HIMSS NCA Chapter Webinar Series - The CARES Act and Beyond: Federal & State Health IT Policy in Response to COVID-19
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HIMSS NCA Chapter Webinar Series
The CARES Act and Beyond:
Federal & State Health IT Policy in
Response to COVID-19
April 29, 2020
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4
HIMSS NCA April Webinar
Hear from the HIMSS Government Relations team on how the federal
and state governments are responding to COVID-19, including through
the CARES Act and agencies as well as upcoming activities.
Moderator
• Mandy Peckham, HIMSS NCA Programs Co-Chair
Panelists
• David Gray
• Senior Manager, Government Relations & Connected Health
Policy, HIMSS
• Jeff Coughlin, MPP
• Senior Director, Government Relations, HIMSS
• Valerie Rogers, MPH
• Director, Government Relations, HIMSS
• Ashley Delosh, JD
• Senior Manager, Government Relations, HIMSS
The CARES Act and Beyond: Federal
and State Health IT Policy in
Response to COVID-19
HIMSS Government Relations Team
COVID-19 Policy Update
Wednesday, April 29th 2020 1:00-2:00 PM EST
6
Coronavirus Aid, Relief, and Economic
Security (CARES) Act
and Federal Policy Responses to
COVID-19 Pandemic
7
Congressional Action to COVID-19
COVID #1 - Coronavirus Preparedness and Response Supplemental Appropriations Act
• Signed into law March 6, 2020
• Provided $8.3 billion in emergency funding for federal agencies to respond to COVID-19 pandemic
• Granted HHS Secretary waiver authority over 1834(m) originating site restrictions on telehealth
• Allowed rural AND urban sites, and beneficiary’s home, to serve as eligible originating sites
• Required providers to have a Medicare-established relationship with beneficiary in previous 3 years
COVID #2 - Families First Coronavirus Response Act
• Signed into law March 18, 2020
• Focused on paid leave, free coronavirus testing, protection for public health workers, and expanded benefits for children and
families
• Modified “Qualified Provider” language for Medicare telehealth services to allow required preexisting relationship to be
established outside the Medicare program
COVID #3 - Coronavirus Aid, Relief and Economic Security (CARES) Act
• Signed into law March 27, 2020
• Over $2 trillion relief package focused on healthcare delivery, state & local funding, business and non-profit relief, and overall
economic stimulus.
• Provides financial relief, advanced reimbursement payments, and expanded telehealth flexibility
COVID #3.5/4 - Paycheck Protection Program and Health Care Enhancement Act
• Signed into law April 24, 2020
• $484 billion package for the Paycheck Protection Program and Emergency Economic Injury Disaster Loan program, Hospital
and provider payments, and COVID-19 testing
COVID #5, 6 - ???
8
CARES Act - Overview
• Third, and biggest, Coronavirus relief package signed into law.
• Largest stimulus package in modern history, more than double the 2009
stimulus
• The bill provided direct relief to individuals, families, businesses, and
healthcare providers who have been impacted by the COVID-19
Pandemic
• Five key funding provisions or “buckets”:
• $377 billion for small businesses, including Paycheck Protection Program (which
ran out on April 16th and was replenished with the latest relief bill)
• $500 billion for big business and at-risk industries (airlines, cargo, national security)
• $500-600 billion in direct aid to individuals and families
• $340 billion to state and local governments
• $180 billion to health and other public services
9
CARES Act - Key Healthcare, Health IT, and Funding Provisions
• CDC Public Health Data Modernization - Authorizes $500 million for public health data surveillance and infrastructure
modernization efforts at the CDC, state, and local health departments
• Public Health and Social Services Emergency Fund – Provides $100 billion for our health system to prevent, prepare for, and
respond to coronavirus, domestically or internationally.
• 42 CFR Part 2 Changes
• Amends regulations governing the confidentiality and disclosure of substance use disorder records, including allowing certain
re-disclosures to covered entities, business associates, or other programs subject to HIPAA after obtaining the patient’s prior
written consent.
• HHS Secretary shall issue guidance within 180 days on the sharing of patients’ protected health information related to COVID-
19, including guidance on compliance with HIPAA regulations and applicable policies.
• Community Health Centers and Community Mental Health Services Demonstration – extends funding for these programs (and
others) through November 30, 2020
• Coronavirus Relief Fund - Provides $150 billion to States, Territories, and Tribal governments to use for expenditures incurred due to
the public health emergency with respect to COVID-19 in the face of revenue declines,
• Increased Reimbursement and Additional Waivers and Flexibilities:
• Temporarily suspends 2% Medicare sequestration for the period May 1, 2020 through December 31, 2020
• Medicare add-on payments for inpatient hospital COVID-19 patients, increasing the payment that would otherwise be made
to a hospital for treating these complex patients by 20 percent.
