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March 21, 2023

AMIA commends the Centers for Medicare and Medicaid Services (CMS) for its effort to address administrative simplification through proposing standards for health care attachments transactions and electronic signatures. In theory, standards should be an important step to reduce provider burden if the standards are current and enable a practical application consistent with the current state of infrastructure and practice across the health care ecosystem.

We have multiple concerns with this proposed rule, and we offer the following comments for the Agency’s consideration.