Statements & Positions Archive

View archived EHRA statements & positions.

2023
December 20: Letter on Pennsylvania Immunization Registry Transition to PIERS December 20: Comments on Information Blocking Provider Disincentives Proposed Rule December 15: Comments on Utah Proposed Rule R380-70 December 13: Response to All Hazards Hospital Situational Awareness RFI November 10: Letter to ONC Regarding USCDI Modeling November 10: Letter Regarding Maryland Health Information Exchanges November 10: Letter Regarding California Assembly Bill 352 October 4: Response to Ways and Means Committee Rural Health RFI October 4: Response to Health Care Task Force Health Spending RFI October 4: Feedback to the Maryland Health Care Commission on Draft Amendments to COMAR 10.25.07 and COMAR 10.25.18 September 28: Response to Senate HELP Committee's Health Data Privacy Request for Information September 22: Response to Senate HELP Committee's AI Request for Information September 7: Feedback to CMS on the CY24 Physician Fee Schedule NPRM CMS-1784-P September 6: Feedback to CMS on the CY24 Medicare Hospital OPPS NPRM CMS-1786-P September 6: Letter to Maryland Health Care Commission Regarding SB 0786 August 29: Feedback to CMS on the Draft dQM Plan August 11: Comments to CMS on Episode-Based Payment Model RFI July 31: Comments on Proposed Updates to FTC's Health Breach Notification Rule July 13: Letter to NJDOH & NJHIN on the CKS-MPI Identifier Project June 28: Comments to Yale CORE on the Addressing Social Needs (ASN) Electronic Clinical Quality Measure (eCQM) June 20: Comments to ONC on the HTI-1 Proposed Rule June 7: Comments to CMS on the FY2024 IPPS Proposed Rule May 22: Comments to ONC on 2023 Standards Version Advancement Process (SVAP) April 12: Comments to ONC on Draft USCDI Version 4 April 11: Comments on Initial Proposals for Updating OMB's Race and Ethnicity Statistical Standards April 5: Letter to the CA Senate Health Committee Regarding SB-582 April 3: Comments to CDC on its Race & Ethnicity Code System Update March 24: Support for Data Modernization Initiative (DMI) at the CDC in FY2024 - Group Letter March 21: Comments to HHS on Health Care Attachments Transactions NPRM (CMS-0053-P) March 13: Comments to CMS on Advancing Interoperability & Improving Prior Authorization NPRM February 9: Letter to CMS Administrator Brooks LaSure January 30: Comments on Confidentiality of Substance Use Disorder Patient Records NPRM January 13: Feedback on the Draft QHIN, Participant, and Subparticipant Additional Security Requirements SOP
2022
December 21: EHR Association Letter to CalHHS on its Data Exchange Framework December 21: EHR Association Comments to OSTP on Data Collection for Emergency Clinical Trials & Interoperability Pilot RFI December 6: EHR Association Comments on FDA's Clinical Decision Support Guidance November 22: EHR Association Comments on FDA's NDC Format and Drug Label Barcode Requirements NPRM November 11: EHR Association Comments on CISA's CIRCIA 2022 RFI November 11: EHR Association Comments on Request for Information CMS-9900-NC October 21: EHR Association Comments to FTC on the Trade Regulation Rule on Commercial Surveillance and Data Security ANPR October 21: EHR Association Comments to CMS on the Medicaid Program and CHIP Core Set Reporting Proposed Rule September 8: EHR Association Letter of Support - Behavioral Health IT Now Act September 6: EHR Association Comments to CMS on the CY2023 Physician Fee Schedule NPRM June 17: EHR Association Comments to CMS on the FY2023 IPPS Proposed Rule June 6: EHR Association Comments on the OCR HITECH Act Request for Information May 31: EHR Association Comments to CMS on the Inpatient Rehabilitation Facility Prospective Payment System for FY23 and Updates to the IRF Quality Payment Reporting Program May 2: EHR Association Comments to ONC on SVAP April 28: EHR Association Comments to ONC on the Draft USCDI v3 March 31: EHR Association Comments on the White House OSTP Connected Health RFI March 25: EHR Association Comments to ONC on the ePrior Auth Request for Information March 11: EHR Association Letter on the Proposed Health Data Use and Privacy Commission Act March 11: EHR Association Comments to ASPR on National Health Security Strategy RFI February 28: EHR Association Comments to NIH on Genomic Data Sharing Policy RFI February 17: EHR Association Letter to Secretaries and Agency Heads on no Surprises Act January 31: EHR Association Signed on to Telehealth Pathway to Reform Letter to Congress
