Policy letter to CMS on their Proposed Regulations To Implement 21st Century Cures Act’s Provisions

The proposed regulations take a giant leap forward for interoperability and health care by requiring standardized application programming interfaces (APIs) for payers and plans in CMS’s programs.  We applaud and wholeheartedly support this requirement as an essential prerequisite for moving digital health forward and establishing a national digital health ecosystem that integrates clinical and payment information to enable and evaluate value-based health care.   Payers likewise need to use these API standards for better interoperability and patient access and better health care and value.

CMS also proposes to require that covered payers make educational resources on privacy and security available to enrollees and beneficiaries.  We support this requirement.  While these resources will help enrollees and beneficiaries, we suspect that they will help payers, providers, vendors, and others as well.  We also recommend that CMS require covered payers to use ONC’s Model Privacy Notice, both as an available, consumer-friendly tool to help educate enrollees and beneficiaries, and as a notice for any software applications the payer makes available to its participants.