Public Comment Opportunity: ONC Requests Feedback on EHR Reporting Program by October 17

Stakeholders have the opportunity to submit comments regarding the Electronic Health Record (EHR) Reporting Program established as Section 4002 of the 21st Century Cures Act (Cures Act). Section 4002(c) of the Cures Act requires the U.S. Department of Health and Human Services (HHS) to establish the EHR Reporting Program to provide publically-available comparative information on certified health IT. Under the Centers for Medicare and Medicaid Services’ Promoting Interoperability Programs (PI Programs, formerly the EHR Incentive Programs), health care providers must use an EHR that is certified specifically for the PI Programs to avoid a Medicare payment adjustment or to receive a Medicaid incentive payment. The EHR Reporting Program will provide data to assist health care providers in comparing and selecting certified health IT.

Per the Cures Act, HHS must require health IT developers to satisfy certain requirements as a condition of certification and maintenance of certification, including submitting reporting criteria established by HHS. The EHR Reporting Program is required to address at least the following five topic areas: security; interoperability; usability and user-centered design; conformance to certification testing; and other categories, as appropriate to measure the performance of certified EHR technology.

On August 24, 2018, the HHS Office of the National Coordinator for Health Information Technology (ONC) issued a request for information (RFI) soliciting feedback from the public to inform the establishment of these reporting criteria. Specific questions are posed within two general areas of requested input:

  • Cross-cutting: Requests input on priorities on the intersection of health IT product-related reporting criteria and healthcare provider reporting criteria; and
  • Categories: Requests input on specific focus areas, including the reporting criteria categories required by the Cures Act.

Per the RFI, responses will be used to inform subsequent discussions among stakeholders and future work toward the development of reporting criteria and processes under the EHR Reporting Program as required by the Cures Act. ONC encourages commenters to consider existing sources of information about health IT products, what information is lacking from these sources, and what the reporting criteria under the EHR Reporting Program could uniquely contribute.

Comments are due no later than 5:00 PM ET on Wednesday, October 17, 2018. Instructions for submitting online, by mail, or by hand are provided in the RFI. Comments that are received before the close of the comment period will be posted at

ONC will host an informational call at 2:00 PM ET on Thursday, September 6, 2018 to provide additional details on the RFI and to answer general questions. Although space is limited, a second webinar will be scheduled if necessary. Interested participants may access the call information here.

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