Public Policy Positions

2018-09-10
In response to the CMS CY2019 Physician Fee Schedule NPRM, AMIA applauded federal officials for aligning physician and hospital EHR requirements and advancing policies that further incentivize the adoption of health IT for patient care. AMIA also supported CMS efforts to reduce documentation burden...
2018-08-31
AMIA sent a set of recommendations to the federal government in late July, commenting on its Draft Federal Data Strategy. The nation’s health informatics professionals largely supported the Strategy, identifying ways it could help federal agencies improve data sharing and data availability for...
2018-08-06
The following statement was released today by Douglas B. Fridsma, MD, PhD, FACP, FACMI, regarding a letter to ONC about information blocking: Information blocking is the absence of interoperability, and there are numerous reasons why information may not flow as intended. Some of these reasons are...
2018-07-11
In response to an FDA request for input, AMIA developed a preliminary review of relevant research into the specific benefits and risks to health associated with software functions that the 21st Century Cures Act excluded from the definition of medical device. While some health IT applications to...
2018-07-11
In response to an HHS request for information on the creation of a new Healthcare Sector Innovation and Investment Workgroup, AMIA strongly recommended the inclusion of representatives of the health informatics community. Additionally, AMIA called for HHS to orient the Workgroup towards innovating...
2018-06-25
In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the American Medical Informatics Association (AMIA) applauded federal officials for balancing burden reduction provisions with a need to continue making progress on health IT adoption and use.
2018-04-03
In comments submitted yesterday, the American Medical Informatics Association (AMIA) called on the National Institutes of Health (NIH) to declare that all data generated through its grants align with FAIR data principles. It is not enough that the NIH commit to FAIR data principles, the nation’s...
2018-03-19
In comments submitted to HHS March 19, 2018, AMIA recommended that HHS proceed swiftly with implementation of revisions to the Common Rule, known as the 2018 Requirements. AMIA recommended that 2018 Requirements be made effective July 19, 2018 and that the compliance date be set as January 19, 2019...
2018-02-06
In comments submitted to the Food & Drug Administration (FDA) today, the American Medical Informatics Association (AMIA) said new draft guidance is well-timed to initiate a broad discussion over the future of clinical decision support (CDS) and patient decision support (PDS) software.
2017-11-28
In comments submitted to Office of the National Coordinator for Health Information Technology (ONC), the American Medical Informatics Association (AMIA) called on the federal government to update and enhance the Nationwide Interoperability Roadmap. The nation’s experts in health informatics also...
2017-11-21
In response to a CMS Innovation Center request for information (RFI) on its potential new direction, AMIA offered several suggestions focusing on the interdependency of payment and delivery reforms, supported by health IT and health informatics. AMIA suggested additional guiding principles with...
2017-11-02
In response to a request for information (RFI) from the National Library of Medicine (NLM), AMIA detailed numerous key challenges and opportunities for data science in health and biomedicine. AMIA further provided policy and research ideas in support of the NLM fulfilling a 2015 Advisory Committee...
2017-11-02
AMIA provided comments to a VA proposed rule that would allow its providers to furnish telehealth services, regardless of the state or location where they or the beneficiary is physically located. AMIA supported the proposal, while emphasizing that any telehealth applications use nationally...
2017-09-11
Today, AMIA responded to a CMS Proposed Rule on the CY 2018 Physician Fee Schedule. AMIA supported many of the proposals, including a proposal to begin the Appropriate Use Criteria Program in 2019 and proposed changes to E/M documentation guidelines. 
2017-08-24
In comments submitted August 24, AMIA submitted comments to ONC regarding the development of a Trusted Exchange Framework and Common Agreement as required by the 21st Century Cures Act. AMIA recommended ONC look to use the Framework to provide a floor upon which existing networks – and new networks...
2017-08-21
Today, AMIA responded to a CMS Proposed Rule on Year 2 of the Quality Payment Program. AMIA supported many of the new flexibilities offer to eligible clinicians to participate in MIPS or advanced alternative payment models. The organization also urged CMS to require 2015 Edition CEHRT beginning in...
2017-07-25
AMIA submitted comments supporting ONC’s draft framework, recommending a measurement approach that focuses on the clinician and patient experience. AMIA also underscored the need to have the benefits of measurement outweigh the costs, and urged federal officials to provide sufficient support to...
2017-07-12
In comments submitted to the Networking and Information Technology Research and Development (NITRD) Program, the nation’s leading biomedical and health informaticians applauded federal officials for developing a draft strategic framework for health IT research and development (R&D). AMIA...
