PEPC appreciates the opportunity to provide input on the Request for Information (RFI) on Electronic Event Notifications for Value-Based Care and Care Coordination included in the Interoperability Standards and Prior Authorization for Drugs Proposed Rule. As outlined in our letter, urge CMS to ensure that all policy is designed with small and independent physician practices in mind, considering their unique circumstances and instances where technical assistance and other resources may be necessary.
Health technology plays an essential role in supporting health care providers in value-based care arrangements. Small and independent practices are more resource constrained and struggle to develop the data infrastructure, including the Admit, Discharge, and Transfer (ADT) feeds necessary to receive and act on patient event notifications, and the associated supports necessary to fully leverage data and technology. PEPC appreciates the Administration’s commitment to reducing burden and promoting seamless and secure flow of health information between patients, providers, and payers, which will be particularly beneficial to small and independent physician practices and further support CMS’ goals of increasing health care competition and participation of independent physician practices in value-based care models.
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