June 23, 2020 – CommonWell Health Alliance submitted comments to the Office of Inspector General (OIG) regarding its Proposed Rule to amend and update Civil Money Penalty Rules of the Department of Health and Human Services (HHS), published on April 24, 2020.
CommonWell believe the ONC’s Strategic Plan aligns with our mission and vision. In our submission, we provided specific comments surrounding Timing and Effective Dates, recommending the OIG adjust its enforcement timelines to align with the ONC’s Enforcement Discretion Dates and Timeframes, and the Appeals Process, supporting the inclusion of an appeal process. Additionally, we asked for further clarification around certain points pertaining to Violation Definitions and Examples as well as Determinations regarding the Amount of Penalties.
Overall, CommonWell remains committed to patient-centric interoperability on a national scale with the goal of ubiquitous, secure exchange of clinical data to the benefit of providers, patients, payers, public health and all other stakeholders in health care and beyond. We support the mission and vision HHS has constructed with its recent interoperability rulemaking and further appreciate the challenge of developing appropriate penalties. We believe transparency is the key to an efficient and effective regulatory environment and look forward to any additional clarification that can be included in the final rule and any associated guidance documents.