Comment on the 2015 Certification Edition Proposed Rule: The HHS Office of the National Coordinator for Health Information Technology (ONC) has issued a proposed rule for the next edition (the “2015 Edition”) of health IT certification criteria, including provisions related to health information exchange, patient engagement, social determinants of health data, sexual orientation & gender identity, race and ethnicity standards. We are also soliciting input on a new “Application Access to Common Clinical Data Set” certification criterion that would require the demonstration of an application programming interface (API) that responds to data requests for any one of the data referenced in the Common Clinical Data Set, as well as for all of the data referenced in the Common Clinical Data Set. We have developed a public comment template that can be used to respond to the specific proposals of interest to you.  Comments are due by 5pm on May 29, 2015 and may be submitted here.

Comment on Meaningful Use Stage 3: The Centers for Medicare & Medicaid Services (CMS) has released the Stage 3 proposed rule which includes provisions for the next stage of the EHR Incentive Programs, including provisions related to patient-generated health data, patient access to and provider’s role in view/download/transmit requirements, secure messaging, and API access to a common clinical data set.  Comments to the Stage 3 proposed rule are due by 5pm on May 29, 2015 and may be submitted here.

Meaningful Use Modifications Rule

The Centers for Medicare and Medicaid Services (CMS) recently released the Modifications Rule. This rule includes provisions to modify Meaningful Use in 2015 through 2017, including Stage 2 provisions related to view, download, and transmit requirements, public health reporting, and secure messaging.  Comments to the Modifications rule are due by 5pm June 15, 2015 and may be submitted here.

Both ONC and CMS will read and consider every single public comment within the scope of each respective rulemaking to inform the policies and proposals that are ultimately adopted in the associated final rules. As a point of emphasis, it is important to comment on proposals that you agree with as well as disagree with.  We look forward to your comment!