Policy & Regulatory

CARIN is publishing a Best Practice Recommendations for HL7® FHIR® Based Deployment for how to improve the current HL7® FHIR® ecosystem to prepare the industry for implementing HL7® FHIR® at scale. We believe if followed, these best practices will dramatically improve FHIR connectivity across the country with provider, payers, and patients.

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.

CARIN Alliance Comments on National Healthcare Directory

CARIN Alliance Comments on the ONC Health Data, Technology, and Interoperability: Certification Program Updates, AlgorithmTransparency, and Information Sharing NPRM

CARIN Alliance Comments on the CMS Advancing Interoperability and Improving Prior Authorization Processes NPRM (CMS-0057-P)

CARIN Alliance Comments on Medicare Advantage requirements for Real-time Benefit Tools

CARIN Alliance Comments on ISA 093022

Comments to Recognized Coordinating Entity on the Current Draft IAS Exchange Purpose Implementation SOP

CARIN Alliance Comments to Recognized Coordinating Entity on the Current Draft IASProvider Privacy and Security Notice and Practices SOPs

Letter to OCR requesting clarification regarding Breach Notification requirements for Patient Access in a Networked Environment

CARIN Alliance Comments on Draft USCDI v3 042922 –

Response to the Request for Information (RFI) on Strengthening Community Health Through Technology

Letter to ONC on CARIN IG for Blue Button® Data Class for USCDI 09302021

Comments on HIPPA NPRM

Medicaid Program; Patient Protection and Affordable Care Act; Reducing Provider and Patient Burdenby Improving Prior Authorization Processes, and Promoting Patients’ Electronic Access to HealthInformation for Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIPManaged Care Entities, and Issuers of Qualified Health Plans on the Federally-facilitated Exchanges;Health Information Technology Standards and Implementation Specifications

RE: Health Breach Notification Rule, 16 CFR part 318, Project No. P205405

RE: Medicare and Medicaid Programs: Patient Protection and Affordable Care Act; Interoperability andPatient Access for Medicare Advantage Organization and Medicaid Managed Care Plans, State MedicaidAgencies, CHIP Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans in theFederally-facilitated Exchanges and Health Care Providers

RE: Medicare Program; Revisions to Payment Policies under the Physician Fee Scheduleand Other Revisions to Part B for CY 2019; Medicare Shared Savings ProgramRequirements; Quality Payment Program; and Medicaid Promoting InteroperabilityProgram

Re: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2019 Rates; Proposed Quality Reporting Requirements for Specific Providers; Proposed Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (Promoting Interoperability Programs) Requirements for Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals; Medicare Cost Reporting Requirements; and Physician Certification and Recertification of Claims

RE: CMS: Innovation Center New Direction RFI

RE: 2018 Interoperability Standards Advisory (ISA)

RE: HHS DRAFT Strategic Plan FY 2018-2022

RE: 21st Century Cures Act Trusted Exchange Framework and Common Agreement Public Comments

Re: Medicare Program; CY 2018 Updates to the Quality Payment ProgramDocket No. CMS-2017-0082