The federal government recently asked health care stakeholders for ideas on ways to advance interoperability and health information exchange. “Stop regulating” was one of the answers from the American Hospital Association in response to the request for information.

The RFI wrongly suggests that additional regulatory requirements are necessary, the association asserts in the letter to the Centers for Medicare & Medicaid Services and the Office of the National Coordinator for Health Information Technology. Instead of more rules, CMS should fully implement its new payment and delivery programs that provide incentives for information exchange, but not add specific exchange requirements, as the mechanisms of exchange may vary by project. “Concurrently, we urge ONC to re-double its efforts to remove barriers to interoperability and support the development of a robust infrastructure for health information exchange.”

The government should focus on successful implementation of data exchange requirements in Stages 1 and 2 of the electronic health records meaningful use program before placing other HIE requirements on providers, AHA contends. “Achieving Stage 2 of meaningful use will require tremendous changes to provider information systems, including adoption and use of many new standards for recording and sharing data, and will take place over the next two to three years,” according to the comment letter. “Providers are reliant on their vendors to build and deploy certified EHRs that meet the Stage 2 regulatory requirements, including the new functionality for health information exchange.”

Other recommendations from AHA include:

* Take steps now to ensure EHRs can support Stage 2 HIE requirements. ONC should make public results of its pilot testing of the Direct secure messaging protocols, “particularly as it relates to expanding use of Direct from a core set of vendors involved in creating Direct to use by all providers across the country.”

* Revise Stage 2 criteria to make the Simple Object Access Protocol (SOAP) standard for secure transport of computable data a requirement for certified EHRs. This would make both the Direct and SOAP standards available and enable providers to choose which standard is appropriate for given circumstances. “It is certainly possible that a single hospital could use both standards, depending on the capacity of receiving entities.”

* HHS should support establishment of provider directories. “A major stumbling block to information exchange, including the transition of care requirements under meaningful use Stage 2, is the lack of provider directories that allow providers and patients to determine where to send information. Given that CMS maintains the National Provider Identifier, we recommend that HHS explore ways to support the state-designated HIEs and other entities that could establish provider directories.”

The full comment letter is available here.

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