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Former National Coordinators Applaud Interoperability Final Rules

by Aledade

Today, six of the United States' former National Coordinators for Health Information Technology, including Aledade CEO and co-founder Farzad Mostashari, wrote to the current National Coordinator and the Administrator of the Centers for Medicare and Medicaid Services applauding the new final rules released by the U.S. Department of Health and Human Services on health IT interoperability.

Former coordinators call the publication of these rules a "pathbreaking achievement"

March 10, 2020 


Submitted Electronically and by Hand

Donald Rucker, M.D.
National Coordinator for Heath Information Technology
Office of the National Coordinator (ONC)
Department of Health and Human Services
Attn: 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Proposed Rule
Mary E. Switzer Building
Mail Stop: 7033A
330 C Street SW 
Washington, DC 20201

The Honorable Seema Verma
Administrator Centers for Medicare & Medicaid Services (CMS)
Department of Health and Human Services
Attn: CMS-9115-P
P.O. Box 8016
Baltimore, MD 21244-8016

Dear Dr. Rucker and Administrator Verma, 

We are writing to congratulate you on the publication of the final rules relating to promoting the interoperability of health information in the United States: "Interoperability and Patient Access" (CMS 9115-F) and "21st Century Cures Act: Interoperability, Information Blocking and the ONC Health IT Certification Program" (RIN 0955-AA01), together the "Interoperability Rules." 

Simply put, we view the publication of the final Interoperability Rules as a pathbreaking achievement that, when implemented, will be a key to unlocking the ability to make tremendous progress in creating greater value for consumers in our health care system. 

As former public servants who have each had the honor of serving as National Coordinator over the past 15 years - under both Republican and Democrat-led administrations - we know well the challenges to creating greater consumer access to health information, as well as the unnecessary cost in dollars and lives that comes from a health system where information is siloed. We also know well the tremendous missed opportunities that come from not being able to apply advanced analytics to our health data to identify early the onset of disease and to support care coordination and advanced prevention initiatives. 

There is no doubt that in the last 15 years there have been many accomplishments in advancing the use of health information to improve care, particularly the forward leaps in technology standardization and technical specifications and the more widespread adoption and use of electronic health records. But even with these notable accomplishments, we still face major obstacles in creating the cultural shift necessary to make information portability and sharing an expected attribute of our remarkable health care system, rather than a challenge that often frustrates consumers and providers alike. 

The Interoperability Rules give us strong reason to believe the obstacles that inhibited information sharing will now be overcome and we will indeed experience a paradigm shift that enables far greater consumer access and control over health information, as well as supports tremendous leaps in our ability to foster innovation in how we pay for and deliver health care services. Among the critical features of the Interoperability Rules are: 

  • the adoption of HL7 Fast Healthcare Interoperability Resource (FHIR) as the foundational standard for open application programming interfaces (APIs);
  • a requirement that health plans in Medicare Advantage, Medicaid and CHIP as well as plans on the Federal exchanges use FHIR-based APIs to make patient claims and other health care information available to patients;
  • the establishment of a new Condition of Participation to ensure hospitals participating in Medicare and Medicaid are promoting the health and safety of patients by advancing interoperability requirements, including initially the use of electronic patient notifications as a tool for improving transition of care between settings;
  • the development and enforcement of information blocking rules, designed to ensure patient access to their clinical information in a timely and cost-effective manner. 

We understand that the implementation of the Interoperability Rules will require much collaboration and education and some navigation of emerging issues that are sure to arise. As we embark on this new terrain, however, we think it is important to pause for a moment and applaud the tremendous effort and leadership that brought us to this moment. We remain committed to working with you in the months and years ahead.


Dr. David Blumenthal 

Dr. David Brailer 

Dr. Karen DeSalvo

Dr. Robert Kolodner 

Dr. Farzad Mostashari 

Dr. Vindell Washington