information technology (IT) programs, we offer the following comments to highlight areas significant to medical groups. MGMA supports ONC’s efforts to promote interoperability and transparency in the electronic sharing of health information. We have long advocated for patient safety and the adoption of safe, effective, and affordable health IT to improve administrative processes and reduce practice costs.
We hope the agency will work in collaboration with medical groups of all sizes to ensure that the proposed changes to information blocking regulations, ONC certification criteria, decision support interventions, and more function properly as to ensure there are no unintended consequences. Adding unnecessary administrative and financial burdens to practices will only hinder necessary efforts to facilitate the efficient sharing of electronic health information (EHI).
June 20, 2023