2021
November 29: EHR Association Comments to FDA on Real World Data Draft Guidance October 21: EHR Association Feedback on the TEF Comment Agreement Elements October 11: EHR Association Recommendations Letter on SVAP September 27: EHR Association Health Equity & Social Determinants of Health Congressional Briefing Slides September 27: EHR Association Health Equity & Social Determinants of Health Congressional Briefing Recording (passcode: H@R$UZ02) September 21: EHR Association Feedback on the Congressional SDOH Caucus RFI September 17: EHR Association Feedback on TEFCA QHIN Technical Framework September 14: EHR Association Feedback on the EHR Reporting Program Draft Developer- Reported Measures September 13: EHR Association Comments to CMS on the CY22 Physician Fee Schedule Proposed Rule July 26: Post-COVID Telehealth Priorities Group Letter June 28: EHR Association IPPS FY22 Comments June 15: EHR Association Hosts Congressional Briefing on Information Blocking, Public Health Modernization, and Safeguarding Health Data: View Recording June 15: EHR Association Hosts Congressional Briefing on Information Blocking, Public Health Modernization, and Safeguarding Health Data: View Slides and Panelist Bios May 13: EHR Association Written Testimony- HITAC Public Health Data Systems Hearing May 6: EHR Association Comments on the HIPAA Proposed Rule April 15: EHR Association Comments to ONC on the Draft USCDI Version 2 February 22: EHR Association Comments on HHS Teletracking COVID-19 Portal ICR February 16: 210216 Health IT Recommendations to Biden Administration on COVID-19 Vaccination Distribution and Administration February 1: EHR Association Comments to CMS on the Prior Authorization NPRM RFIs January 4: EHR Association Comments to HHS on the Prior Authorization and Patient Access NPRM
2020
December 1: EHR Association Letter to Senate on Patient Identification November 9: EHR Association Comments to ONC on the Standards Version Advancement Process November 9: EHR Association Comments to ONC on the Interoperability Standards Advisory November 2: EHR Association Comments to CMS on the COVID-19 CLIA IFC October 5: EHR Association Comments to CMS on the EPCS RFI October 1: EHR Association Comments on the Physician Fee Schedule NPRM September 4: EHR Association Comments to ONC on Patient Identity and Record Matching August 10: EHR Association Comments to ONC on the EHR Reporting Program Draft Voluntary user Reported Criteria July 30: EHR Association Telehealth Letter of Support - Senate July 30: EHR Association Telehealth Letter of Support - House July 30: EHR Association Comments to FDA Development of 21st Century Cures Act- Section 3060 RFI July 10: EHR Association Comments to CMS on the 2021 IPPS Proposed Rule June 23: EHR Association Hosts Congressional Briefing on Information Blocking: View Recording June 23: EHR Association Hosts Congressional Briefing on Information Blocking: View Summary, Slides, and Panelist Bios June 23: EHR Association Comments to the Office of Inspector General on Proposed Grants Contracts and Other Agreements June 22: EHR Association Comments to the DEA on e-Prescriptions for Controlled Substance Interim Final Rule June 18: EHR Association Hosts Congressional Briefing on COVID-19: View Recording June 18: EHR Association Hosts Congressional Briefing on COVID-19: View the Summary, Slides, and Panelist Bios March 13: EHR Association Comments on 2020-2025 Federal Health IT Strategic Plan January 29: EHR Association Response to CMS on Transparency in Coverage Proposed Rule
2019
