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Health IT Strategic Planning

Strategic Plan Public Comments

Collect - Share -UseONC accepted public comments on a draft version of the Federal Health IT Strategic Plan 2015-2020 [PDF - 1 MB]. The time for public comments ended on February 6, 2015.

This Plan represents a coordinated and focused effort among 35+ federal departments and agencies to advance the collection, sharing, and use of electronic health information to improve health care, individual and community health, and research.

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Jim Pyles
Powers, Pyles, Sutter & Verville, PC

(comments attached)

Maria Veronica Svetaz, MD MPH FSAHM FAAFP
Henne-Teen MEdical DIrector


Posted: 02/07/2015 - 12:16pm

I am a physician working in direct care and on innovation for healthcare, mainly Adolescent and Health Equity Care, working for the past years in making sure our EHR vendor EPIC allows us to protect the privacy right (by law) of teen care for certain issues (those issues vary by States, but we found a way to accommodate to those laws, and trained the workforce around that). I know our organization SAHM, is sending a document but I am just puzzled again how there is not mention of privacy needs, not only for teens, but for people in general, particularly women. To me, the Logo Chain should be "Collect, PROTECT, Share, Use". We had to create a interdisciplinary task force that worked for the past 6 years in developing a strategy and creating "convoluted electronic loopholes", because this was never considered an important piece of our EHR. We presented our work in EPIC Conference 2010, and we are presenting again this coming March 16, at the Spring EPIC Conference this year, and will be more than happy to share more, but this has been shocking to the whole community of providers working with adolescents, how this evidence based right was so over-sighted. Thanks for allowing us to express our ideas (even in English as Second Language!).

Silvia Yee
Senior Staff Attorney
Disablity Rights Education and Defense Fund


Posted: 02/06/2015 - 11:53pm

My deepest apologies for missing the 5 PM EST time deadline. I sincerely hope that you will still consider these comments from the Disability Rights Education and Defense Fund regarding the use of Health IT by and for people with disabilities.

Kiersten Steward
Director of Public Policy and Advocacy
Futures Without Violence


Posted: 02/06/2015 - 11:31pm

Thank you for the opportunity to submit these comments.

Joe Mccluskey


Posted: 02/06/2015 - 10:12pm

This committee must include pre-hospital EMS in its future plans. Thinking that volunteer organizations, VAC's or FD's will be able to withstand the increase in pre-hospital emergency medical calls is fantasy, and misguided.

Michelle Dougherty
LTPAC Health IT Collaborative


Posted: 02/06/2015 - 9:29pm

Members of the Long Term & Post-Acute Care Health Information Technology Collaborative (LTPAC Health IT Collaborative), which was formed in 2005 to advance health IT issues by encouraging coordination among LTPAC provider organizations, policymakers, vendors, payers and other stakeholders, appreciates the opportunity to offer comments on the Draft Federal Health IT Strategic Plan 2015 – 2020 released in December 2014.

The LTPAC Health IT Collaborative agrees with the laudable goals outlined in the Federal Health IT Strategic Plan and appreciate HHS’s ongoing efforts to drive wide-spread adoption and use of health IT that will benefit the individual and society alike. We also applaud HHS & ONC for presenting a thoughtful plan that reflects the interests of 35 federal agencies and acknowledges the important role of all stakeholders.

Thank you for this opportunity to offer comments in the uploaded document for your consideration.

Respectfully submitted,
LTPAC Health IT Collaborative

Dana Singiser
Vice President of Public Policy and Government Relations
Planned Parenthood Federation of America


Posted: 02/06/2015 - 8:12pm

Comments are attached.

Cynthia Morton
Executive Vice President


Posted: 02/06/2015 - 7:10pm

The National Association for the Support of Long Term Care (NASL) appreciates the opportunity to offer comments on the draft Federal Health IT Strategic Plan 2015 – 2020, which was released on December 8, 2014. While we support the broad goals and objectives outlined in the Federal Health IT Strategic Plan, we know that the challenge is in implementation. So, we are eager to review the details provided in the just-released Nationwide Interoperability Roadmap and Standards Advisory. Please review our specific comments in the attached file.

