Federal Public Comments

OCHIN strongly supports the Office of the National Coordinator of Health Information Technology’s (ONC) efforts to drive interoperability through national standards, which are essential to addressing structural inequality in health care and informing data-drive responses to public health emergencies, and offers recommendations about the proposed standards in the U.S. Core Draft of Interoperability version 2.

The CONNECT for Health Act of 2021 Expanding Medicare Telehealth Coverage

April 29, 2021

OCHIN urges swift action to move this legislation forward to increase equitable access to health care and to strengthen public health readiness while providing a critical bridge to value-based care models that will allow providers to bend the cost curve.

Request to Rescind 340B Drug Pricing “Pass-Through” Rule Destabilizing Community Clinics

March 11, 2021

SAMHSA Waiver X Sign On Letter

February 5, 2021

OCHIN and several other community-based clinics and provider organizations respectfully urge that the Administration improve access to opioid use disorder treatment.

COVID-19 Telehealth Program Application Evaluation Metrics

January 19, 2021

On behalf of OCHIN, I appreciate the opportunity to provide feedback on the COVID-19 Telehealth Program Application Evaluation Metrics. We truly appreciate the FCC’s leadership in supporting underserved communities throughout the country.

Information Concerning Effective and Innovative Approaches/Best Practices in Health Care in Response to the COVID-19 Pandemic

January 11, 2021

OCHIN appreciates the opportunity to respond to the request for information concerning effective and innovative approaches/best practices in health care in response to the COVID-19 pandemic.

2020 Public Comments

HHS Securing Updated and Necessary Statutory Evaluations

December 4, 2020

OCHIN appreciates the opportunity to provide comments on the Department of Health and Human Services (HHS) proposed rule, “Securing Updated and Necessary Statutory Evaluations Timely.”

OARs 410-146-0085, 410-147-0120 Rule Language to Clarify Telemedicine Encounters for IHS/FQHC/RHC Providers

August 21, 2020

OCHIN commends the Oregon Health Authority for its swift action to support patients and providers through virtual care during this pandemic, and strongly support efforts to embrace telehealth flexibilities permanently.

Regulatory Relief to Support Economic Recovery RFI

December 20, 2020

OCHIN responds to a Request for Information concerning Regulatory Relief to Support Economic Recovery, focusing on the need to permanently expand telehealth and virtual services coverage and payment flexibilities in HHS' federal healthcare programs.

ONC Information Blocking Rule Extension to 2021

November 13, 2020

OCHIN applauds the U.S. Department of Health and Human Services’ (HHS) Office of the National Coordinator for Health IT (ONC) Interim Final Rule with Comment, which extends the compliance deadline for information sharing initially established in the 21st Century Cures Act: Interoperability, Information Blocking and the ONC Health IT Certification Program Final Rule.

Including Social Determinants of Health in the U.S Core Data for Interoperability

December 9, 2020

CMS Physician Fee Schedule 2021

September 23, 2020

OCHIN is grateful for the opportunity to comment on the Centers for Medicare & Medicaid Services (CMS) proposed rule on the revisions to Medicare payment policies under the Physician Fee Schedule.

HHS Long-Term Monitoring of Health Care System Resilience

July 8, 2020

OCHIN takes the opportunity to provide thoughtful responses to a Request for Information by HHS regarding health care system resilience.

OIG CMP and Information Blocking

June 23, 2020

OCHIN took the opportunity to reiterate concerns regarding the information blocking rule and inequities which may result from applying penalties without proper considerations.

DEA Electronic Prescription Controlled Substances

June 22, 2020

OCHIN responds to the DEA regarding proofing requirements for participation in EPCS.

Maternal and Infant Health Care in Rural Communities

May 31, 2020

OCHIN takes the opportunity to respond to a request for information on maternal and infant health in rural communities, with a specific focus on current pressures on FQHCs and RHCs to deliver long term care to these patients.

Behavioral Health Integration

May 30, 2020

OCHIN applauds the Behavioral Health Integration Task Force for their extensive work to improve behavioral health bi-directional integration, and took the opportunity to make a number of thoughtful suggestions on how to improve behavioral health for safety net patients nationally.

OCHIN Coronavirus Request to Congress

March 17, 2020

2020-2025 Federal Health IT Strategic Plan

April 3, 2020

OCHIN responds to the proposed 2020-2025 HIT Strategic Plan, urging that we learn from COVID-19 prior to implementing changes to our HIT system.

2019 Public Comments

CMS Stark Law

December 25, 2019

OCHIN responds to proposals from CMS to Stark Law and the impact to rural and safety net providers.

OIG Anti-Kickback Statute

December 25, 2019

OCHIN responds to proposals from OIG to the Anti-Kickback Statute and the impact to rural and safety net providers.

Rural and Underserved Communities RFI

November 29, 2020

OCHIN applauds the Ways and Means Committee for their efforts and work to improve care for rural patients and provides thoughtful responses to the questions they pose.

Substance Use Disorder RFI

November 1, 2020

OCHIN applauds substance use disorder (SUD) reforms and suggests steps to further improve SUD treatment for patients.

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.

CMS Reducing Administrative Burden

August 12, 2020

OCHIN responds to a request for information from CMS to reduce provider burden and administrative burnout.

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

June 17, 2019
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

May 31, 2019
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

May 16, 2019
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

February 12, 2019
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

January 22, 2019
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.

Medicaid and Medicare Efficiency, Transparency, and Burden Reduction

November 19, 2018
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

November 16, 2018
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

November 15, 2018
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

October 17, 2018
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

October 9, 2018
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

October 1, 2018
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

September 24, 2018
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

September 10, 2018
OCHIN provided comments on modernizing Medicare reimbursement for virtual care. We also expressed support for 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

August 7, 2018
OCHIN took the opportunity to express the great need to 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

June 29, 2018
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

June 1, 2018
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

May 5, 2018
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.

Medicare Program: Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2019 Rates Proposed Quality Reporting Requirements for Specific Providers; Proposed Medicare and Medicaid Electronic Health Record Incentive Programs

May 7, 2018
OCHIN used this opportunity to comment on the need to align state and federal measures, employ the national interoperability framework, and incorporate the PDMP into the EHR.