December 20: EHR Association Response to FDA on Clinical Decision Support Software Draft Guidance December 20: EHR Association Response to CMS and OIG on the Anti-Kickback Statute and Physician Self-Referral Regulations December 16: EHR Association Response to Cures 2.0 Request for Information November 8: EHR Association Letter of Support for the CONNECT Act of 2019 October 25: EHR Association Comments to SAMSHA on Proposed 42 CFR pt. 2 Changes October 11: EHR Association Response to RFI for the Development of a CMS Action Plan to Prevent Opioid Addiction October 3: EHR Association Letter to ONC Regarding Additional Feedback to 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Proposed Rule September 27: EHR Association Comments to CMS' Revisions to Payment Policies Under the Physicians Fee Schedule September 23: EHR Association Comments to the ONC 2019 Interoperability Standards Advisory (ISA) August 28: EHR Association Letter to Senate Committee on Finance Regarding Prescription Drug Pricing Reduction Act August 27: EHR Association Joins Industry Letter to Senate Committee on Appropriations on Patient Identification August 20: EHR Association Response to Minnesota Department of Health RFI on a Connected Networks Approach to Health Information Exchange August 16: EHR Association Response to CMS' Secure Electronic Prior Authorization for Medicare Part D Proposed Rule August 12: EHR Association Response to CMS RFI: Reducing Administrative Burden to Put Patients Over Paperwork June 25: EHR Association Congressional Briefing Summary: 21st Century Cures Act: Interoperability, Information Blocking, and the Impacts on Healthcare June 24: EHR Association Comments to CMS on Hospital Inpatient Prospective Payment Systems June 17: EHR Association Comments to the ONC Trusted Exchange Framework Draft 2 June 3: EHR Association Response to ONC Proposed Rule on Interoperability Information Blocking and Certification Program June 3: EHR Association Response to CMS Proposed Rule on Interoperability and Patient Access May 30: EHR Association Response to FDA Proposed Framework for Artificial Intelligence and Machine Learning-Based SaMD March 26: EHR Association Response to Senator Warner's RFI on Advancing Security in the Healthcare Sector March 4: EHR Association Response to Senate HELP Committee RFI on Reducing Healthcare Costs March 4: EHR Association Letter to CMS Requesting Extension to Public Comment Period for the Interoperability and Patient Access Proposed Rule March 4: EHR Association Letter to ONC Requesting Extension to Public Comment Period for 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Proposed Rule February 9: EHR Association Letter to CMS Regarding Concerns and Recommendations for Promoting Interoperability Program February 8: EHR Association Response to OCR's Modifying HIPAA Rules to Improve Coordinated Care RFI January 30: EHR Association Letter to FDA on the Role of EHR in Helping to Combat the Opioid Crisis January 28: EHR Association Response to HHS Draft Strategy on Reducing Regulatory and Administrative Burden Relating to Use of Health IT and EHRs
2018
December 20: EHR Association Response to FDA on Clinical Decision Support Software Draft Guidance December 20: EHR Association Response to CDC National Test Collaborative RFI December 13: EHR Association Letter to ONC on Health IT Certification Program Guidance and Resources October 26: EHR Association Response to OIG on the Anti-Kickback Statute RFI October 17: EHR Association Response to 21 Century Cures Act EHR Reporting Program RFI October 10: EHR Association Comments to ONC on Certification Test Procedures and Test Data October 1: EHR Association Comments to ONC 2018 Interoperability Standards Advisory (ISA) September 10: EHR Association Comments to CMS' Medicare Program: Revisions to Payment Policies under Physician Fee Schedule August 17: EHR Association Response to CMS' Request for Information on Physician Self-Referral Law August 17: EHR Association Response to Health Care Innovation Caucus Request for Information July 19: EHR Association Comments to FDA on Developing a Software Precertification Program: A Working Model v0.2 July 18: EHR Association Letter of Support for the National Guidelines Clearinghouse June 28: EHR Association Response to FDA's Development of 21st Century Cures Act Section 3060 Required Report Request for Input June 22: EHR