AMIA Public Comments

Generally, AMIA encourages FTC to ensure that HBNR and HIPAA are aligned such that there are no gaps in regulation over the covered entities and other non-covered entities that work with PHR; to align definitions with other agencies, including the definition of PHR; and to provide clarity around whether a […]

AMIA’s leadership and staff consistently value and prioritize health data privacy through our country’s ever-changing healthcare landscape. In 2020, AMIA published a set of Policy Principles, which details our stance on the need for health and healthcare data privacy as follows:

We appreciate ONC taking into account our prior comments supporting enhanced harmonization of policies among agencies including the Food and Drug Administration (FDA), the Federal Trade Commission (FTC), and the Centers for Medicare and Medicaid Services (CMS). We also strongly support the use of updated vocabulary standards as found in […]

AMIA supports efforts by HHS to revise the Standards for Privacy of Individually Identifiable Health Information (“Privacy Rule”) under HIPAA and HITECH Act, to implement protections limiting uses and disclosures of protected health information (PHI) for certain purposes where the use or disclosure of information is about reproductive health care […]

AMIA, along with other organizations, urges Congress to fully fund the U.S. Department of Health and Human Services’ (HHS) Office of the National Coordinator for Health Information Technology (ONC) at the President’s proposed FY24 budget request of $103.6 million. ONC has long served as the key partner to public and […]

AMIA appreciates ONC’s efforts to solicit feedback on data collection for future iterations of USCDI. Overall, AMIA encourages ONC to ensure that USCDI will decrease burden with common elements for interoperable exchange. Increasing burden on clinical workflow will be a detriment to all stakeholders. We believe the lack of clear […]

AMIA appreciates the efforts of the Working Group and the Office of the Chief Statistician to improve the quality and usefulness of federal race and ethnicity data. The current (1997) race and ethnicity standards should be revised to capture data that reflect the diversity of the U.S. population more accurately […]

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 […]

AMIA commends CMS for taking steps to address the workflow burden of prior authorization and the significant barriers and delays that it imposes on medical practice. Most importantly, prior authorization impedes timely patient access to needed care and in some cases, results in denial of appropriate care altogether. We believe […]

AMIA provided comments to The White House Office of Science and Technology Policy (OSTP) Request for Information on Clinical Research Infrastructure and Emergency Clinical Trials. AMIA commends OSTP for its focus on efforts to protect the public health in cases of national emergency. An established research infrastructure, uniform protocol […]