AMIA Public Comments

AMIA’s goal is to improve the legislative and regulatory environment for health informatics research, practice and education through AMIA member expertise. The primary pathway through which AMIA achieves this goal is by engaging Federal Agencies and Congress on public calls for input, such as Notices of Proposed Rulemakings (NPRMs) or Request for Information (RFIs). Below, AMIA responses are arranged by Federal Agency and Congressional Committee.

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AMIA Applauds EHR Reporting Program Measures, Urges Additional Focus on Public Health and EHR Safety

September 14, 2021

In response to a request for public feedback on a set of draft developer-reported measures for the Electronic Health Record Reporting Program, AMIA recommended elevating an additional public health-focused measure to the first set of measures for the program. AMIA additionally recommended that and EHR safety measure that leverages […]

AMIA Calls for MIPS Focus on Certified Health IT, Public Health Measure Alignment in Physician Fee Schedule Proposed Rule

September 13, 2021

In comments submitted to the Centers for Medicare and Medicaid Services (CMS), AMIA continued to support the transition to the MIPS Value Pathways (MVPs) reporting mechanism, while also calling on CMS to center the use of certified health IT in MVP design. AMIA also urged CMS to align Promoting Interoperability […]

AMIA Hails Public Health Proposals, Renews Call for Improvement Activities Option in Hospital Payment Rule

June 28, 2021

In comments submitted to CMS, AMIA applauded its proposal to require reporting of the four measures associated with the Public Health and Clinical Data Exchange Objective of the Promoting Interoperability Program. In responding to a request for information (RFI) on digital quality measures (dQMs), AMIA also reiterated its call for […]

AMIA Calls for More Harmonization of Common Data Elements (CDEs) in NIH-funded Research

May 10, 2021

In comments submitted to the National Library of Medicine (NLM) and National Institute of Neurological Disorders and Stroke (NINDS), AMIA pointed the overall lack of harmonization among available Common Data Elements (CDEs). AMIA urged NLM and NINDS to take the next step in its stewardship of the NIH CDE Repository […]

AMIA Supports Overall Direction of HIPAA Modification Proposals, Calls for More Patient Privacy Protections and Alignment with Cures Rule

May 6, 2021

In comments submitted to the U.S. Department of Health and Human Services (HHS) Office of Civil Rights (OCR), AMIA applauded the agency for its proposals to promote information sharing and patient access to data. However, AMIA strongly urged OCR to coordinate with the Federal Trade Commission (FTC) to bolster protections […]

AMIA Supports Direction of CMS API Proposals

January 4, 2021

In comments submitted to CMS last week, AMIA strongly supported the agency’s effort to provide patients, providers, and payers improved access to certain data through modern API standards and policies to enable such access. However, it also cautioned that CMS should reevaluate the proposed implementation timeline and seek to include […]

AMIA Offers Input on Leveraging Novel Technologies for Chronic Disease Management for Aging Underserved Populations

December 22, 2020

In response to a Request for Information (RFI) from the HHS Office of the Assistant Secretary for Health (OASH), AMIA reminded the Office that to best leverage novel technologies for chronic disease management, there must be a recognition that care delivery models should evolve in parallel with advancements in technology […]

AMIA Lays Out Strategic Opportunities and Challenges for NLM

October 19, 2020

In comments delivered to the NIH’s National Library of Medicine (NLM), AMIA highlighted informatics-driven efforts to develop standards to facilities use of clinical data for research, foster computable and executable knowledge artifacts and a knowledge ecosystem, and advance how scholarly contributions are recognized. Beyond these efforts, AMIA encouraged NLM to […]

AMIA Urges CMS to Stay the Course on Telehealth Expansion, Encouraging Health IT Use

October 5, 2020

In comments submitted last week to Centers for Medicare and Medicaid Services (CMS), AMIA strongly supported CMS’s expansion of reimbursement for telehealth and other communications technology during the pandemic, MIPS Value Pathways (MVP) framework changes that would seek to leverage digital quality measures. It also provided detailed comments on a […]

AMIA Urges FTC to Expand Purview of Health Breach Notification Rule

August 24, 2020

In comments submitted to the Federal Trade Commission (FTC), AMIA recommended that the agency subject username/password information to its Health Breach Notification (HBN) Rule and expand its purview to provide warning to health apps that provide inadequate transparency into its data use, reuse, and exchange. AMIA further urged FTC to address […]

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