This week, EHRA submitted comments to ONC regarding the 21st Century Cures Act (Cures) Trusted Exchange Framework and Common Agreement implementation.
You can read EHRA’s recommendations here. Our comments focus primarily on:
1. EHRA’s support for secure exchange and non-discrimination in data-sharing. Developers who adopt the EHRA Code of Conduct “are committed to developing and implementing our software, services, and business practices in ways that protect patients’ privacy through the secure and trusted handling of protected health information (PHI).”
2. Urging ONC to build upon the progress that has been made by stakeholders, versus introducing major mid-course changes which would lead to disruption. “EHRA emphasizes that important work and investments have been made by developers, HIEs, exchange consortia, providers, payers, and other stakeholders in technical standards and technology approaches for interoperability and encourages future work by ONC to build upon and not undermine or reduce the value of this foundation.
3. Emphasizing that participation in the trust framework should be voluntary. “Failure to adhere should not be considered de facto information blocking when other methods are used to exchange information.”
4. Noting that some comment areas proposed by ONC seem to extend beyond specific Cures requirements. “It will be important to distinguish between statutory requirements and ONC policy goals.”
EHRA looks forward to continuing to work with ONC and other stakeholders dedicated to advancing secure data exchange to support patient care through the best use of EHRs.
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