Workgroup for Electronic Data Interchange Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, Dec. 19 -- Jay Eisenstock, chair of the Workgroup for Electronic Data Interchange, has issued a public comment on the Centers for Medicare and Medicaid Services proposed rule entitled "Reducing Provider and Patient Burden, and Promoting Patients' Electronic Access to Health Information (CMS-9123-P)". The comment was written on Dec. 15, 2020, and posted on Dec. 17, 2020:

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On behalf of the Workgroup for Electronic Data Interchange (WEDI), I thank you for releasing your Notice of Proposed Rulemaking entitled Medicaid Program; Patient Protection and Affordable Care Act; Reducing Provider and Patient Burden by Improving Prior Authorization Processes, and Promoting Patients' Electronic Access to Health Information for Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, and Issuers of Qualified Health Plans on the Federally-facilitated Exchanges; Health Information Technology Standards and Implementation Specifications.

WEDI is very appreciative of the proposed solutions to address the burdens associated with prior authorization. Given the importance of this proposal and the impact to the industry, WEDI believes the time afforded to submit formal comments is insufficient and hereby request an extension of thirty days.

WEDI a named advisor to the Secretary of the U.S. Department of Health and Human Services (HHS) in the Health Insurance Portability and Accountability Act of 1996 (HIPAA), is a frequent commenter on administrative simplification regulations.

As a multi-stakeholder organization comprised of health plans, providers, vendors, standards development organizations, and government representatives, WEDI offers a wealth of experience in advising HHS and educating the industry on a wide range of health information technology (IT) regulatory requirements.

The rule proposes an aggressive set of regulatory requirements that have significant potential to streamline information exchange between providers and payers. However, to be successfully implemented, these proposals will require adoption of new standards and substantially revised business workflows. It is critical that the Centers for Medicare & Medicaid Services (CMS) receive detailed feedback from payer and provider organizations and other impacted stakeholders. In addition, the rule includes requests for information (RFIs) on a wide range of topics. Each of these RFIs will require careful consideration and may require outreach to our member organizations to appropriately respond.

We recognize the agency's desire for swift rulemaking to address one of the foremost administrative challenges and for soliciting input from the industry on the topics included in the RFIs. However, due to the complexity and importance of this proposed regulation we strongly urge CMS to extend the public comment period a minimum of 30 days.

As the collective voice of the health care industry on health IT, WEDI appreciates the opportunity to offer our recommendations on this important matter. Please contact me at [email protected] or Charles Stellar, President and CEO of WEDI, at [email protected] with any questions you may have.

Sincerely,

Jay Eisenstock Chair, WEDI

cc: WEDI Board of Directors

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0157-0001

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