By Danielle Friend (Epic), Chair, Standards & Interoperability Workgroup, and John Stamm (Epic), Vice Chair, Public Health Workgroup

Previous installments of this 3-part blog series on the EHR Association’s top concerns with HTI-2 focused on the overarching issues and specific issues with the complex web of proposed changes to Insights Measures. Our full comments to ASTP are available on our website.

Along with unrealistic compliance timeframes and out-of-sync cross-agency requirements, ASTP’s Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule creates substantial compliance burdens for providers, the EHR developers that support them, and public health agencies (PHAs) due to the laundry list of premature and/or unnecessary and lopsided requirements.

Three areas where these issues are quite prominent are HTI-2’s proposed requirements pertaining to standards, electronic prior authorization (ePA), and public health reporting.