Scott Plack
Director, Public Policy & Government Relations
Group Health Cooperative


Posted: 02/06/2015 - 6:14pm

Group Health Cooperative offers the following comments that are most pertinent to objectives 2C - protect the privacy and security of health care information, and 4A - empower individual, family, and caregiver health management and engagement. The intention of these comments is to ensure that the strategies to meet these objectives reflect the unique needs of adolescents within the healthcare system.

The appropriate use of health information technology is becoming a developmental milestone for adolescent patients, particularly those with chronic health conditions. As with the rest of the health care system, health IT must be able to balance adolescents’ ethical rights to privacy and autonomy with their ongoing needs for adult support and supervision.

The current draft of the strategic plan states that the “federal government also supports the development of policy, standards, and technology to facilitate patients’ ability to control the disclosure of specific information that is considered by many to be sensitive in nature (such as information related to substance abuse treatment, reproductive health, mental health, or HIV) in an electronic environment.” Similar policies would be appropriate to meet the privacy needs of adolescents.

A health IT system appropriate for adolescents will need to incorporate:

1. Seamless, fool proof mechanisms for health care providers to protect from typical release some information in the medical record, while leaving it available for those who truly need to know.

2. The ability to mark some visit types, medications and lab orders confidential within the record. An accompanying policy issue is to redact these from explanation of benefits notices.

3. Recognition that the current generation of adolescents is much more likely to use mobile applications accessible on a smart phone or similar device than other means of electronic communication.

4. The ability for direct communication between health care providers and adolescent patients regarding health care for which the adolescents consent to independently of their guardians.

5. The ability for direct communication between health care providers and families regarding health care which is co-managed by families and adolescents.

Major health plans/provider groups around the country are struggling to make this happen by broad and vigorous support on the Society of Adolescent Health and Medicine list serve.

Thank you for the opportunity to comment.

Majd Alwan
SVP of Technology
LeadingAge, Center for Aging Services Technologies (CAST)


Posted: 02/06/2015 - 5:51pm

Dear Sir/ Madam,

I am writing on behalf of LeadingAge, an association of 6,000 not-for-profit organizations dedicated to making America a better place to grow old. The mission of LeadingAge is to expand the world of possibilities for aging. Our membership includes 6,000 not-for-profit organizations representing the entire field of aging services, 39 state partners, and hundreds of businesses, consumer groups, foundations, and research partners. Together, our members touch 4 million lives every day.

LeadingAge is also a part of the International Association of Homes and Services for the Aging (IAHSA), which spans 30 countries across the globe.

LeadingAge is a 501c3 tax exempt charitable organization focused on education, advocacy, and applied research.

The LeadingAge Center for Aging Services Technologies (CAST) is a program of LeadingAge that is leading the charge to expedite the development, evaluation and adoption of emerging technologies that can improve the aging experience. CAST has become an international coalition of more than 400 technology companies, aging services organizations, research universities, and government representatives.

LeadingAge, LeadingAge CAST and our members agree with the laudable goals outlined in the Federal Health IT Strategic Plan and appreciate ONC’s ongoing efforts to drive wide-spread adoption/ use of Health IT that will benefit the individual and society alike. We also applaud HHS & ONC for presenting a thoughtful plan that reflects the interests of 35 federal agencies and acknowledges the important role of all stakeholders.

It is significant to find LTPAC included in the ONC’s definition of “provider” and acknowledged as an important part of the healthcare system. We were also pleased to the broadening of Health IT to include Telehealth and Mobile Technology. While we support the broad goals and objectives outlined in the strategic plan, the challenge is in implementation; so, we are eager to review the details provided in the just-released ONC Interoperability Roadmap.

As ONC acknowledges in this draft, LTPAC, behavioral health and other providers did not receive incentives under the HITECH Act and American Recovery & Reinvestment Act (ARRA) that hospitals and eligible professionals have used to offset costs related to Meaningful Use of health IT. The lack of incentive payments has not dampened the enthusiasm that many LTPAC providers and Health IT vendors have demonstrated in terms of investing in health IT, advancing interoperability and promoting health information exchange. Nonetheless, it is an important limiting factor that we wish to be understood by federal policymakers.

While we look forward to achieving the goals outlined in the Federal Health IT Strategic Plan, we are mindful of the barriers we must address. We encourage ONC to continue with a more focused effort – one that is centered on high-value strategies as well as a set of LTPAC-specific programs and activities that allow all providers to be engaged in the process and that increase networking across the healthcare spectrum. By narrowing the scope around certification, by focusing on standards and by producing truly meaningful deliverables – such as care summaries that inform transitions of care – we are more likely to achieve ONC’s mission of improving health, health care and reduce costs.