• Gives acute care hospitals flexibility during the COVID-19 emergency period to transfer patients out of their facilities and into
alternative care settings (such as post-acute care) in order to prioritize resources needed to treat COVID-19 cases
• Provides additional funding to address issues around Smart Communities, SDOH, Precision Medicine
10CARES Act - Medicare Telehealth Takeaways (*limited to COVID-19 PHE)
• HRSA Grants (Sec. 3212): - Reauthorizes HRSA’s grant programs that promote the use of telehealth. The bill
authorizes $29 million annually through FY 2025, with at least 50% of the funds awarded for projects in rural areas
• *HSAs for Telehealth Services (Sec. 3701) - Allows for High Deductible Health Plans (HDHP) with a Health Saving
Account (HSA) to cover telehealth services prior to a patient reaching the deductible.
• *Medicare Telehealth Flexibilities (Sec. 3703) - Removes the requirement that a provider must have treated the
patient in the past three years. Further, the section expands the Secretary’s waiver authority over all 1834(m)
statutory restrictions.
• *Telehealth Distance Sites (Sec. 3704) - Allows Federally Qualified Health Centers and Rural Health Clinics to serve
as a distant site for telehealth services during the COVID-19 emergency.
• *Home Dialysis Patients Waiver (Sec. 3705) - Eliminates the requirement that a nephrologist conduct some of the
periodic evaluations of a patient on home dialysis face-to-face during the COVID-19 emergency period.
• *Hospice Care Telehealth Waiver (Sec. 3706) - Allows qualified providers to use telehealth to fulfill the hospice
face-to-face recertification requirement during the COVID-19 emergency period.
• *Telecommunications, Remote Patient Monitoring and Telehealth Waivers (Sec. 3707) - Directs HHS to issue
guidance encouraging the use of telecom systems, including RPM, to furnish home health services during the
COVID-19 emergency.
• Federal Communications Commission - Provides $200 million for the FCC to support the efforts of providers by
providing telecommunications services, information services, and devices necessary to enable the provision of
telehealth services.
11Congress gave HHS all this new
authority, but what does it all mean?
12Medicare FFS Telehealth Reimbursement Before COVID-19
Background
SECTION 1834(m) of the Social Security Act (42 U.S.C. 1395m(m))
• “Telehealth” (synchronous) vs. “Store-and-forward” (asynchronous)
• Telehealth must use an interactive audio and video telecommunications system permitting real-time
communication; store-and-forward only permitted for federal demonstration programs in Alaska or Hawaii
• Eligible Telehealth Services
• CMS telehealth services list limited to specific HCPCS/CPT codes
1834(m) Restrictions
• Geographic location
• Patient must be in a rural health professional shortage area or non-Metropolitan Statistical Area
• Originating sites (where patient is located)
• Generally, only facilities including a physicians office, critical access hospital, RHC, FQHC, hospital, and skilled nursing facility can
serve as an originating site
• Eligible physicians and practitioners,
• Only Medicare-defined “physicians” and “practitioners” are eligible: physicians, nurse practitioners, physician assistants, nurse
midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals.
• Excludes professionals like physical, respiratory, and occupational therapists.
• Distant sites (where provider is located)
• FQHC’s and RHC’s cannot act as distant sites
13Other Medicare FFS Virtual Care Tools:
Starting with CY2019 Physician Fee Schedule Changes
Communication Technology-Based Services (CTBS) aka Non-Telehealth Digital Health
Tools
All of these services:
• Require a preexisting relationship with the patient,
• Must be patient-initiated,
• Cannot originate from a related service provided within previous 7 days or lead to a service or
procedure within the next 24 hours or soonest available appointment
• Are not considered telehealth and are not subject to geographic or originating site restrictions
• Brief communication technology-based service (e.g. virtual check-in) - HCPCS code
G2012
• E-visits – HCPCS codes G2061-2063 – non face-to-face, not synchronous
• patient-initiated communications with their doctors using online patient portal
• 5-10 minutes of time spent
• Remote evaluation of pre-recorded patient information - HCPCS code G2010 –
9Other Medicare FFS Virtual Care Tools:
Starting with CY2019 Physician Fee Schedule Changes
• Remote Patient Monitoring
• RPM is the collection and interpretation of physiological data digitally stored and
transmitted by a patient to a health care profession
• Examples of vital signs include weight, pulse oximetry, blood pressure, heart rate, respiration
rate, blood glucose levels, etc.