Association Comments to CMS on 2019 Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System (IPPS) June 20: EHR Association Letter of Support for Overdose Prevention and Patient Safety Act June 6: EHR Association Congressional Briefing: Maximizing Health IT in the Fight Against the Opioid Crisis May 31: EHR Association Letter to Congress Requesting Inclusion of Patient Identification and Matching Language to House FY19 Labor, Health and Human Services, and Education and Related Agencies (Labor-HHS) draft Appropriations Bill May 31: EHR Association Comments to FDA on Fostering Medical Innovation: A Plan for Digital Health Devices; Software Precertification Pilot Program May 25: EHR Association Response to CMMI Request for Information (RFI) on Direct Provider Contracting Models May 3: EHR Association Letter of Support for Improving Access to Behavioral Health IT Act February 20: EHR Association Comments to ONC on Trusted Exchange Framework and Common Agreement February 16: EHR Association Recommendations to Senate Committee on Finance Request on the Opioid Epidemic February 6: EHR Association Comments to FDA on Clinical and Patient Decision Support Software Draft Guidance February 6: EHR Association Comments to FDA on Changes to Existing Medical Software Policies January 10: EHR Association Comments to CMS' Medicare Prescription Drug Benefit Programs
2017
November 20: EHR Association Response to CMS: Innovation Center New Direction Request for Information (RFI) November 17: EHR Association Comments to ONC's 2018 Interoperability Standards Advisory (ISA) November 9: EHR Association Statement for the Record to Senate HELP Committee - Implementation of 21 Century Cures Act October 26: EHR Association Comments on HHS Draft Strategic Plan FY2018 - 2022 September 11: EHR Association Comments to CMS' Physician Fee Schedule Proposed Rule August 25: EHR Association Submission to Medicare Red Tape Relief Project August 23: EHR Association Comments to ONC's Trusted Exchange Framework & Common Agreement August 21: EHR Association Comments to CMS' 2018 Quality Payment Program Proposed Rule July 24: EHR Association Comments to ONC's Proposed Interoperability Standards Measurement Framework June 30: EHR Association Comments to CDS Coalition's Draft Industry Guidelines June 22: EHR Association Highlights from Congressional Briefing "Examining the Role of Health IT in Value-Based Care" January 26: EHR Association Letter to National Governors Association on "Getting the Right Information to the Right Health Care Providers at the Right Time: A Road Map for States to Improve Health Information Flow Between Providers." January 26: EHR Association Response to CDC RFI on Adherence to Clinical Guidelines & Information Flow
2016
December 19: EHR Association Response to CMS on MACRA Final Rule November 21: EHR Association Comments to ONC 2015 Edition Certification Test Procedures November 15: EHR Association Letter to Senate HELP Committee on Proposed Ratings System for Health IT October 27: EHR Association Response to CMS RFI on State Innovation Model Concepts October 24: EHR Association Comments to ONC 2017 Draft Interoperability Standards Advisory October 18: EHR Association Response to API Task Force Final Recommendations on Privacy & Security Considerations September 6: EHR Association Comments to CMS Physician Fee Schedule NPRM September 1: EHR Association Comments to CMS Hospital Outpatient Prospective Payment NPRM August: EHR Association Interoperability FAQs July 18: EHR Association Comments to FDA on the Role of EHR Data in Clinical Investigations July 6: EHR Association Statement to National Committee on Vital and Health Statistics on "Minimum Necessary" Standard June 27: EHR Association Submits Comments to CMS on MACRA/MIPS Proposed Rule June 7: EHR Association Sponsors Congressional Briefing in Washington D.C. and Publishes Fact Sheet on Interoperability June 3: EHR Association Responds to ONC's RFI on Measuring Interoperability May 2: EHR Association Submits Comments on the ONC Health IT Certification Program: Enhanced Oversight and Accountability NPRM April 29: EHR Association Submits Letter to API Task Force Regarding Privacy and Security Recommendations April 21: EHR Association Submits Comments on ONC's 2016 Interoperability Standards Advisory April 11: EHR Association Submits Comments on HHS' SAMHSA Substance Abuse Confidentiality Regulations Proposed Rule April 1: EHR Association Letter to ONC and CMS regarding the EHR Incentive Program for Stage 3 January 29: EHR Association Submits Letter to API Task Force Regarding Privacy and Security Recommendations