LeadingAge views coordination among federal agencies as a critical role for ONC. It is essential that ONC coordinate and harmonize all the programs and efforts of various federal and state agencies. ONC also has a role to play as convener, too. ONC has the authority and responsibility to not only coordinate among federal agencies, but to serve as convener of national Health IT strategy – bringing public/private together, all stakeholders – not only incentivized providers, and involving technology leaders that serve LTPAC and other care settings that have not had the opportunity to participate on the FACAs in the same way that vendors involved in Meaningful Use have.

LeadingAge and LeadingAge CAST and their members support the use of Telehealth, Mobile and other technologies such as remote patient monitoring. Telehealth and technologies such as remote patient monitoring have the potential to deliver cost savings and increased efficiencies in care delivery through more timely medical interventions, reduced unplanned hospitalizations and emergent care. In addition, these services allow for greater patient engagement and higher levels of care satisfaction. Through longitudinal care coordination, providers are able to better manage the care of patients with chronic conditions by monitoring changes in health status with increased frequency and employing advanced analytic tools to improve the timely delivery of care, care coordination and reduce unintended emergency room visits and hospital readmissions.

As new payment models such as risk-sharing, bundling and ACOs are being evaluated, we would encourage HHS to explore how new modalities like telehealth, home-based remote care management and remote patient monitoring can treat patients as part of an efficient, comprehensive program that provides integrated, person-centered care and services in less restrictive and less costly settings.

• New care models, such as ACOs, that we had hoped might support the cost of Health IT adoption among non-incentivized providers, including LTPAC providers, are not working that way – only few larger LTPAC providers that already have the Health IT infrastructure and the ability to scale up are participating and taking advantage of these opportunities! ONC should consider specific strategies to encourage the adoption Health IT, including EHRs and Telehealth, as well as the active participation in Health Information Exchange, by LTPAC providers, particularly small and/or rural LTPAC providers who do have neither the resources nor the market opportunities created by the Health Reform to justify the investment of Health IT. Such strategies may include direct incentive payments, reimbursement of a broader array of Telehealth services, Health IT grants, and no/low-interest loans in addition to no/low-cost technical assistance on planning and implementation, by HITRECs for example.

• Reimbursement should be considered as a strategy/ tool to drive the adoption of telehealth technology to achieve reduced hospital readmissions, bed days and emergency room visits while providing care in the least restrictive and costly settings. For these reasons, ONC should coordinate with CMS to waive restrictions imposed by section 1834(m) of the Social Security Act for any Medicare patient. The aforementioned section restricts Medicare reimbursement to a limited number of Medicare Part B services furnished through particular telecommunications systems to only those beneficiaries able to reach an “originating site” located in a rural Health Professional Shortage area or a county outside of a Metropolitan Statistical Area (MSA). Specifically, “originating sites” only include physician offices, hospitals, critical access hospitals, skilled nursing facilities, and Federally Qualified Health Centers. We believe that CMS should consider:

o Eliminating the restriction on location (originating site) and presence of a health professional for receipt of telehealth delivered evaluation and management services, to include home-based remote care management and remote patient monitoring, and non-rural areas.
o Eliminating the stipulation of live voice and video, to ensure coverage of store-and-forward remote patient monitoring and telephone-based remote care management and coordination.
o Expanding the scope of distant site providers eligible for reimbursement to include not only physicians, physician assistants, and hospitals, but also nurse practitioner, home health and hospice agencies, nurses, and care managers.
• As CMS and CMMI continue to encourage innovation and explore new payment models, ONC should coordinate with CMS/CMMI to explore launching demonstration programs focused on, or led by LTPAC providers, that have emphasis on not only Health IT, including EHRs, Telehealth and health information exchange, but but also innovative operational and payment models collaboratively designed to provide incentives for the adoption and meaningful use of these technologies long-term.
• More opportunities for exchange of information between LTPAC providers, physicians and hospitals are also needed.

• The infrastructure needs to be there to achieve our collective goals – that will be driven by the business case for Health IT adoption.
• Ensuring that the infrastructure necessary to exchange health information is in place is essential. ONC can ensure that policies impacting infrastructure support multiple platforms and technologies, including existing and future iterations.
• Recognize that IMPACT Act is driving standardized assessment and quality measure reporting for LTPAC, which will have an effect on interoperability.

