AMIA Public Comments

In comments submitted to ONC's Recognized Coordinating Entity (RCE) for the Trusted Exchange Framework and Common Agreement (TEFCA), AMIA stressed that participants and subparticipants must be confident that participation in TEFCA will be a net benefit to their current exchange activities. AMIA further recommended that ONC scenarios to clarify how TEFCA […]

In comments submitted to the new Congressional Social Determinants of Health Caucus (SDOH) Caucus, AMIA stressed that data issues, including standards, systems, policies, access, privacy, ethics, and analysis, must be top of mind when discussing any bipartisan legislative efforts to address SDOH challenges. AMIA’s response to the Caucus’ request […]

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 […]

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 […]

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 […]

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 […]

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 […]

In comments to submitted to the Agency for Healthcare Research and Quality (AHRQ), AMIA stressed that “data creation and collection and algorithm development, deployment, and evaluation do not occur in a value-free vacuum.” Thus, while “there are systematic steps and approaches that can be helpful in both recognizing and reducing […]

In comments submitted to the National Institutes of Health (NIH), AMIA called for the creation of new funding opportunities for diversity, equity, and inclusion (DEI) research, as well as prioritizing DEI research proposals, researchers, training, and experience. AMIA further urged NIH to incentivize partnerships between large research institutions and those […]