2017-06-13
In comments to CMS, AMIA supported proposals to reduce the number of required quality measures and new proposed reporting period flexibilities, while also recommending additional such flexibilities for the 2018 Hospital IQR Program and the Medicare and Medicaid EHR Incentive Programs. AMIA...
2017-05-24
In comments submitted to the Federal Communications Commission, AMIA recommended FCC view broadband access as a social determinant of health and pursue policies that enable patients to participate in the fast-changing mobile health ecosystem.  AMIA also recommended several potential areas of...
2017-03-17
President Trump released his FY 2018 Budget Blueprint March 17, 2017, beginning a conversation with Congress on how to fund federal policies and programs.  This budget outlines, at a high level, which policies and programs this Administration prioritizes, and it describes the kind of country this...
2017-01-31
In comments submitted to the National Library of Medicine, AMIA said members envision a future where NLM leads the medical and research enterprise in demonstrating how real-world and “big” health data can be leveraged to develop new concepts of human disease, design novel therapies, and train...
2017-01-31
In comments submitted to the Centers for Disease Control and Prevention, AMIA recommended CDC pursue activities with the notion of CDS-as-a-Service as the conceptual goal.  CDC must ensure that a coordinated strategy presents stakeholders with a unified vision for how public health CDS can be...
2017-01-24
In comments submitted to PCORI, AMIA voiced strong support for its draft Data Sharing Policy for awardees.  AMIA recommended that suggested that PCORI consider requiring a preliminary data sharing plan as part of award applications, and earmarking specified amounts of grant funding for data...
2017-01-18
In comments submitted to the NIH, AMIA called for change to its Data Sharing policy in order to ensure that research data can be systematically and strategically collected, managed and shared.  Specifically, AMIA recommended that Data Sharing Plans be subject to peer-review and made scorable...
2016-11-02
In comments submitted to the FDA, AMIA voiced supported for several aspects of MDUFA IV meant to enhance use of consensus standards; develop patient engagement strategies and improve the science of patient input; utilize real world evidence (RWE) to improve regulatory decision-making; and...
2016-10-25
In comments submitted to the FDA, AMIA supported the use of real-world data and real-world evidence to support regulatory decision-making for medical devices.
2016-10-06
In comments submitted to the FDA, AMIA said it supports FDA’s efforts to develop modern, flexible and adaptive regulatory approaches to the oversight of NGS-based tests as part of the Precision Medicine Initiative (PMI).  This support notwithstanding, AMIA noted a lack of standards – for ontologies...
2016-10-05
In comments submitted September 29, AMIA recommend several ways the NIH could assess the value of biomedical digital repositories and knowledgebases.  The metrics span categories related to "utilization" and "impact" to "service quality" and "governance."  AMIA recommended another category be...
2016-09-27
In conjunction with HIMSS and 36 other organizations, AMIA submitted recommendations on how the Office of Management & Budget should update the Standard Occupational Classification codes, which help Federal statistical agencies understand and forecast national data on occupations. The groups...
2016-09-06
In comments submitted to CMS, AMIA recommend CMS proceed with proposals for a 90-day reporting period for hospitals in 2016, and it supported policies that are meant to align requirements for hospitals participating in MU with requirements for clinicians participating in MIPS.
2016-09-06
In comments submitted to CMS, AMIA supported continued policymaking to implement the Medicare AUC Program as part of the 2017 Physician Fee Schedule. The organization strongly recommended CMS target a 2019 implementation deadline, rather than the proposed 2018 start.
2016-08-16
In conjunction with a public meeting held by the FDA August 15, 2016, AMIA submitted public comments supporting the direction of the its Prescription Drug User Fee Agreement Commitment Letter.  Specifically, AMIA supports FDA’s work to utilize Real World Evidence in regulatory decision-making,...
2016-07-18
On July 18, 2016, AMIA submitted comments to FDA regarding their draft guidance to industry on using EHR data in clinical investigations.  AMIA was supportive of the guidance, but challenged the assertion that EHR data was readily usable for prospective randomized controlled trials.
2016-06-27
On June 27, 2016 AMIA submitted comments to CMS regarding proposed policies related to the new Medicare Quality Payments Program, which replaces the Sustainable Growth Rate and reforms how nearly 1.3 million clinicians are paid through Medicare.  AMIA described a set of principles and...
2016-05-24
On May 23, 2016, AMIA submitted comments to the Office of the National Coordinator recommending they develop a patient-centric approach to measuring nationwide health IT interoperability.  As part of this recommendation, AMIA described a new methodology and approach to measuring interoperability...