• LTPAC providers are important partners for acute care providers. The success of these partnerships depends upon the ability to use health information technology (IT) and to exchange relevant health information electronically to ensure patients experience seamless transitions from one care setting to the next and quality of care in every setting.
• Bring physicians who visit multiple sites along the LTPAC spectrum of care and have adopted their own Health IT systems into the plan, so they are connected to the facilities and pharmacies
• LTPAC and physicians need to work on interoperability – physicians are critical to continuous sign-off on care plans, medication and chronic care management.
• Communication and coordination piece are essential as we look to manage chronic care, multiple comorbidities and involve patients/family caregivers as well as professional caregiving teams.
• Areas of priority:
o Accurate medication reconciliation/management
o LTPAC is first to do holistic, longitudinal view of the patient.
o Data exchange / not just records but best practice processes for such things as medication management.
o Look at advanced directives – right now it’s a checkbox – not included in the timeline until 2018.
o CMS needs to recognize and pay for two new CPT advance care planning codes adopted by the CPT Editorial Panel and valued by the AMA/Specialty Society Relative Value Scale Update Committee (RUC). These new codes would greatly improve end of life care services for Medicare patients by supporting patient choice regarding end of life care and also enhancing quality of life for patients.

Thank you for this opportunity to offer these comments for your consideration.

Respectfully submitted by Majd Alwan, on behalf of LeadingAge and LeadingAge CAST.

Joel White
Executive Director
Health IT Now


Posted: 02/06/2015 - 5:48pm

Thank you for the opportunity to comment on the Federal Health IT Strategic Plan. Attached please find Health IT Now's comments.

Comments Upload: 
Guy Durant
Goal 5


Posted: 02/06/2015 - 5:47pm

Clinical Trials Research is too often an afterthought of Electronic Medical Records design and support. It is time for IRB data and Research Data gathering to be built into all E.H.R.s and that Standard of Care Costs and Drug and Clinical Trial Costs are separated and documented in Billing Systems for medical care. We all want to reduce the cost of healthcare, but are we tracking those costs by coding Medical Records collected during Clinical Trials in the Same EMR/EHR medical record systems in our Hospitals, Universities and Research Clinics? How are we sharing Medical Research Records differently from Standard of Care Medical Treatment Records. Yes, we want a common Repository of all Health Records, but we want codes and flags and data sharing for Research Records (Which have Patient Consent to share) to be more open and less subject to Hipaa privacy concerns. I think if a Patient Record contains Non-Research Records that is fully private and fully protected by HIPAA, but if a Patient Record contains Clinical Trials Data or Research Data that was funded by an IRB approved and Patient Consented Clinical Trial, then the Data Sharing and Access to those Research Records should be fully shareable and segmented for sharing apart from all the other medical data except maybe for Demographics. Demographics is very important in Research and if a Patient consents to sharing that data for Research, we should not have to jump through the same HIPAA hoops to use data already patient consented for us in a Medical Records or EHR system that shares data with Researchers. What is your policy about opening up EHR and EMR systems to greater Researcher access and sharing? How can you set standards for Sharing Research Data in Exchanges. We have CDISC for the format of the Research Records, but what about the Repositories themselves? Are you requiring EHR Vendors like EPIC and ALLSCRIPTS, etc. to share Research Data less restrictively than other Non-Consented Patient Records? Are you requiring Research Specific Modules be added to these systems to support greater research sharing apart from the normal GUI's that allow for Adding or sending HL7 data around? Let's get practical standards for encouraging Research Data sharing. I will give you an example. When I was at Walter Reed, I noticed that the EMR/EHR system had no central or easily accessible way to track Patient Blood Type. It was not stored with other Demographic data like Race, Age, Sex, etc., in fact you really couldn't find Blood Type without first ordering a "LAB" Result. The Blood Type was only stored as part of a "Lab". Well, I think for Research it is very important to track how drugs interact with people of various Blood Types, just as it is important to track how drugs affect Women vs. Men or Old vs. Young or Black vs. White, etc., Yet the lack of even this Demographic standard was appalling when looking to later on do retrospective research studies on patients according to BloodType. So, If I wanted to pull or enter Research Data on Clinical Trials and cross reference EHR/EMR data such as Blood Type, how can I get everything I need for my clinical study without it being required to store Blood Type for every patient? Even if you don't require that, you should standardize how the data is stored either as a Lab result or a demographic fixed item (except for maybe transfusions). Thanks. Please improve your Strategy for Research Sharing.

