Public Comments

2021

• Response to Medicare Program; CY 2022 Payment Policies Under the Physician Fee Schedule and Other
  Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider
  Enrollment Regulation Updates; Provider and Supplier Prepayment and Post-Payment Medical
  Review Requirements
• Proposed Modifications to the HIPAA Privacy Rule to Support, and Remove Barriers to, Coordinated Care and Individual Engagement NPRM, RIN 0945-AA00

2020

• Response to Proposed Rule on Interoperability-Related Provisions in the Annual Physician Fee Schedule, Primarily for the Merit-based Incentive Payment System (MIPS) CMS-1734-P
• Response to Proposed Rule on Grants, Contracts, and Other Agreements: Fraud and Abuse; Information Blocking; Office of Inspector General’s Civil Money Penalty Rules RIN 0936–AA09
• Joint industry letter to U.S. House and U.S. Senate regarding outdated rider language in the Fiscal Year 2021 Labor, Health and Human Services, and Education and Related Agencies (Labor-HHS) Appropriations bills that prohibits the US Department of Health and Human Services (HHS) from spending any federal dollars to promulgate or adopt a national unique patient identifier (UPI)

2019

• Response to ONC’s Trusted Exchange Framework (TEF) Draft 2
• Centers for Medicare Medicaid Services (CMS) Proposed Rule: 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 (CMS-9115-P)
• The Department of Health and Human Services (HHS) Proposed Rule: 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program (RIN 0955-AA01)
• Interoperability Matters Information Blocking Workgroup Final Report on ONC March 2019 Proposed Rule: Information Blocking Provisions
• Response to Request for Information on Modifying HIPAA Rules to Improve Coordinated Care (RIN 0945-AA00)

2018

• 21st Century Cures Act
• Response to ONC’s Draft Trusted Exchange Framework (TEF)