AMIA Public Comments

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 […]

Partnering with AHIMA, AMIA recommended that policymakers modernize HIPAA by either establishing a new term, “Health Data Set,” which includes all clinical, biomedical, and claims data maintained by a Covered Entity or Business Associate, or by revising the existing HIPAA “Designated Record Set” definition and require Certified Health IT to […]

In response to a Request for Comment from the National Telecommunications and Information Administration, AMIA urged the administration to seek harmonization of federal data privacy policies, while also ensuring that consumer access to and control over his or her data be the baseline for its policies.

AMIA strongly encouraged the Trump administration to leverage an existing strategy on Artificial Intelligence Research and Development (AI R&D), rather than begin from scratch. It additionally emphasized a need for federal investments in areas of strong societal importance not aimed at consumer markets, especially related to human-AI collaboration and the […]

In comments submitted to the Office of the National Coordinator for Health IT (ONC), the AMIA questioned the constrained scope of the EHR Reporting Program, strongly recommending that it measure performance to improve CEHRT security, interoperability, and usability, and not be used simply to provide data for “acquisition decision makers.”

In response to the CMS CY2019 Physician Fee Schedule NPRM, AMIA applauded federal officials for aligning physician and hospital EHR requirements and advancing policies that further incentivize the adoption of health IT for patient care. AMIA also supported CMS efforts to reduce documentation burden through new options to use time […]

AMIA sent a set of recommendations to the federal government in late July, commenting on its Draft Federal Data Strategy. The nation’s health informatics professionals largely supported the Strategy, identifying ways it could help federal agencies improve data sharing and data availability for research and other supplemental purposes.