• CPT Coverage - Remote monitoring of physiologic parameter(s) (e.g. Weight, blood pressure, pulse
oximetry, respiratory flow rate)
• CPT 99453 - Initial; set-up and patient education on use of monitoring equipment
• CPT 99454 - initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days
• CPT 99457 – Remote physiological monitoring treatment management services; 20 minutes of clinical
staff/physician/other qualified healthcare professional time in a calendar month requiring interactive
communication with the patient/caregiver
• CPT 99458 – Each additional 20 minutes of time
• BIG CAVEAT – RPM reimbursable for treating chronic conditions
• Confusion among providers if RPM codes can be used to treat patients with acute
conditions, like COVID-19.
10CMS Relaxes Requirements in Response to COVID-19
HHS Secretary Granted Waiver Authority over all 1834(m) restrictions
• Starting on March 6, 2020 and lasting for the duration of the public health
emergency:
• Geographic limitations are waived(urban and rural)
• Originating site restrictions are waived – any healthcare facility and a patients home
are now eligible originating sites
• Providers can furnish services to both new and established patients
• Added over 80 additional “telehealth services” that are eligible
• Examples include ED consultations, initial nursing facility and hospital inpatient services, discharge
visits, and home visits, therapy services, and many other inpatient and outpatient services
• Audio-video requirements remain, but the use of telephones that have both audio and
video capabilities (e.g. smartphones) are allowed
• New billing rules pay telehealth services at same rate as in-person
16CMS Relaxes Requirements in Response to COVID-19
(continued)
• CTBS – Virtual Check-ins and E-visits
• Eligible for new and established patients
• Broadens eligible providers and practitioners to include LSW, OT, PT, SLP
• Must still be patient initiated, but provider may educate patient and consent can be
obtained annually
• Audio-Only (Telephone) Services
• Brand new benefit in response to COVID-19
• Not considered telehealth since there is no video component required
• No geographic or originating site requirements
• Eligible for new and established patients
• CPT Codes 99441-99443, 98966-98968
• Reimbursed at a lower rate than telehealth services
• Remote Patient Monitoring Services
• Available for treating all chronic AND acute conditions, including treating COVID-19 –
change is permanent (not just limited to PHE)
17Additional HHS Waivers and Flexibilities
• HHS Office of Inspector General (OIG)
• Notified physicians that they will not be subject to administrative sanctions for reducing or
waiving any cost sharing obligations federal health care program beneficiaries may owe for
telehealth services furnished (Federal anti-kickback statutes)
• Covers various modalities, including telehealth visits, virtual check-in services, e-visits, monthly remote care
management, and monthly remote patient monitoring
• HHS Office of Civil Rights and HIPAA Requirements
• OCR will exercise enforcement discretion and waive penalties for HIPAA violations against health
care providers that use platforms such as Skype and FaceTime for telehealth for the duration of
the public health emergency
• Must serve patients in good faith
• In-State Telehealth Licensure Requirements
• In general, a provider must be licensed in the state where the patient is located at the time of
treatment
• CMS has waived this requirement for Medicare patients
• States can request a Medicaid waiver from CMS
• According to the Federation of State Medical Boards, 44 states have waivers in place for
their Medicaid programs for this purpose
18CMS Expands Accelerated and Advance Payment
Program
• Program focused on increasing cash flow to a broad group of Part A and Part
B* providers. Only for the duration of the public health emergency
• Intended to provide necessary funds when there is a disruption in claims submission
and/or claims processing.
• On April 26, CMS announced that it is reevaluating the amounts that will be paid under
its Accelerated Payment Program and suspending its Advance Payment Program to
Part B suppliers effective immediately.
• Since expanding the AAP programs on March 28, 2020:
• CMS approved over 21,000 applications totaling $59.6 billion in payments to Part A providers,
which includes hospitals.
• For Part B suppliers, including doctors, non-physician practitioners and durable medical
equipment suppliers, CMS approved almost 24,000 applications advancing $40.4 billion in
payments.
• The AAP programs are not a grant, and providers and suppliers are typically required to
pay back the funding within one year, or less, depending on provider or supplier type.
19CMS Actions Granting Quality Payment Program
Flexibility
• Quality Payment Program and Quality Reporting Program/Value-Based Purchasing
• Deadline for 2019 submission extended until April 30, 2020
• COVID-19 has triggered implementation of the MIPS Automatic Extreme and
Uncontrollable Circumstances (E&UC) policy
• Clinicians who don’t submit data will automatically receive a neutral payment
adjustment in 2021
• The automatic policy does not apply to groups or virtual groups
• Required to complete an application if data has already been submitted
• Granting exceptions from reporting requirements and extensions for clinicians and
providers participating in Medicare quality reporting programs for upcoming measure
reporting and data submission.
