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Don Rucker, MD
National Coordinator for Health Information Technology
Department of Health and Human Services
Attention: EHR Reporting Program Request for Information
330 C Street NW
Washington, DC 20201

Submitted online at https://www.regulations.gov/

SUBJECT: HHS-ONC-2018-022 – Request for Information Regarding the 21st Century Cures Act Electronic Health Record Reporting Program

Dear Dr. Rucker:

On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the opportunity to comment on this request for information (RFI) regarding the Electronic Health Record (EHR) Reporting Program.

The EHR Reporting Program was established under Section 4002 of the 21st Century Cures Act (Cures Act) and is intended to provide publicly available, comparative information on certified health information technology (HIT) that will inform the purchasing and implementation decisions of certified HIT users. The Cures Act requires that these reporting criteria specifically address security, interoperability, usability and user-centered design, and conformation to certification testing, as well as other categories as appropriate. The Cures Act also suggests several other categories for consideration, including, but not limited to: enabling users to order and view results of laboratory tests, imaging tests, and other diagnostic tests; exchanging data with clinical registries; accessing and exchanging data from medical devices, health information exchanges, and other health care providers; and accessing and exchanging data held by federal, state, and local agencies. Importantly, the statute also requires that ONC establish these reporting criteria through a public, transparent process that reflects input from developers and end users of certified HIT. This RFI represents a first step toward developing these criteria and implementing the statute.

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