EHR Association

several recommendations with the ONC and OIG on behalf of our member companies and the healthcare organizations they serve. These included requests for practical guidance on how best to facilitate access, exchange, and use of EHI, and an initial two-year “learning period” following the rule’s effective date, during which the OIG could exercise enforcement discretion by guiding compliance through corrective action plans and other education-based mechanisms. Modernizing Public Health Reporting EHRA members have also prioritized efforts to advance the nation’s public health objectives. The COVID-19 pandemic made it abundantly clear that a truly effective public health response requires leveraging EHRs as a critical source of patient data. To maintain forward momentum toward eliminating the challenges that impacted the nation’s pandemic response, we developed several recommendations on the role of EHRs and health IT, most notably related to reporting infrastructures. First, ensuring that the necessary reporting infrastructures are in place requires a more homogeneous approach. While the data itself is consistent, variances come into play when conditions within individual jurisdictions require different levels and types of reporting. This creates complexities that hamper the ability to get data where it needs to be, in the right format, and with the appropriate level of immediacy. The solution requires discouraging jurisdictional variation in public health surveillance and monitoring; eliminating the wide variety of reporting requirements and data needs that have proved to be a major barrier to public health officials’ success. Establishing a national public health data model that aligns data requirements across jurisdictions will further reduce variations that impede rapid scaling and deployment of EHRA