October 17, 2018: MGMA comments on ONC RFI on the CURES Act

October 17, 2018   
 
Don Rucker, MD
National Coordinator
Office of the National Coordinator for Health Information Technology
Department of Health and Human Services  
200 Independence Avenue, SW  
Washington, DC 20201  
 

RE: Request for Information Regarding the 21st Century Cures Act Electronic Health Record Reporting Program 
 
Dear Dr. Rucker:  
 
The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the request for information entitled, “Information Regarding the 21st Century Cures Act Electronic Health Record Reporting Program,” published on August 24, 2018. We believe this requirement of the Cures Act has the potential of significantly impacting the ability of physician  practices to acquire the health information technology (HIT) that best meets their clinical and administrative needs.  
 
MGMA is the premier association for professionals who lead medical practice. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures and specialties that deliver almost half of the healthcare in the United States. 
 
An increasing number of physician practices are acquiring certified health IT. The development of effective tools that assist practices to identify the most appropriate products that best meets an organization’s clinical and administrative needs will simplify this complex purchasing decision. Further, making the best decision for the practice will lessen the chance that the practice will be forced to undergo a costly and burdensome “rip and replace” process when their current product proves less than adequate.   
 
For practices, choosing the right EHR typically requires a certain level of technical expertise, an understanding of the functionalities necessary for quality improvement and value-based payment, and familiarity with legal and regulatory compliance requirements at both the state and federal levels. There are, however, few tools that currently provide practices comparative information on certified health IT. The ones that are available tend to be costly and unreliable. If implemented appropriately, a resource that offers practices the ability to compare and contrast EHRs on the basis of usability, interoperability, security, cost and other criteria, in addition to functionality, would not only be helpful to the practice as they shop between vendors, but could also incentivize software developers to compete for market share on these newly-measurable factors. 

Key Recommendations 
MGMA supports ONC’s efforts at developing an EHR Reporting Program to assist end users make better and more informed purchasing decisions. MGMA highlights the following high-level recommendations aimed at ensuring that the Reporting Program meets its objectives:
 

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