CARIN Letter to HHS on Provider Information Blocking Disincentives
The CARIN Alliance provided comment to ONC and CMS on their provider information blocking disincentive proposed rule with recommendations on its complaint submission process, applicable providers, and prioritization of enforcement activity. In our comments we provided a number of innovative ideas including a ‘complaint clearinghouse’ concept that requests ONC to allow providers and payers an option to submit complaints to an independent third-party who would aggregate those complaints and then submit them as a group. This would avoid individual providers and payers knowing which of their trading partners submitted the complaints but would also identify clear violations of information blocking to advance information sharing with providers, payers, and most importantly patients. See the link above for our full comments.
