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The Center for Democracy and Technology (CDT), through its Health Privacy Project, promotes comprehensive privacy and security policies to protect health data as information technology is increasingly used to support the exchange of health information. CDT, along with those listed at the end of this letter, submits these comments in response to the July 7, 2010 notice of proposed rulemaking (NPRM) issued by the Dept. of Health and Human Services (HHS) Office of Civil Rights.
The Affordable Care Act includes a number of important new consumer protections, commonly referred to as “The Patients Bill of Rights.” These protections will, beginning this year, provide children with pre-existing conditions access to coverage, and in 2014 provide all people with access to coverage regardless of their health status; ensure that coverage continues to protect people who face serious and costly illnesses by restricting and eventually eliminating annual and lifetime dollar limits; prevent abusive retroactive cancellations of coverage; help people choose providers that will ensure continuous and coordinated care; and improve coverage for people who face an emergency and must obtain treatment out-of-network.
The undersigned organizations are members of the Consumer Partnership for e-Health (CPeH), a coalition of consumer, patient, and labor organizations working on both the national and local levels that, since 2005, has served as a strong and diverse consumer voice advocating for patient-centered policies related to health information technology (HIT). We submit these comments in response to the request for information (RFI) on the implementation of the modifications to the HIPAA Privacy Rule’s Accounting of Disclosures provisions required by Title XIII, Subtitle D of the American Recovery and Reinvestment Act of 2009 (ARRA).
Under the Affordable Care Act, plans existing on or before March 23, 2010 may qualify for “grandfathered status” and not be subject to many of the new insurance market reforms, like coverage of preventive health benefits without cost sharing and strengthened internal and external appeals processes.
On behalf of the 56 undersigned consumer, labor union and employer organizations, we wish to express our sincere gratitude for the strong direction of the final meaningful use rule that was released by the Centers for Medicare & Medicaid Services (CMS) on July 13.
Health information technology (health IT) provisions of the American Recovery and Reinvestment Act of 20091 (Recovery Act) set the expectation that individuals will be able to get electronic copies of pertinent health information about themselves.
Good afternoon Mr. Chairman, Congressman Herger, and distinguished members of the subcommittee. My name is Christine Bechtel and I am Vice President of the National Partnership for Women & Families. Just over a year ago, I was also appointed by the Government Accountability Office (GAO) to serve on the Health IT Policy Committee, where I represent the consumer perspective.
Good afternoon Mr. Chairman, Congressman Shimkus and members of the subcommittee. My name is Christine Bechtel and I am Vice President of the National Partnership for Women & Families. Just over a year ago, I was also appointed by the Government Accountability Office (GAO) to serve as a consumer representative on the Health IT Policy Committee.
Susan Crowson is a family caregiver from Maryland who is part of the Campaign for Better Care. She looks after her father, “Pop,” who has Alzheimer’s disease, heart arrhythmia, prostate problems, low blood platelets, and is highly susceptible to other infections.
On July 13, 2010 the Centers for Medicare & Medicaid Services (CMS) released a final rule detailing incentive payments for the meaningful use of certified Electronic Health Record (EHR) technology. With this rule, CMS has ensured that tax-payer-funded incentive payments do not simply go to digitizing paper records but to actually improving the quality of care.
The Campaign for Better Care is a multi-year initiative focused on improving delivery and payment for health care services in ways that enhance quality and coordination of care for older patients and individuals with multiple health problems.
As representatives of consumers, patients, employers, clinicians, health plans, and other health care providers, we write in strong support of the nomination of Don Berwick, M.D., to the position of Administrator of the Centers for Medicare and Medicaid Services (CMS). We urge Congress to act quickly to confirm Dr. Berwick to this important position.
The Affordable Care Act calls on the Department of Health and Human Services (HHS) to develop an insurance Web portal through which individuals and small businesses can identify affordable health insurance coverage options in their State.
The HITECH Act provisions of the American Recovery and Reinvestment Act of 2009 (“ARRA”) established Medicare and Medicaid incentive payments to providers who are meaningful users of certified Electronic Health Record (EHR) technology.
Health information technology (HIT) provides opportunities to increase health care quality, efficiency, and access to services. But along with the promise of digital tools come concerns about privacy—especially when sensitive health information is involved.
Individual consumers are the ultimate payers of all health care - and health coverage - costs. Even workers in large businesses, whose employer contributes 100% of the insurance premium for the employee, understand that their wages are reduced to reflect the cost of health coverage offered through their employer.
As you craft the final criteria for meaningful use incentives, the consumer and employer communities wish to convey our strong belief that public funding used to incentivize provider adoption of HIT must result in improvements in the quality and affordability of care, not just the presence of technology in provider settings. The incentive program created by HITECH is a major investment that can help put in place the infrastructure necessary not just for better individual health care, but also for system-wide reform.
A number of key changes to the insurance market under the Affordable Care Act go into effect in 2010. Before any regulations were released, we partnered with other consumer advocacy organizations to write to the Administration about these “immediate” insurance market reforms to ensure that implementation was guided first and foremost by the needs of patients and consumers.
The 21 undersigned organizations are members of the Consumer Partnership for e-Health (CPeH), a coalition of consumer, patient, and labor organizations working on both the national and local levels that, since 2005, has served as a strong and diverse consumer voice advocating for patient-centered policies related to health information technology (HIT).
The release of the Notice of Proposed Rulemaking (NPRM) for the Centers for Medicare and Medicaid Services' (CMS) incentive program for the Meaningful Use of electronic health records (EHRs) marks a major, positive step forward in the nation's efforts to improve health and health care by putting modern information technology (IT) tools at the fingertips of medical professionals and consumers alike.
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