2016-05-02
On April 27, 2016, AMIA submitted comments to the Office of the National Coordinator supporting their proposed authority to conduct direct review of certified health IT products.  AMIA said that reviews should be limited to instances when health IT posed a potential or real threat to patient safety...
2016-04-06
On April 6, 2016, AMIA called proposed revisions to substance use disorder (SUD) regulations, also known as 42 CFR Part 2, well-intentioned, but ultimately insufficient. AMIA urged the Department of Health and Human Services (HHS) to lead a national effort to develop technical standards that would...
2016-02-29
On January 26, 2016, AMIA submitted a letter of support for the Office of the National Coordinator for Health Information Technology (ONC) “Private Sector Interoperability Commitments Pledge,” which seeks to bolster interoperability in healthcare by enabling consumer access to their data, improving...
2016-02-01
On February 1, 2016, AMIA submitted comments to the Centers for Medicare and Medicaid Services making several recommendations of how to improve quality measurement in an electronic environment.  The group called for an overhaul to the current process, while looking to specialty societies for expert...
2016-01-08
On January 8, 2016, AMIA submitted comments to the National Center for Advancing Translational Sciences (NCATS) on priority areas the Center should consider when developing its strategic plan.  AMIA believes NCATS should focus on (1) developing ways to measure and convey how their programs impact...
2016-01-06
On January 6, 2016 AMIA submitted comments to HHS recommending ways to improve the Federal Policy for the Protection of Human Subjects, also known as the Common Rule.  AMIA support many of the updates, and believes they will better enable a learning health system over current policies.
2015-12-14
On December 14, AMIA submitted comments to CMS regarding the need to redesign Meaningful Use (MU) in the face of changing reimbursement models.  Specifically, AMIA asked regulators to change MU requirements to better align with programs required by the Medicare Access and CHIP Reauthorization Act (...
2015-06-09
On June 10, 2015 Dr. Thomas H. Payne, AMIA Board Chair-elect provided testimony to the Senate Health Education Labor & Pensions (HELP) Committee, identifying near-term actions Congress should take to improve health IT interoperability and promote health information exchange.  Dr. Payne’s...
2015-05-29
On behalf of the American Medical Informatics Association (AMIA), I am pleased to submit these comments in response to the above-referenced proposed rule. AMIA is the professional home for biomedical and health informatics and is dedicated to the development and application of informatics in...
2015-05-29
On behalf of the American Medical Informatics Association (AMIA), I am pleased to submit these comments in response to the above-referenced proposed rule. AMIA is the professional home for biomedical and health informatics and is dedicated to the development and application of informatics in...
2013-06-27
Food and Drug Administration Safety and Innovation Act (FDASIA): Request for Comments (RFC) on the Development of a Risk-Based Regulatory Framework and Strategy for Health Information Technology
2013-04-22
Submitted via: http://www.regulations.gov. Dear Ms. Tavenner, On behalf of AMIA (American Medical Informatics Association), I am pleased to submit these comments in response to the above-referenced request for information. AMIA is the professional home for biomedical and health informatics and is...
2013-02-04
Re: ONC’s Request for Comments (RFC) about the Proposed Health IT Patient Safety Action and Surveillance Plan Dear Dr. Mostashari: On behalf of AMIA (American Medical Informatics Association), I am pleased to submit these comments in response to the above-referenced request for comments. AMIA is...
2012-09-21
Dear Ms. Roper, On behalf of the American Medical Informatics Association (AMIA), I am pleased to submit these comments in response to the above-referenced request for information (RFI). AMIA thanks the Department of Health and Human Services (the Department) and the Agency for Health Care...
2012-09-07
Dear Dr. Buehler, On behalf of AMIA (the American Medical Informatics Association), I am pleased to submit these comments in response to the above-referenced request for comments. AMIA thanks the Department of Health and Human Services and the Centers for Disease Control and Prevention (CDC) Public...
2012-08-10
The draft plan establishes PHSIPO's vision, identifies key priorities, and defines strategies to advance the science and practice of public health surveillance and informatics.
2012-07-20
The Patient Safety and Quality Improvement Act of 2005 (Patient Safety Act), Public Law 109–41,42 U.S.C. 299b–21–b–26, provides for the formation of Patient Safety Organizations (PSOs), which collect, aggregate, and analyze confidential information regarding the quality and safety of health care...
2012-07-16
The Alliance for Nursing Informatics (ANI) submit ted a letter of support for the comments developed by the AMIA Nursing Informatics (NI) Working Group (NIWG) to the National Quality Forum (NQF) on the Quality Data Model (QDM).
