AMIA Public Comments

In comments submitted September 29, AMIA recommend several ways the NIH could assess the value of biomedical digital repositories and knowledgebases.  The metrics span categories related to "utilization" and "impact" to "service quality" and "governance."  AMIA recommended another category be included relate to data quality and data completeness.

In conjunction with HIMSS and 36 other organizations, AMIA submitted recommendations on how the Office of Management & Budget should update the Standard Occupational Classification codes, which help Federal statistical agencies understand and forecast national data on occupations. The groups strongly recommended separate codes for Health Informatics, Health IT and […]

In comments submitted to CMS, AMIA recommend CMS proceed with proposals for a 90-day reporting period for hospitals in 2016, and it supported policies that are meant to align requirements for hospitals participating in MU with requirements for clinicians participating in MIPS.

In comments submitted to CMS, AMIA supported continued policymaking to implement the Medicare AUC Program as part of the 2017 Physician Fee Schedule. The organization strongly recommended CMS target a 2019 implementation deadline, rather than the proposed 2018 start.

In conjunction with a public meeting held by the FDA August 15, 2016, AMIA submitted public comments supporting the direction of the its Prescription Drug User Fee Agreement Commitment Letter.  Specifically, AMIA supports FDA’s work to utilize Real World Evidence in regulatory decision-making, incorporating the patient’s voice in drug development […]

On July 18, 2016, AMIA submitted comments to FDA regarding their draft guidance to industry on using EHR data in clinical investigations.  AMIA was supportive of the guidance, but challenged the assertion that EHR data was readily usable for prospective randomized controlled trials.

On June 27, 2016 AMIA submitted comments to CMS regarding proposed policies related to the new Medicare Quality Payments Program, which replaces the Sustainable Growth Rate and reforms how nearly 1.3 million clinicians are paid through Medicare.  AMIA described a set of principles and recommendations CMS should consider during implementation […]

On May 23, 2016, AMIA submitted comments to the Office of the National Coordinator recommending they develop a patient-centric approach to measuring nationwide health IT interoperability.  As part of this recommendation, AMIA described a new methodology and approach to measuring interoperability that they said should be developed immediately.  AMIA also […]

On April 27, 2016, AMIA submitted comments to the Office of the National Coordinator supporting their proposed authority to conduct direct review of certified health IT products.  AMIA said that reviews should be limited to instances when health IT posed a potential or real threat to patient safety, or was […]

On April 6, 2016, AMIA called proposed revisions to substance use disorder (SUD) regulations, also known as 42 CFR Part 2, well-intentioned, but ultimately insufficient. AMIA urged the Department of Health and Human Services (HHS) to lead a national effort to develop technical standards that would enable patients to have […]