Jamie Ferguson
VP, Health IT Strategy & Policy
Kaiser Permanente


Posted: 02/06/2015 - 5:38pm

Kaiser Permanente offers the following comments to ONC on the Federal Health IT Strategic Plan. Please see attached letter.

Meredith Lichtenstein
Senior Research Analyst
Council of State and Territorial Epidemiologists


Posted: 02/06/2015 - 5:24pm

Dear Office of the National Coordinator for Health Information Technology,

This letter contains comments from the Council of State and Territorial Epidemiologists (CSTE) on the Office of the National Coordinator for Health Information Technology (ONC) request for comment on the Federal Health IT Strategic Plan 2015-2020. CSTE is an organization of member states and territories representing public health epidemiologists. CSTE and all epidemiologists at state and local public health agencies have a vested interest in the successful implementation of health information technology to not only allow public health to efficiently detect, track, manage, and prevent disease outbreaks – but to improve and protect people’s overall health and well-being. We are supportive and pleased of ONC’s inclusion of public health as a prominent entity whose efforts are integral to the successful implementation of this strategic plan. The Federal Health IT Strategic Plan recognizes the central role that public health agencies play across the goals of collecting, sharing, and using health information. Public health agencies are the front-line of national efforts to build electronic data exchanges. CSTE comments on individual goals, objectives, and strategies of the Strategic Plan are included on the following pages.

CSTE wishes to acknowledge the vision of the ONC in continuing to promote population health improvement. We are enthusiastic and supportive of ONC’s efforts to coordinate over thirty-five separate, federal departments and agencies to protect and improve our nation’s health with electronic health information. Maintaining a focus on improving population health is critical to transforming healthcare and achieving the highest possible value from the public investment in the Health Information Technology for Economic and Clinical Health Act. CSTE looks forward to continuing to engage with ONC on the implementation of this strategic plan and to strengthen our relationship with ONC and other partners to support the integration of public health and clinical care through the widespread adoption of health IT and other interoperable technologies.


Jeffrey P. Engel, MD (Executive Director)
Alfred DeMaria, MD (CSTE President)
Janet J. Hamilton, MPH (CSTE Surveillance/Informatics Steering Committee Chair)

Overall Strategic Plan Comments:

• For the Strategy to succeed it is imperative for the federal government to sustain and enhance cooperative efforts with national associations that build greater capacity for informatics at state, tribal, local, and territorial (STLT) levels. Public health agencies are constantly challenged with limited resources to train, recruit, and retain staff with the skills necessary to facilitate information exchange and maintain necessary collaborations. Given the increasing number of electronic data trading partners and exponentially greater volumes of information, public health agencies are experiencing an acute strain on technical and administrative functions. Building informatics workforce capacity will reinforce and boost public health’s efforts to participate in national activities to develop public health data and exchange standards, as well as overcome fiscal constraints and IT procurement challenges.

• CSTE is pleased to see public health entities mentioned throughout as an integral partner to the successful implementation of this strategic plan and recognition of the important role public health plays in responding to emergencies. We do see specific areas of the plan in which public health is not uniquely addressed but could aid in strategic objective implementation (Objectives 1A, 1B, 2A, 3A, 3B, and 5A).

• We see the need to clarify the distinction between ‘population health’ and ‘public health’ in the document. Population health to most providers means managing the health of their specific panel of patients (be it big or small) and population health is ultimately about an entire population regardless of where they seek care or who insures them. In some instances, population health and public health are interchangeable and other times are listed separately (Objective 3C).

• We see the need to clarify the distinction public health as a provider (page 5) in addition to public health’s role supporting population health across the continuum not just serving in the provider capacity.

• Public health’s role in the Overview (page 4) and Goal 4 (page 21) is described as having the ability to ‘detect, track, manage, and prevent disease outbreaks’, which is certainly an important function of public health. Public health plays a broader role well beyond the prevention of disease outbreaks to protect the public’s health such conducting population based surveys such as the Behavioral Risk Factor Surveillance System (BRFSS), immunizations, cancer registries, and vital statistics can greatly benefit from the vision of this strategic plan for the next 5 years. Suggest adding to this statement to reflect the broader role of public health.