2012-07-10
Quality measurement is a critical element of the strategy to improve the quality of care delivered in the U.S. health care system. Until recently, quality measurement relied almost exclusively on the use of electronic claims data, manual chart abstraction, and patient surveys. However, there has...
2012-06-29
Dear Mr. Posnack: On behalf of AMIA (the American Medical Informatics Association), I am pleased to submit these comments in response to the above-referenced request for information (RFI). AMIA is the professional home for biomedical and health informatics and is dedicated to the development and...
2012-05-17
Re: 45 CFR Part 162 [CMS–0040–P] RIN 0938–AQ13Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for ICD–10–CM and ICD–10–PCS Medical Data Code Sets
2012-05-07
The Honorable Kathleen Sebelius, Secretary of Health and Human Services U.S. Department of Health and Human Services 200 Independence Ave, SW Washington, DC Marilyn Tavenner, Acting Administrator and Chief Operating Officer Centers for Medicare and Medicaid Services 7500 Security Boulevard...
2012-05-07
Farzad Mostashari, MD Office of the National Coordinator Hubert H. Humphrey Building, Suite 729D, 200 Independence Ave. SW. Washington, DC 20201 Re: Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology, 2014...
2012-03-16
AMIA and the NIWG submitted comments in response to the Patient-Centered Outcomes Research Institute’s (PCORI’s) request for comments about its draft National Priorities for Research and Research Agenda. PCORI was created to fund research that will give patients, caregivers, and clinicians more...
2011-11-10
AMIA acknowledged NIST’s efforts to highlight the importance of usability testing for electronic health records (EHRs) through its issuance of the proposed guidance. AMIA expressed concerns about several aspects of the draft guidance including the following: a limited and narrow identification of...
2011-11-07
AMIA and its Nursing Informatics Working Group once again provided input to the National Quality Forum (NQF) during an open comment period to solicit input on NQF's Quality Data Model (QDM). In its comments, AMIA recognized the importance of having an information model that clearly defines concepts...
2011-10-25
This week AMIA submitted comments to the Department of Health and Human Services (HHS) in response to the a request for comments regarding Human Subject Research Protections: Enhancing Protections for Research Subjects and Reducing Burden, Delay, and Ambiguity for Investigators (aka "the Common...
2011-10-19
AMIA recently issued comments in response to a U.S. Food and Drug Administration (FDA) draft guidance on mobile medical applications. In the comments, AMIA president Ted Shortliffe noted, among other things, the need for additional clarification, definitions, terms, and terminology in the guidance...
2011-09-13
In response to the U.S. Food and Drug Administration (FDA) invitation AMIA participated in a public workshop on the FDA’s Draft Guidance on mobile medical applications. AMIA, the association for informatics professionals, made a presentation and participated in panel discussions that advised the...
2011-08-01
AMIA has commented on a recent HHS notice of proposed rulemaking (NPRM) to modify the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule's standard for accounting of disclosures of protected health information. The purpose of the modifications spelled out in the NPRM...
2011-06-06
AMIA submitted comments today on the proposed rule from the Centers for Medicare and Medicaid Services (CMS) on the Medicare Shared Savings Program: Accountable Care Organizations (ACOs). In the comments, AMIA president Ted Shortliffe asserts that ACOs, especially as enabled by the science of...
2011-05-26
Today, AMIA and its Nursing Informatics Working Group provided input to National Quality Forum (NQF) during an open comment period to solicit input on NQF's Quality Data Model (QDM). The QDM provides a way to describe clinical concepts in a standardized format so that those monitoring clinical...
2011-05-06
AMIA has weighed in on the Federal Health IT Strategic Plan in response to the HHS Office of the National Coordinator’s (ONC) call for comments on the overarching strategy for realizing health IT goals set forth by the U.S. Congress and the Administration. AMIA states in its comments to ONC that...
2011-04-01
Dear eMeasure Format Review Panel: On behalf of AMIA (the American Medical Informatics Association), we are pleased to submit these comments to help inform your important discussions. AMIA is an unbiased, authoritative source within the informatics community and the healthcare industry. AMIA and...
2011-03-17
AMIA submitted comments recently to the National Institute of Nursing Research (NINR) in response to their request for public comments on the latest draft of the Institute's strategic plan. The association's comments were informed by AMIA's Nursing Informatics Working Group (NIWG), which promotes...
2011-03-07
Re: Request for Information Regarding the Effectiveness of Federal Agency Participation in Standardization in Select Technology Sectors for the National Science and Technology Council‘s Sub-Committee on Standardization. Dear Dr. Gallagher: On behalf of AMIA, I am pleased to submit these comments...
