The American Medical Association delivered the following comment letter to ONC National Coordinator Donald Rucker, MD and CMS Administrator Seema Verma urging a 30-day extension to the comment periods for the two proposed federal rules regarding interoperability and information blocking. The letter is posted in its entirety below:
Dear Dr. Rucker and Administrator Verma:
On behalf of the physician and medical student members of the American Medical Association (AMA), I want to express my appreciation for the detail and thought put into your proposed rules, 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program and Medicare and Medicaid Programs; Patient Protection and Affordable Care Act and the 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.
The 21st Century Cures Act includes many provisions that, through prudent regulation, will advance patients’ and physicians’ access to medical information. I recognize and appreciate the desire for swift rulemaking. However, such rapid change in health care policy, technology, and business practices may lead to unintended consequences for patient privacy and physician burden. Moreover, the proposed rules are interwoven, complex in nature, and include multiple detailed requests for information. To ensure that the rules are as successful as possible in meeting your goals, it is vital that stakeholders be given adequate time to provide comprehensive, thoughtful, and detailed comments. Expediency should not take precedence over deliberation as we confront a true paradigm shift in health care. I therefore urge that the comment periods for both rules be extended by at least 30 days. I appreciate your consideration and ongoing collaboration.
Thank you for considering our request. If you have any questions or care to discuss further, please feel free to reach out to Margaret Garikes, vice president of federal affairs, at 202-789-7409 or firstname.lastname@example.org.
James Madara, MD