• Analysis or Summary
  • June 7, 2019

CHA Comments on Proposed Interoperability, Pediatric HIT and Information Blocking Rules

On June 3, CHA submitted comment letters to CMS and the Office of the National Coordinator for Information Technology (ONC) on their respective companion proposed rules on interoperability, electronic health record (EHR) certification and information blocking. Each letter focuses on aspects of the proposed rules with implications for children’s health care, including issues of safety, security and confidentiality considerations that are unique to pediatrics.

The letter to CMS also highlights our opposition to its proposed Medicare/Medicaid Condition of Participation that would require all hospitals to electronically notify all of a patient’s providers when the patient is admitted, discharged or transferred. The letter to ONC includes our recommendations related to the types of EHR data that should be collected for pediatric care; refinements to proposed voluntary pediatric EHR certification requirements; and concerns regarding the inclusion of price information in the scope of the prohibition on information blocking.