On January 4, 2021 NYeC submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the Reducing Provider and Patient Burden by Improving Prior Authorization Processes and Promoting Patient Access to Electronic Health Information Proposed Rule. This Proposed Rule builds on CMS’ 2020 Interoperability and Patient Access Rule and places new requirements on Medicaid and CHIP fee-for-service and managed care plans, and Qualified Health Plans on the Federally Facilitated Exchanges to build and maintain FHIR-based Application Programming Interfaces (APIs) that will improve the electronic exchange of healthcare data and streamline processes related to prior authorization.
NYeC’s comments support CMS’ goals to advance interoperability through standards‐based APIs, but caution that APIs in and of themselves will not solve all of the challenges to seamless data exchange. Meaningful exchange via APIs requires robust data governance, coordination, and a foundation of reliable data. Health Information Exchanges (HIEs) and Health Information Networks (HINs), like the SHIN‐NY, have a demonstrated history of providing these services and should be central to any nationwide interoperability strategy.
NYeC’s comments and recommendations regarding the Proposed Rule reflect NYeC’s continued commitment to partnering with the Administration to develop policy solutions that will support a cohesive, nationwide strategy that leverages HIEs to enable secure, meaningful, and scalable data sharing across all sectors of care.