May 30, 2019
The Honorable Seema Verma
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
202 Independence Avenue, S.W., Room 445-G
Washington, D.C. 20201
Re: CMS-9115-P, Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Interoperability and Patient Access for Medicare Advantage Organization and Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans in the Federally-Facilitated Exchanges and Health Care Providers
Dear Administrator Verma,
The Medical Group Management Association (MGMA) is pleased to submit the following response to the Centers for Medicare & Medicaid Services’ (CMS’) proposed rule seeking to improve the nation’s healthcare delivery system by increasing interoperability and patient access to health information and meeting the requirements outlined in the bipartisan 21st Century Cures Act (Cures Act). Improving access to information will assist both clinicians and patients make informed healthcare decisions. We applaud the agency for recognizing the need to improve interoperability as well as increase access to health care information and for seeking stakeholder feedback on how best this can be accomplished.
MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 40,000 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.
CMS has proposed an extremely ambitious set of requirements on physician practices and health IT developers. We support many of the Administration’s health IT goals, particularly putting patients more at the center of the care delivery process and arming them with the health information they need. Our hope is that interoperability, if appropriately implemented, will permit physician practices and other care providers to gain quicker access to more accurate and pertinent patient information. MGMA appreciates the intent of the CMS Proposed Rule and the promise that health IT offers physician practices. However, as Senate Health, Education, Labor and Pensions Committee Chairman Lamar Alexander reminded the Administration at the May 7 hearing Implementation of the 21st Century Cures Act: Making Electronic Health Information Available to Patients and Providers, Part II, “…if you play it a little slower, you’re less likely to make a mistake.” We urge ONC to avoid pushing physician practices too far, too fast. The risks of moving too quickly include additional administrative and financial burdens on practices, weaker privacy and security protections for of sensitive health information, an increased level of physician burnout, and even the potential of compromised patient care.