AMIA Public Comments

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 […]

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 […]

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 […]

In response to a CMS request for information (RFI) on how it can use emerging technologies like artificial intelligence (AI) and machine learning (ML) to improve program integrity, AMIA cautioned that such technologies are still in their infancy. AMIA called on CMS that – as it considers the use of […]

In comments submitted to the Centers for Medicare & Medicaid Services (CMS), AMIA reiterated some previous recommendations it made to HHS and made several new ones for CMS to consider in various categories that drive regulatory and administrative burden: documentation; reporting; lack of program alignment; heath IT usability and user […]

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 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 […]