MGMA comments on HTI-2 proposed rule (October 4, 2024)

October 4, 2024 

Micky Tripathi, PhD, MPP
Assistant Secretary for Technology Policy
National Coordinator for Health Information Technology
Office of the National Coordinator for Health Information Technology
Department of Health and Human Services
330 C Street, SW, 7th Floor
Washington, DC 20024

Re: Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (RIN 0955-AA06)

Dear Assistant Secretary Tripathi:

The Medical Group Management Association (MGMA) thanks the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) for the opportunity to comment on the Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule. We support ASTP/ONC’s efforts to remove technological roadblocks that negatively affect the ability of medical groups to transmit and receive important information.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical group practices ranging from small private medical practices to large national health systems, representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following policy recommendations.

This wide-ranging proposed rule offers numerous policies which, if implemented correctly, would increase interoperability, reduce administrative burden, and avoid penalizing medical groups for commonsense practices under information blocking regulations. At the same time, we caution ASTP/ONC that there is a rapid promulgation of health information technology (IT) regulations happening that not only requires medical groups to expend substantial financial resources, but devote time to hiring/training staff, implementation, and compliance.

View the full letter