A driving force for health equity

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

2019 Public Comments

Comments on SAMSHA 4162-20 Confidentiality of Substance Use Disorder Patient Records

October 15, 2019
OCHIN applauds SAMHSA for their efforts to simplify and update 42 CFR Part 2, but suggested language to expand the Part 2 designation to further align Part 2 with HIPAA to allow for easier sharing of Part 2 data where a provider has a agreed to comply with Part 2 requirements.

Proposed Uniform Data System Changes for Calendar Year 2019

September 13, 2019
OCHIN took the opportunity to advocate for continued alignment to CMS eCQM specifications, expanding the PrEP measurement process, the collection of social determinants of health (SDH), and integrating the PDMP into the EHR.

Office of the National Coordinator 2019 Interoperability Standards Advisory

September 13, 2019
OCHIN praised a number of improvements on the ISA while also suggesting improving coordination between federal agencies for standards, using a qualitative approach for adoption level of standards, and creating vendor standards. We also advocated for ONC to start focusing funding on highly mature standards for FWHCs and small clinics.

Ohio Department of Medicaid Request for Information – Ohio Medicaid Managed Care Program Feedback from Individuals and Providers

July 31, 2019
OCHIN took the opportunity to respond to the Ohio Department of Medicaid to suggest they work with the Ohio Department of Transportation on their project to expand broadband infrastructure throughout the state, incentivize the adoption and onboarding of providers onto certified electronic health record technology with a focus on those left out of Meaningful Use, and to build their social service resource locators.

Ohio Department of Transportation Request for Information – Digital Infrastructure Assets and Strategy

July 8, 2019
OCHIN suggested Ohio use health care as the use case for broadband extension, with a focus on telehealth and virtual care by considering other states’ models, gaining stakeholder input, and understanding the impact of broadband connectivity on public health through improved economic prosperity.

In the Matter of Universal Service Contribution Methodology, WC Docket No. 06-122

July 1, 2019
The FCC proposed to cap the Universal Service Fund (USF) which is comprised of four programs providing funding assistance to extend broadband throughout the nation. OCHIN offered recommendations on how to improve efficiency of the program funding and administration.

FCC Connected Care Proposal - OCHIN Statement

June 28, 2019
OCHIN expressed support for Commissioner Carr’s and the Federal Communications Commission’s efforts to adopt the “Promoting Telehealth for Low-Income Consumers” Notice of Proposed Rulemaking (NPRM).

Trusted Exchange Framework and Common Agreement (TEFCA) Draft 2

Published 6/17/19
The Technical Exchange Framework and Common Agreement (TEFCA) Draft 2 is the last of three sets of comments which encourage and support interoperability on the national scale. The TEFCA Draft 2 is a revision of TEFCA Draft 1, also commented on by OCHIN, that seeks to establish a national Network of Networks to improve health information exchange.

Medicare and Medicaid Programs: Patient Protection and Affordable Care Act; Interoperability and Patient Access for Medicare Advantage Organization and Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans in the Federally-facilitated Exchanges and Health Care Providers

Published 5/31/19
CMS’s Interoperability Rule is the second of three sets of comments which encourage and support interoperability on a national scale. This rule is a proposal in an ongoing interoperability rulemaking process by CMS, which OCHIN responded to last year and can be found below.

21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program

Published 5/20/19
ONC’s Information Blocking Rule is the first of three sets of comments which encourage and support interoperability on a national scale. The Information Blocking Rule is an evolving provision of The 21st Century Cures Act, designed to innovate care delivery by embracing advances in technology while overcoming emerging barriers.

Request for Information on Modifying HIPAA Rules to Improve Coordinated Care

Published 2/12/19
OCHIN commented in response to the request to address the Office for Civil Rights (OCR) Request for Information on Modifying HIPAA Rules to Improve Coordinated Care, and provided recommendations on how the OCR can modify HIPAA rules to remove regulatory burdens while increasing the efficiency of care coordination.

Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs

Published 1/22/19
OCHIN commented in response to the request to address the Office of the National Coordinator’s (ONC’s) Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs. We advocated for creating clear standards for the exchange of healthcare information, aligning national standards for provider reporting metrics for Medicaid and Medicare, supporting the use of CCDA as the standard basis for health information exchange (HIE), applying national standards for HIE, the Prescription Drug Monitoring Program (PDMP), and Social Risk Factors (SRF, or social determinants of health: SDH), and aligning 42 CFR Part 2 with HIPAA.

2018 Public Comments

Medicaid and Medicare Efficiency, Transparency, and Burden Reduction

Published 11/19/18
OCHIN commented in support of reducing increasing transparency and reducing burden using a number of methods. We advocated for using MAT and other funding to onboard behavioral health providers, standardizing telehealth payer structure, continuing adoption of 2015 or greater CEHRT and enabling national framework’s standards, integrating external capabilities into the EHR such as PDMP, and finally, 42 CFR Part 2 reformation.

IMPACT ACT Study to Integrate Social Risk Factors

Published 11/16/18
OCHIN, a leader in social determinant of health research took the opportunity to translate our learnings around social determinants into recommendations for ASPE. We advocated for standardizing EHRs and SDH definitions, incorporating extensive training to prepare for social risk factor collection, ensuring clinics compile robust community resources for addressing social issues, and the need for clinics to gain access to their claims data for a successful move towards value-based care.

California Telehealth Policy Manual Updates

Published 11/15/18
OCHIN submitted comments echoing those of the California Telehealth Policy Coalition in response to updates to the California Telehealth Policy Manual. We advocated for funding to expand broadband connectivity and telehealth projects, standardization of payments and networks for eConsult and telehealth services, allowing non-CA based providers to virtually serve CA patients, and alignment of eConsult codes.

ONC Request for Information Regarding 21st Century Cures Act Electronic Health Record Reporting Program

Published 10/17/18
OCHIN submitted comments about implementation of the 21st Century Cures Act requirements, which addresses interoperability and data sharing in the EMR. We advocated for reducing provider burden by promoting the exchange of healthcare information through national framework’s standards, continued adoption of 2015 or newer Certified electronic health record technology (CEHRT), the use of national health information exchange standards and metrics, regardless of health platform, and 42 CFR Part 2 reform to ensure needed data sharing and care coordination to address the opioid crisis.

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,
Executive Vice President of Government Relations and Public Affairs