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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Request for Information: Electronic Prior Authorization Standards, Implementation Specifications, and Certification Criteria

March 25, 2022

In comments submitted to ONC, AMIA calls for a coordinated effort to address prior authorization burdens for patients and providers.

NIH Request for Information (RFI) on Proposed Updates and Long- Term Considerations for the NIH Genomic Data Sharing Policy

February 28, 2022

In comments submitted to the National Institutes of Health, AMIA calls for strengthening protections for data across its lifecycle.

Establishing a Pathway for Comprehensive Telehealth Reform

January 31, 2022

Thank you for your leadership in expanding access to virtual care during the COVID-19 public health emergency (PHE). This access has been transformational – Americans now expect that the future of our health care system includes telehealth as a key way to access health care services. Health care providers across […]

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 […]

Addressing Algorithmic Bias Only One Part of Broader Societal Effort, AMIA Tells AHRQ

May 4, 2021

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 […]

AMIA Calls for New Focus on DEI Research

April 15, 2021

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 […]

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