National Partnership for Women & Families

Regulatory Letters and Resources for the Administration

Once laws are passed, it’s up to the relevant federal agency to determine how they are implemented. As the agency defines rules for each law, we comment and urge them to keep your best interests in mind.

2013 Regulatory Letters

Accelerating Health Information Exchange and Interoperability (April 2013)
We know that patients and families want their providers to talk to each other and share health information. As EHRs and other forms of health IT become more commonplace, it is equally important that these systems are able to communicate with each other — otherwise known as interoperability. This comment letter offers consumer input on the question of how best to advance interoperability and health information exchange in the health care system.

Proposed Criteria for Stage 3 Meaningful Use (January 2013)
Under the Recovery Act of 2009, Congress provided significant public funding to stimulate provider adoption and “meaningful use” of health information technology (health IT). This takes the form of a three-stage incentive program administered through Medicare and state Medicaid programs. Whether or not a provider is a meaningful user of health IT is determined according to specific criteria finalized through the regulatory process. This letter offers the consumer perspective on proposed Stage 3 advancements in the definition of meaningful use, as articulated by the Consumer Partnership for eHealth, a coalition of consumer advocates led by the National Partnership.

Health IT Patient Safety Action & Surveillance Plan (February 2013)
In December 2012, the Office of the National Coordinator for Health IT (ONC) issued the Health IT Patient Safety Action & Surveillance Plan for public comment. The Action Plan makes several important recommendations to promote the use of health IT to make care safer, as well as continuously improve the safety of health IT itself.

2012 Regulatory Letters

Stage 2 Meaningful Use Notice of Proposed Rulemaking (May 2012)
Comments from members of the Consumer Partnership for e-Health and the Campaign for Better Care on the proposed criteria for Stage 2.

2011 Regulatory Letters

Proposed Criteria for Stage 2 Meaningful Use (February 2011)
Comments from members of the Consumer Partnership for e-Health and the Campaign for Better Care on proposed criteria for Stage 2 of Meaningful Use.

2010 Regulatory Letters

Personal Health Records and Emerging Technologies (December 2010)
Comments from members of the Consumer Partnership for e-Health to the Office of the National Coordinator on consumer expectations and education regarding personal health records and related emerging technologies.

Quality Measure Concept Prioritization (December 2010)
Comments from members of the Consumer Partnership for e-Health and the Campaign for Better Care directing the federal government to invest in the development of measures that fill certain "gap areas" with the most potential for advancing patient outcomes and values — in particular, new kinds of measures that enable us to assess the patient-centered dimensions of quality supported by the meaningful use of health IT and advanced by the new models of care delivery and payment created by the Affordable Care Act (ACA).

Privacy & Security Concerns Related to Proposed Health Claims Data Warehouse (October 2010)
Collaborative comments from members of the Consumer Partnership for e-Health to the Office of Personnel Management expressing privacy and security concerns regarding a proposed Health Claims Data Warehouse.

Privacy Concerns Related to New Appeals Processes (September 2010)
Comments from the National Partnership for Women & Families and the Center for Democracy & Technology on the Department of Health and Human Services’ Interim Final Rule implementing new requirements relating to internal claims and appeals and external review processes for group health plans and health insurance coverage.

Modifications to the HIPAA Privacy Rule (September 2010)
Collaborative comments on the Department of Health and Human Services’ Office of Civil Rights’ Proposed Rule detailing modifications to the HIPAA Privacy, Security, and Enforcement Rules.

Accounting of Disclosures (May 2010)
Comments from members of the Consumer Partnership for e-Health to the Department of Health and Human Services’ Office of Civil Rights’ regarding modifications to the HIPAA Privacy Rule’s provisions on accounting of disclosures of personal health information.

Open Letter on Meaningful Use (April 2010)
Open letter to the administration and congress from the consumer and employer communities supporting the robust proposed definition of meaningful use, and stating the critical importance of maintaining elements of the proposed rule that are most likely to improve health outcomes and reduce costs.

Standards for EHRs (March 2010)
Collaborative comments on the Office of the National Coordinator’s Interim Final Rule on the initial set of standards, implementation specifications, and certification criteria for EHR technology.

Proposed Stage 1 Meaningful Use Rule (March 2010)
Comments from members of the Consumer Partnership for e-Health on the Centers for Medicare & Medicaid Services’ Proposed Rule detailing incentive payments for the meaningful use of certified EHR technology.

2009 Regulatory Letters

Breach Notification Requirement (October 2009)
Comments from members of the Consumer Partnership for e-Health on the Department of Health and Human Services’ Office of Civil Rights’ Interim Final Rule instituting requirements for the notification of breaches of unsecured protected health information.

Health IT Policy Committee’s Meaningful Use Recommendation (June 2009)
Comments from members of the Consumer Partnership for e-Health to the Office of National Coordinator regarding the Health IT Policy Committee’s proposed definition for meaningful use.

Regional Extension Centers (June 2009)
Comments from members of the Consumer Partnership for e-Health in response to on the Department of Health and Human Services’ draft description of a program for establishing regional extension centers (RECs) to assist providers seeking to adopt and become meaningful users of health IT.

Consumer Engagement (May 2009)
Consumer Partnership for e-Health Statement to the National Committee for Vital and Health Statistics regarding leveraging health IT to support meaningful consumer engagement and improved health.

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