Enabling a Healthier Future for Every Community

OCHIN regularly comments on proposed regulatory and federal guidelines to share our perspective as a health innovation organization. 

2018 Public Comments

Proposed Uniform Data System Changes for Calendar Year 2019

Published 10/9/18
OCHIN took the opportunity to advocate for common metrics between state and federal programs, reporting substance use treatment services performed by primary care providers, and extending telemedicine and virtual visits to those suffering from substance use disorder. We also made a number of specific comments on proposed changes.

Office of the National Coordinator 2018 Interoperability Standards Advisory

Published 10/1/18
OCHIN praised the format of the ISA but also made some recommendations on how to improve it. We advocated for reducing provider burden by promoting the exchange of healthcare information through national framework’s standards, such as Carequality or Commonwell, continuing adoption of 2015 or newer CEHRT, and standardization across all healthcare platforms.

Medicare Program: Proposed Changes to Hospital Outpatient Prospective Maybe and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Requests for Information on Promoting Interoperability and Electronic Health Care Information, Price Transparency, and Leveraging Authority for the Competitive Acquisition Program for Part B Drugs and Biologicals for a Potential CMS Innovation Center Model

Published 9/24/18
OCHIN expressed its support for assisting providers adopt 2015 or newer CEHRT through national standardization and funding, improving virtual care reimbursement rates, and reducing provider burden by promoting and incentivizing use of national frameworks such as Carequality or Commonwell.

Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019l Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program

Published 9/10/18
OCHIN provided comments on modernizing Medicare reimbursement for virtual care. We also expressed support of expanding virtual care, integrating PDMP into the electronic health record system, and incentivizing non-opioid alternatives to heal the opioid crisis.

Healthcare Innovation Caucus Request for Information

Published 8/7/18
OCHIN took the opportunity to express the great need for utilize technology to expand care for the safety net. Increasing virtual screening, e-consults, tele-counseling, and remote patient monitoring will increase access to specialist care, and improve both outcomes and costs. OCHIN also advocated for an increase in reimbursement rates for virtual care.

Request for Information on the HEALing Communities Study: Developing and Testing an Integrated Approach to Address the Opioid Crisis

Published 6/29/18
OCHIN made recommendations on research design, baseline data considerations, possible confounding variables and other threats to study validity, target metrics, and best approaches based on experience as a leader in clinical safety-net data.

Facilitation of Public-Private Dialogue to Increase Innovation and Investment in the Healthcare Sector

Published 6/1/18
OCHIN echoed the importance of the HHS proposal to create this workgroup and suggested the group place emphasis on the Medicaid Reimbursement structure for telehealth expansion and utilization. OCHIN recommended including clinics, public health entities, health data researcher organizations, health IT perspectives, Primary Care Associations and related state and federal actors.

Medicare Promoting Interoperability Program Call for Measures

Published 5/15/18
OCHIN suggested a measurement for closed loop referrals, another for reductions in ancillary orders with an increase in health information exchange (reduction in duplicated orders), and finally, a measure for interoperability between all healthcare sectors, including physical, mental, dental, and public health services.


Fore more information on OCHIN’s government affairs work, please contact:

Jennifer Stoll,
Vice President of Government Affairs