2011-02-26
Dear Dr. Seidman: On behalf of AMIA (the American Medical Informatics Association), I am pleased to submit these comments in response to the above-referenced request for comment (RFC). AMIA is the professional home for biomedical and health informatics and is dedicated to the development and...
2011-01-19
Re: Request for Information Regarding the President’s Council of Advisors on Science and Technology (PCAST) Report Entitled "Realizing the Full Potential of Health Information Technology to Improve Healthcare for Americans: The Path Forward" Dear Mr. Posnack, On behalf of AMIA, I am pleased to...
2010-12-10
AMIA comments to ONC on consumer’s privacy and security of Personal Health Records. AMIA discusses the benefits and risks to consumers of PHRs and other points.
2010-11-23
AMIA submitted comments to HHS on the Common Format, Device or Medical/Surgical Supply, including HIT Devices. The comments address patient safety data collections and event reporting. Failures with HIT devices are different from those associated with other devices and warrant a distinct form and...
2010-11-12
The current commercial health information technology (IT) arena encompasses a number of competing firms that provide electronic health applications to hospitals, clinical practices, and other healthcare-related entities. Such applications collect, store, and analyze patient information. Some...
2010-09-13
AMIA comments on the HHS NPRM to modify HIPPA Privacy, Security and Enforcement Rules under the Health Information Technology for Economic and Clinical Act (HITECH) published in the Federal Register on July 14, 2010. The discussion focuses mainly on protecting the PHI of consumers by the way of...
2010-05-29
AMIA comments to DEA on E-Prescribing Controlled Substances which would revise the Comprehensive Drug Abuse Prevention and Control Act of 1970 (Controlled Substances Act, or CSA) and the related regulations to allow healthcare providers to write prescriptions for controlled substances...
2010-05-10
AMIA comments on the proposed establishment of the Certification Programs for health information technology (HIT). AMIA agrees with the distinction between “testing” and “certification,” and support the use of the International Organization for Standard (ISO) and the International Electrotechnical...
2010-03-15
AMIA offers comments to ONC on Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology. AMIA finds absence of detail in the certification criteria and to include directions for testing will ensure...
2010-03-10
AMIA comments on the proposed rule which implements the initial stage of incentive funding for meaningful use (MU) of certified EHR technology. AMIA strongly believes that three principles are essential to achieving meaningful use of certified EHR technology: 1) we must invest in people, as well as...
2010-02-25
AMIA’s testimony to the HIT Policy Committee, Adoption/Certification Workgroup, discusses potential unintended consequences of health information technology (HIT) and HIT policy, as well as effective options for addressing them. AMIA and its task force offer several recommendations that involve...
2010-02-10
AMIA NIWG submits statement to the Institute of Medicine (IOM) and the Robert Wood Johnson Foundation Initiative on the future of nursing. NIWG recognizes the importance of increasing the nursing workforce and to prepare them to meet the educational challenges of implementing HIT on a grand scale....
2009-12-24
AMIA comments on the interim final rule, which amends the enforcement regulations promulgated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to conform to the revisions made pursuant to the Health Information Technology for Economic and Clinical Health Act (HITECH)...
2009-12-04
AMIA comments on the proposed rule to the Genetic Information Nondiscrimination Act of 2008 (GINA). AMIA supports the inclusion in the HIPAA Privacy Rule to prohibit against the use of genetic information for underwriting purposes. Covered entities (CE) would use genetic information only to benefit...
2009-10-22
AMIA comments on the Breach Notification for Unsecured Protected Health Information Interim final rule. AMIA supports ARRA’s definition of breach but offers suggestions for amendment. The comment also discusses the kinds of triggers the notification obligation CEs have to determine in order to...
2009-05-20
AMIA comments on the “Guidance Specifying the Technologies and Methodologies That Render Protected Health Information Unusable, Unreadable, or Indecipherable to Unauthorized Individuals for Purposes of the Breach Notification Requirements under the American Recovery and Reinvestment Act of 2009....
2008-01-01
AMIA and AHIMA advocate empowering individuals to manage their healthcare through the use of a personal health record (PHR). The PHR is a tool for collecting, tracking and sharing important, up-to-date information about an individual’s health or the health of someone in their care. Using a PHR will...
2008-01-01
The American Medical Informatics Association (AMIA) and the American Health Information Management Association (AHIMA) have a long history of working to protect the confidentiality of individuals’ health information and to promote fair information practices. Public confidence that privacy will be...
2008-01-01
Summary Position on Adoption of ICD-10 (pdf)- a joint statement with the American Health Information Management Association (AHIMA).