20Federal Communications Commission Response to
COVID-19
• COVID-19 Telehealth Program
• This program will provide $200 million in funding as part of the CARES Act, to help
health care providers provide connected care services to patients at their homes or
mobile locations in response to COVID-19.
• Limited to non-profit and public eligible health care providers that fall within the categories
of health care providers in section 254(h)(7)(B) of the 1996 Act.
• Connected Care Pilot Program
• This separate three-year Pilot Program will provide up to $100 million of support from
the Universal Service Fund (USF) to help defray health care providers’ costs of
providing connected care services and to help assess how the (USF) can be used in
the long-term to support telehealth.
21ONC and CMS Announce Enforcement Discretion for
Interoperability Regulations
• Period for enforcement discretion around implementation of the final interoperability
regulations to provide all health system stakeholders with additional time to focus on
addressing the COVID-19 Pandemic
• Agencies are allowing compliance flexibilities for many of the provisions
• Regulations to be formally published May 1, 2020
• Enforcement discretion covers certain parts of CMS Interoperability Regulation
• ADT Conditions of Participation extended by six months, to become effective May 3, 2021
• Patient Access API and Provider Directory API policies to begin July 1, 2021
• Other policies implemented and enforced on schedule
• ONC effective date for many regulatory provisions comes 60 days later, or June 30, 2020
• Compliance occurs six months from its publication, or November 2, 2020
• This date is when specific compliance requirements start for several Conditions of Certification, etc
• ONC is instituting an additional three-month period of enforcement discretion, meaning that
February 1, 2021, would be the earliest date for enforcement around many provisions
22HHS OIG Issues Proposed Regulation for Information
Blocking CMPs
• Investigating and taking enforcement action against entities that engage in information blocking is
consistent with OIG’s history
• Actors are defined as health IT developers, HINs, and HIEs
• HHS has the authority to impose CMPs up to $1 million per violation on these actors
• OIG’s CMP authority does not extend to health care providers
• OIG would refer provider to the appropriate agency for appropriate disincentives
• OIG is proposing to use its discretion to choose which complaints to investigate and only select
cases for investigation that are consistent with its enforcement priorities
• OIG’s enforcement priorities will include conduct that resulted in, is causing, or had the potential to cause
patient harm
• OIG believes that it lacks the authority to pursue information blocking CMPs against actors who it concludes
did not have the requisite intent
• OIG is not planning to bring enforcement actions for innocent mistakes
• Enforcement of the information blocking CMPs will not begin until this regulation is effective
• Effective date is 60 days from the date of final publication
• Until that time, OIG plans to exercise enforcement discretion
23COVID-19 US State & Local Policies
for Health IT Preparedness &
Response
24HIMSS Supports Global Health IT Response Efforts for
the COVID-19 Pandemic
• HIMSS continues to monitor current CDC recommendations and funding supporting response to COVID-19 Response
$631 million to 64 jurisdictions through the existing Epidemiology and Laboratory Capacity for Prevention and Control of
Emerging Infectious Diseases (ELC) cooperative agreement.
• HIMSS engaged the ONC and EHRA to determine how to improve outbreak management functioning (like electronic
contact tracing) within commercial and CDC GOTS (NEDSS Base System) surveillance systems
• Taiwan's Infection Control Strategies Supported by Technology and Digital Health to Fight the COVID-19 Pandemic
• April 30, 2020, 06:00 PM in Taipei; 6:00 AM ET
• HIMSS China Team is monitoring the response of this issue on the ground and documenting lessons learned around vital
strategies
The team is leveraging big data for screening low-risk groups with a possible contact history and is also considering how
internet based apps and platforms can be employed to deliver cost-effective online screening and consultation to a
larger low-risk population
Working to combine other sources of data, could help track down and manage the high-risk population with precision
The team released a recent article about current efforts using big data and screening tools that can be found at
https://mp.weixin.qq.com/s/N36WQDJf3MqhjCWuuHKv8Q
• HIMSS was successful in helping to secure $50 million for the first year of a multi-year effort to support the modernization of
public health data surveillance and analytics at CDC and state and local level.
