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HHS Releases Landmark Report: Reforming America’s Healthcare System

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HHS Releases Landmark Report: Reforming America’s Healthcare System

On December 3, 2018, the Department of Health and Human Services (HHS) released an extensive, 120-page report on the administration’s proposals to reform the healthcare system. The ...

On December 3, 2018, the Department of Health and Human Services (HHS) released an extensive, 120-page report on the administration’s proposals to reform the healthcare system. The report, titled Reforming America’s Healthcare System Through Choice and Competition, is divided into four major sections. The report  that government policy of the last few years has suppressed competition, increased prices for healthcare, and limited choices for consumers. Though rich in detail as it tries to prove each of these points, the more than fifty recommendations are often broad and aspirational rather than practical.

Since I am not a health economist, I will leave the market issues to others to discuss (many of the ideas in this report have been vetted and discussed by others previously). But there are two sections of the report which make direct mention of Health IT.

A Public Health Perspective ONC’s Strategy to Reduce Burden on Physicians

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A Public Health Perspective ONC’s Strategy to Reduce Burden on Physicians

On November 28, 2018 the Office of the National Coordinator for Health Information Technology (ONC) released a draft Strategy on Reducing Regulatory and Administrative Burden Relat ...

On November 28, 2018 the Office of the National Coordinator for Health Information Technology (ONC) released a draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs for public comment. The strategy aims to reduce the time and effort and improve the functionality of electronic health records (EHRs) for clinicians, hospitals, and other healthcare organizations.

This strategy was developed primarily through the efforts of ONC-convened workgroups in response to requirements laid out by Congress in the 21st Century Cures Act (Section 13103). The report itself does not identify who exactly served on these workgroups and what organizations were represented.

ONC EHR Reporting Program RFI: A Public Health Perspective

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ONC EHR Reporting Program RFI: A Public Health Perspective

On August 24, 2018, the Office of the National Coordinator for Health Information Technology (ONC) released a Request for Information (RFI) related to the EHR Reporting Program. Th ...

On August 24, 2018, the Office of the National Coordinator for Health Information Technology (ONC) released a Request for Information (RFI) related to the EHR Reporting Program. This RFI is required by the 21st Century Cures Act and its primary purpose is to gather ideas and suggestions related to how ONC might provide better information about Certified EHR Technology (CEHRT).

Apparently, the initial intention was to create a “star rating” like the type used in Consumer Reports to use to rate EHRs, but that seems to have been abandoned in favor of some kind of measurement system. But it is far from clear exactly how this would be done. There may be something to learn from the Immunization Information System (IIS) community: with guidance from the CDC, the American Immunization Registry Association (AIRA) initiated a process to help assess compliance of IIS with national functional standards through a formal measurement and improvement initiative. “Validation,” rather than “certification” or “compliance,” is the carefully-chosen term to signify a system meeting the designated measures through formal testing. The process is interactive, and the results are only made public with the agreement of the IIS program. Perhaps some of the concepts and processes in this initiative can be useful for the EHR Reporting Program.

Frankly, there is not much of interest in here for public health, which is not in the business of worrying about CEHRT. Of course, the quality and functionality of EHR products does impact their effectiveness in supporting interoperability with public health registries. To that end, the RFI does as some questions towards the end (p. 42918) about additional information that might be useful for prospective purchasers of CEHRT, including “Submitting, editing, and retrieving data from registries, such as clinician-led clinical data registries.”

ONC asks for how they might prioritize including information related to this in EHR Reporting as well as data sources for reporting about this. It may be useful for public health to weigh in on these questions; comments are due no later than 5 p.m. on October 17, 2018 at the Federal eRulemaking Portal.

CMS IPPS Final Rule: A Public Health Perspective

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CMS IPPS Final Rule: A Public Health Perspective

On August 2, 2018 the Centers for Medicare and Medicaid Services (CMS) released the 2019 Inpatient Prospective Payment System Final Rule to Quality Payment Program. We earlier rele ...

On August 2, 2018 the Centers for Medicare and Medicaid Services (CMS) released the 2019 Inpatient Prospective Payment System Final Rule to Quality Payment Program. We earlier released thoughts on the Proposed Rule as well as our formal comments.

The Final Rule affirmed most of CMS’ proposed changes, with some notable exceptions:

  • Required public health measures were reduced from three (Stage 3 requirement) to just two, but Syndromic Surveillance will not be a requirement for hospitals covered under the rule.
  • While CMS continued to be unclear about its plans for the removal of public health measures altogether for CY2022 and beyond, they did express some openness to consider continuing public health measures and to study the issue over the next few years.

It is clear from the comments discussed in the final rule that comments submitted supporting public health requirements were received, noted, and had a positive impact on the final rule. Kudos to public health advocates for their strong voice!

HLN Submits Comments to CMS on IPPS NPRM

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HLN Submits Comments to CMS on IPPS NPRM

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemakin ...

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program based on our earlier comments:


HLN Consulting, LLC is pleased to submit the following comments on the recently-released CMS IPPS NPRM, CMS–1694–P. HLN is a leading public health informatics consulting company. With that in mind, we read documents like the NPRM through a public health lens, and confine our comments to that important context.