2015
December: EHR Association Testimony for HITPC Certified Technology Comparison Task Force December 15: EHR Association Submits Comments on CMS’ Meaningful Use, Stage 3 Proposed Rule November 30: EHR Association Responds to ONC’s Proposed 2015 Edition Certification Criteria November 17: EHR Association Responds to CMS’ RFI on new provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA): Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APMs) and physician-focused payment models (PFPMs) November 6: EHR Association Provides Insights to ONC on Interoperability Standards Advisory October 14: EHR Association Comments on ONC's Proposed Patient Safety Collaboratory September 8: EHR Association Comments on Physician Fee Schedule Proposed Rule July 1: EHR Association Interoperability FAQs June 15: EHR Association Responds to Proposed Modifications to the Meaningful Use Program May 22: EHR Association Chair Presents to Institute for eHealth Policy on Interoperability May 7: EHR Association Responds to ONC's Standards Advisory Proposal April 3: EHR Association Responds to ONC's 10 Year Interoperability Roadmap February 6: EHR Association Responds to the Federal Health IT Strategic Plan January: EHR Associations Interoperability Roadmap and Response to Jason Task Force
2014
October 21: EHR Association Responds to the PCAST Report, Big Data and Privacy: A Technological Perspective September 11: EHR Association Responds to ONC's Request for Input on the 10-Year Interoperability Roadmap September 2: EHR Association Response to CMS' Proposed Rule on Changes to the Physician Fee Schedule August 27: EHR Association Cypress Letter August 12: EHR Association Responds to Senate Finance Committee Request re Healthcare Data Sharing July 21: EHR Association Responds to House Committee on Energy and Commerce White Paper, "A Path to 21st Century Cures" July 10: EHR Association Responds to ONC and CMS on Proposed Rule to Add Flexibility to the 2014 Meaningful Use Program July 7: EHR Association Submits Response to FDASIA Report, A Proposed Strategy and Recommendations for a Risk-Based Framework July 3: EHR Association Responds to JASON Report on "A Robust Health Data Infrastructure" July 2: EHR Association Responds to Unexpected Changes to Meaningful Use FAQs from CMS June 30: EHR Association Comments on Proposed IPPS Rule to Align Quality Measure Programs May 7: EHR Association Testimony for ONC HIT Policy Committee Certification Hearing April 22: EHR Association Responds to ONC's Voluntary 2015 Edition EHR Certification Criteria; Interoperability Updates and Regulatory Improvements January 28: EHR Association Provides Guidance on MU2 Secure Transport January 16: EHR Association Comments on SAFER Guides
2013
November 22: EHR Association QRDA Letter November 12: EHR Association Responds to Congressional Proposal to Permanently Repeal the Sustainable Growth Rate (SGR) Formula Payment System November 6: EHR Association Responds to FDASIA Recommendations on Health IT Regulation September 5: EHR Association Responds to CMS Physician Fee Schedule Proposed Rule September 5: CQM Development Timelines June 30: EHR Association Responds to FDASIA RFC on the Development of a Risk-Based Regulatory Framework and Strategy for Health Information Technology June 25: EHR Association Responds to CMS IPPS Proposed Rule June 10: EHR Association Responds to Proposed Changes to Stark Anti-Kickback Regulations May 16: EHR Association Responds to Senators' White Paper, "Reboot: Re-examining the Strategies Needed to Successfully Adopt Health IT April 18: EHR Association Responses to RFI on Advancing Interoperability and Healthcare Information Exchange April 10: EHR Association Responds to Proposed EHR User Fee February 4: EHR Association Responds to ONC Health Information Technology Patient Safety Action & Surveillance Plan for Public Comment February 1: EHR Association Responds to the CMS RFI on Readiness for Electronic Quality Reporting January 14: EHR Association Responds to RFC Regarding the Stage 3 Definition of Meaningful Use of Electronic Health Records (EHRs)