• To provide greater assurance that efforts aligned with Goal 1 adequately build data collection capacities for public health purposes, CSTE suggests that ONC work with its federal partners to further support and incentivize the development and adoption of health information technologies for public health functions; e.g., contact tracing, countermeasure administration, outbreak management systems, etc.

• CSTE emphasizes the importance of public health and public health information for advances on Goal 3. To strengthen care delivery, population health outcomes must be objectively measured and contextualized within a fully, holistic and complete public health system perspective.

Strategies and Objectives:

• Objective 1A: CSTE supports efforts to increase the adoption and effective use of health IT systems and EHRs by healthcare providers, especially for public health purposes. The continued inclusion of public health objectives in meaningful use is paramount to the building robust health information exchanges among care providers and STLT public health agencies. CSTE recommends clarifying the first 3-year outcome to say, ‘Increase the percentage of hospitals and professionals who successfully demonstrate Meaningful Use and increasing public health agencies’ capacity to support those measures’.

• Strategy 2 for Objective 1A: CSTE recommends clarifying Strategy #2 for Objective 1A to say, ‘Expand the capacity of the workforce to support use of health IT within both public and private sectors.’

• 3-Year Outcome for Objective 1A: CSTE recommends including public health agencies in the 3-year outcome for Objective 1A, in addition to being involved in the 6-year outcome. The strategies should be expanded to not just use of health IT in electronic health records (EHR) but also to support and have incentives outside of specific EHR technology to increase public health IT interoperability.

• Objective 1B: CSTE recommends including public health and CDC in this objective and subsequent strategies. State and local public health departments can engage the community to address concerns and increase confidence in the safety and use of health IT products.

• Objective 1C: CSTE recommends reviewing and expanding to all relevant agencies called upon in the 3- and 6-year outcomes for this objective, to advance a national communications infrastructure that supports health, safety, and care delivery.

• Objective 2A: Public health agencies are trusted stewards of personal health information. As threats to the security and integrity of information systems evolve, CSTE urges ONC and its federal agency partners to continue and enhance efforts that ensure STLT agencies possess state-of-the-art tools and capacities to maintain cyber-security.

• Strategy 3 for Objective 1C: CSTE recommends ensuring the public health IT and telecommunications infrastructure are resilient and operational during disaster and emergency response situations. This mandates that the infrastructure is operational in times of emergencies and during ongoing day-to-day matters to be able to capture a baseline for comparison during emergencies.

• Strategy 5 for Objective 2A: CSTE recommends Strategy 5 for Objective 2A say, ‘Encourage electronic information sharing between public and private health providers and payers to promote care continuity, in addition to facilitating public health reporting and population analysis.’

• 6-Year Outcome for Objective 2B: CSTE recommends that CDC and other public health agencies be included in the 3- and 6-year outcomes.

• Objective 3B: CSTE recommends clarification on ‘essential health information’. Clearly defining will allow providers and public health agencies have the capacity to collect, share, and manage this type of information.

• Objective 4B: CSTE recommends similar language from the Strategy 1 for Objective 1C to be duplicated in Objective 4B, specifically the use of federal authorities and investments to expand capacity for health IT in state and local health departments.

• Strategy 4 for Objective 4B: The use of the word, ‘prepare’, in Strategy 4 needs to be clarified. CSTE recommends clarifying the use of ‘public health systems’ to distinguish between the technology or the infrastructure. It would behoove state and local health departments to invest in their infrastructure to handle the implementation of interoperable health IT and its future iterations. This would ensure longevity, resiliency, and flexibility of public health tools, resources, and people.

• Objective 5A: CSTE encourages ONC and its federal agency patterns to include STLT public health agencies as necessary collaborators and stakeholders in the strategies outlined for this objective. In order to advance the science and practice of disease surveillance, state and local public health entities must be able to share realistic, but de-identified public health datasets in line with state and federal statutes.

Kendra Manning
Chief, Standards Engagement


Posted: 02/06/2015 - 4:59pm

Thank you for allowing us to participate. Feel free to contact me for any points of clarification. I'll act as the POC to the individual within our organization who submitted the comment.