AMIA Public Comments

In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the American Medical Informatics Association (AMIA) supported proposed flexibilities in how hospitals comply with the Promoting Interoperability (PI) Program and those that incentivize them to continue investments in health IT. However, they continued to urge CMS to more […]

In comments submitted this week to the U.S. Food and Drug Administration (FDA), the nation’s informatics professionals applauded the agency for developing a regulatory Modification Framework for Artificial Intelligence (AI)/Machine Learning (ML)-based software as a medical device (SaMD). The American Medical Informatics Association (AMIA) offered additional observations and recommendations for […]

In comments submitted to the Centers for Medicare & Medicaid Services (CMS), AMIA recommended a phased approach for making payer and insurance plan data available through open application programming interfaces (APIs) to beneficiaries. AMIA also called on the CMS Innovation Center (CMMI) to develop new models to provide structural funding […]

In comments submitted to the Office of the National Coordinator for Health Information Technology (ONC), AMIA applauded the agency on its thoughtful and thorough “21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program proposed rule.” AMIA advised ONC to establish an overall “share now, standardize […]

In comments submitted to the National Science Foundation’s (NSF) Networking and Information Technology Research and Development Program (NITRD), AMIA supported their future vision for interoperability among medical devices, electronic health records, and other systems within the healthcare ecosystem. In doing so, AMIA observed that the future of interoperability will undoubtedly […]

In comments submitted to the Department of Health & Human Services (HHS) Office of Civil Rights (OCR), AMIA recommended that the Office ensure that HIPAA both requires and permits information-sharing upon patient and clinician request, as well as robust penalties for failing to deliver data pursuant to the patient “right […]

In comments submitted to ONC and CMS, AMIA recommended that the Department of Health and Human Services orient its documentation burden reduction strategy towards a long-term goal of decoupling clinical documentation from billing, regulatory, and administrative compliance requirements. AMIA highlighted the unique opportunity to leverage informatics tools and methodologies to […]

In response to a Request for Information from the National Institute for Standards and Technology, AMIA recommended that a planned project to develop a reference architecture for remote patient monitoring utilize existing mobile infrastructures and available health IT standards, such as FHIR, to improve the likelihood of success.

In response to a Request for Information from the Centers for Disease Control and Prevention, AMIA urged HHS officials to focus on narrow use cases, such as CDS or eCQMs, when conceptualizing a national collaborative for health IT testing. AMIA also outlined the pros/cons of focusing on CDS versus eCQMs […]

In comments submitted to the NIH, AMIA supported an expansive update to its 2003 data sharing policy, recommending a phased approach to implement new data management and sharing requirements for NIH-funded research. It also noted that quality data management and sharing plans are prerequisite to the NIH’s goals of making […]