2012
September 21: EHR Association Responds to the AHRQ RFI on Quality Measurement Enabled by Health IT July 31: EHR Association Letter on Meaningful Use, Stage 2 Timelines July 16: EHR Association Comments on the QDM and Style Guide June 20: EHR Association Responds to ONC Request for Information on NwHIN Governance May 3: EHR Association Responds to the ONC's Proposed Rule on EHR 2014 Edition Certification Criteria May 3: EHR Association Responds to the CMS' Proposed Rule on the EHR Incentive Program, Stage 2 March 8: EHR Association Responds to Health Affairs Study and New York Times Article on Health IT and Increased Physician Ordering February 21: The EHR Association Publishes Patient Safety Statement of Commitment January 20: EHR Association Offers Comments on MAP/CQM
2011
December 15: EHR Association Implementation Experience with NwHIN Exchange Specifications Shared with ONC Health IT Steering Committee November 9: EHR Association Comments on the NIST EUP October 13: EHR Association Response to FDA Draft Guidance for Mobile Medical Applications September 26: EHR Association Comments on the Health IT Standards Committee NwHIN Power Team Evaluation and Draft Recommendations September 23: EHR Association Comments on the ANPRM for Metadata August 1: EHR Association Comments on Accounting for Disclosures January 19: EHR Association Response to PCAST Report
2010
July 10: EHR Association Testimony to House Ways & Means Committee on Meaningful Use June 4: EHR Association Response to NHIN Direct "IHE Concrete Implementation" March 12: EHR Association Response to ONC HITECH Initial Set IFR March 12: EHR Association Response to CMS' Proposed Rule on Meaningful Use
2009
December 16: Position: Statement to NHIN Workgroup of the HIT Policy Committee October 27: EHR Association Response to HIT Standards Committee Implementation Work Group July 13: EHR Association Response to HIT Policy Committee Certification/Adoption Work Group June 26: EHR Association Response to HIT Policy Committee on Meaningful Use April 21: EHR Association Position Statement on ARRA Meaningful User & EHR Certification Criteria - Hospital April 14: EHR Association Position Statement on ARRA Meaningful User & EHR Certification Criteria - Eligible Professional (Ambulatory) January 7: EHR Association Position Statement on Privacy January 7: EHR Association Position Statement on National Health IT Leadership
2008
December 2: EHR Association Position Statement on Government Funded EHR October 17: EHR Association Position Statement on CMS Tamper Resistant Printed Prescriptions May: EHR Vendors Association Support National Standards to Promote/Adopt/Improve Interoperability In Electronic Health Records 2008: EHR Vendors Association CCHIT - HITSP Readiness Survey Results
2007
September 17: EHR Vendors Association Statement to OIM on ONC Standards Activities August 20: EHR Vendors Association Position Statement on CCHIT Use Cases July 20: EHR Vendors Association Position Statement to AHIC Use Case August 8: EHR Vendors Association Proposal on Inpatient – Ambulatory Connectivity for ONC/AHIC January 18: EHR Vendors Association Response to National Coordinator Health Information Technology (ONCHIT) Request for Information (RFI)
Code of Conduct (Version 1) As of July 1, 2017, Version 1 is no longer valid and cannot be referenced as current adoption. Health IT companies are encouraged to review and take steps to adopt Version 2.
July 11, 2013: EHR Developer Code of Conduct FAQ (Updated January 2017) July 11, 2013: EHR Developer Code of Conduct Implementation Guidance July 11, 2013: EHR Developer Code of Conduct Badge

Statements & Positions Archive

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Code of Conduct (Version 1)