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AAMC Submits Comment Letter on RFI for Assessing Interoperability under MACRA

June 3, 2016—The AAMC June 1 submitted a comment letter  in response to the Office of National Coordinator (ONC) for Health Information Technology (HIT) request for information (RFI) on assessing interoperability for the Medicare Access CHIP Reauthorization Act (MACRA, P.L. 114-10). The RFI solicits comments in three specific topic areas, including: measurement population, assessing current data sources, and other data sources to successfully measure interoperability.

The AAMC appreciates ONC’s efforts in gathering information that will be used to develop metrics to determine the extent to which there is widespread exchange of health information through interoperable certified electronic HIT. However, the AAMC is concerned that the measures mentioned in the RFI focus on the movement of information and not the importance of the information exchanges for the improvement of patient care. Rather than metrics relying primarily on measuring transactions, metrics should indicate whether or not the information is meaningful to the clinician who is delivering high-quality, low-cost patient care.

The AAMC suggests that ONC work with the Centers for Medicare and Medicaid Services (CMS) to identify objectives under MACRA’s Advancing Care Information program that demonstrate the value of interoperability to patent care while avoiding burdensome reporting.

CMS is currently seeking feedback on the MACRA proposed rule and the final rule is expected to be released in November 2016. 


Len Marquez
Director, Government Relations
Telephone: 202-862-6281


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Telephone: 202-903-0806