Questions and Requests for Stakeholder Feedback

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Comment

EHRs should not charge transaction fees for APIs

EHR vendors should not be allowed to charge any transaction fees as it relates to API calls as this stifles innovation. For example, Epic EMR's transaction fees take 15% of any vendor on AppOrchard's total revenue. If ONC wants health care to evolve out of it's "brick and mortar" presence in order to achieve the quadruple aim then all API calls as it relates to patients' data needs to be free. Thank you.

electronic Long-Term Services and Supports

Please consider adding the eLTSS FHIR IG as an emerging standard.  It includes the 56 data elements that were developed during the TEFT program and documented in the HL7 eLTSS Informative Document
eLTSS ISA.docx

Allscripts 2019 ISA Comments

Please see attached comments in response to the 2019 ISA questions and updates.
Allscripts Response 2019 ISA September 2019.pdf
2020 ACLA Comments ONC ISA-Final.pdf

HIMSS Response to ONC 2019 ISA

The Healthcare Information and Management Systems Society (HIMSS) is pleased to submit these comments for consideration by ONC to update the Interoperability Standards Advisory (ISA). These comments are one set in a series that HIMSS has provided on the content in the web-based version of the ISA. For more information on previous comments, please visit the HIMSS website. Please find comments in the attachment outlining our responses to the ONC Requests for Feedback and additional recommendations for expansion. 
HIMSS Response to ISA September 2019_FINAL.pdf

CAQH CORE Comments to ONC ISA 2020 Reference Edition

Dear Dr. Rucker, Thank you for the opportunity to provide input to the Interoperability Standards Advisory (ISA). CAQH CORE appreciates that the ISA includes a description of standards, implementation specifications, operating rules and other utilities that support interoperability in the exchange of healthcare information. The CAQH Committee on Operating Rules for Information Exchange (CORE), is a non-profit, national multi-stakeholder collaborative that drives the creation and adoption of healthcare operating rules that support standards, accelerate interoperability and align administrative and clinical activities among providers, payers and consumers. CAQH CORE participating organizations represent more than 75 percent of insured Americans, including health plans, providers, electronic health record (EHR) and other vendors/clearinghouses, state and federal government entities, associations and standards development organizations. CAQH CORE is designated by the Secretary of the Department of Health and Human Services (HHS) as the Operating Rule Authoring Entity for HIPAA-mandated administrative transactions. Operating rules are developed by CAQH CORE participants via a multi-stakeholder, consensus-based process. CAQH comments on the ISA are set forth below based on our history of working with stakeholders across the healthcare industry to reduce administrative burdens in areas such as eligibility and benefit verification, prior authorization, attachments or exchange of medical documentation, claims submission and payment, and value-based payment. The comments in this letter are presented in two parts and are intended to enhance the quality of information in the ISA and improve usability:
  • Part I includes specific comments on existing content in Section IV of the ISA.
  • Part II responds to the Request for Stakeholder Feedback pertaining to question 19-3.
CAQH CORE has also posted these comments to the online resource. Thank you for considering our recommendations and comments. Should you have questions for CAQH CORE, please contact me at eweber@caqh.org or 202-517-0435. Sincerely, Erin Richter Weber Director, CAQH CORE
CAQH CORE Comment Letter to ONC ISA_0.pdf

CMS DEL HITWG Comments on Proposed 2019 ISA

The CMS Data Element Library (DEL) Health Information Technology Workgroup (HITWG) is pleased to offer feedback on the proposed 2019 ISA.
CMS_DEL-HITWGComments_ONC 2019 ISA_Final.docx

WA DOH 2019 ISA Comments

Please see attached comments in response to the 2019 ISA questions and updates.
ONC_ISA_WA_DOH_Comments_2019.pdf

DirectTrust Proposed Updates to the 2019 ISA

Dr. Rucker –  DirectTrust is pleased to offer our suggestions for updating the ONC Interoperability Standards Advisory (ISA).  Attached below are changes our diverse membership believes reflect the current status of the Direct Standard™ and of its emerging, and in some cases, widespread use in use-cases not previously documented in this important resource.  Our updates also update readers on our emergence as an ANSI Accredited Standards Development Organization and our new role as the ongoing steward of the Direct Standard. The attached document shows changes proposed to the web version of the ISA in the grid format with new material in red.  Both updates to existing pages as well as new pages are represented.  Bullets to be included in the Limitations, Dependencies, and Preconditions for Consideration are provided in columns to the right of the grid for each page.  The ISA continues to be a valuable resource for the market to understand how standards are being used and to track progress in maturity and adoption.  Please let us know if there are additional clarifications needed.  We value our ongoing collaboration with your team.   Scott Stuewe President and CEO
ISA Updates 09.23.2019.xls

Comments From DICOM Members for ISA 2019

September 23, 2019 The DICOM Secretariat is pleased to submit comments on behalf of DICOM stakeholders in response to the Office of the National Coordinator’s (ONC) Request for Public Comments regarding the Interoperability Standards Advisory (ISA).    DICOM® (Digital Imaging and Communications in Medicine) is the international standard to transmit, store, retrieve, print, process, and display medical imaging information. Individual comments have been posted to each section and included in the attached document. Thank you for the opportunity to provide feedback and please contact me with any questions. Lisa Spellman DICOM General Secretary lspellman@dicomstandard.org
2019_ISA Feedback_DICOM.pdf