Explore with states on the best use of these funds to address immediate threats including COVID-19 and that support
foundational infrastructure that helps all conditions/hazards
25Immediate State &
Local Strategies to
Combat the COVID-
19 Pandemic &
Reopening Society
26Shift to Support Home and Community-based
Services
• 1915(c) Waivers
As described in Appendix K which may be utilized by states during emergency
situations to request amendment to approved 1915(c) waivers. It includes actions
that states can take under the existing Section 1915(c) home and community-based
waiver authority in order to respond to an emergency.
Other activities may require the use of various other authorities such as the Section
1115 demonstrations or the Section 1135 authorities. This appendix may be
completed retroactively as needed by the state.
State plan authority [Section 1932(a)]
Waiver authority [Section 1915 (a) and (b)]
Waiver authority [Section 1115]
https://www.medicaid.gov/resources-for-states/disaster-response-toolkit/home-community-based-services-public-heath-
emergencies/emergency-preparedness-and-response-for-home-and-community-based-hcbs-1915c-waivers/index.html 22HHS Announces Funding for Initial Resources to a limited
Number of State and Local Jurisdictions in Response to COVID-19
• Using funds provided to CDC through the HHS Secretary's Transfer, CDC will:
• Awarded an initial $25 million cooperative agreement to the states and local jurisdictions
who have borne the largest burden of response and preparedness activities to date. This is an
initial award for those jurisdictions who require immediate assistance for activities such as
monitoring of travelers, data management, lab equipment, infection control, and surge
staffing. Once supplemental funding is provided, support will be provided to all states and
local jurisdictions for a variety of critical public health activities.
• Award an initial $10 million cooperative agreement to state and local jurisdictions to begin
implementation of coronavirus surveillance across the U.S., building on existing influenza
activities and other surveillance systems.
This initial award is for a limited number of jurisdictions. Once supplemental funding is
provided, additional support will be provided to all states and local jurisdictions to enhancing
testing and surveillance.
https://www.hhs.gov/about/news/2020/04/23/updated-cdc-funding-information.html
28Testing
29Testing the most vulnerable populations
• Expand testing capacity across states and population centers
Key suggestions for testing every person diagnosed with pneumonia
Health care workers/first responders
People in nursing homes and other congregate facilities, their staff and contacts
People identified as a part of a cluster of disease that could be Covid-19 (e.g. factory workers)
• Strengthen public and private collaborations
Expansion and coordination across public laboratories, university lab and private facilities
Community-based testing…drive-through and walk-up testing sites
Cost sharing and cooperative purchasing and distribution of test kits/tests
• Standardization across different types of testing
New technologies for point-of-care antigen testing and self-administered tests
Serology (antibody) testing
Ensuring public health reporting!
https://www.nga.org/center/publications/health/roadmap-to-recovery /
30Contact
Tracing &
Surveillance
31Strengthen the public health and health data infrastructure by using current relief
funding to prioritize syndromic surveillance, emergency response, and
environmental data with clinical care documentation using standards-based
platforms (e.g. FHIR, etc.).
• Prioritize Syndromic Surveillance (e.g. admission, discharge, and transfer (ADT)
notifications from all hospitals. This data can support efforts to develop situational
awareness related to COVID-19
• States should consider the use of smart health technologies such as artificial intelligence
and machine learning to provide predictive analytics with hourly detection as well as
continuous monitoring for potential outbreaks leading to greater situational awareness and
timelier interventions.
• Public health communications infrastructure is similarly important, and states should take
advantage of the growing availability of mobile phones and internet-based reporting tools
that may inform contact tracing, outbreak and diagnostic reporting, particularly where
traditional surveillance systems are outdated.
32Recent COVID-19 Headlines State & Local Governments Track Cell
Phone Data
33Strengthen
Public Health
Infrastructure
34Mandate by public statute or regulation routine public health data
submission and query by leveraging relief funding that supports
electronic case reporting (eCR), and that enables cross-jurisdiction
sharing of notifiable condition reports.
• Given current COVID-19 data collection and aggregation efforts taking place, states
should leverage easily scalable solutions like the CDC Foundation-supported Digital
Bridge or EHR-lite mechanisms to ensure consistent quality data reporting to the state
health departments and to the CDC. This strategy is vital to ensuring that underserved
and rural communities are able to respond to the COVID-19 crisis.
• States should also consider as a priority, the establishment or expansion of reporting on
additional data elements during emergency declarations such as bed capacity,
workforce, personal protective equipment (PPE), etc., where assessment and
coordination to handle system surge is supported by data.
• Moreover, states should mandate that demographic data is captured and shared with
state and local public health authorities to support contact tracing, hot-spotting, and
informed policy decision making. This activity is especially important as providers
leverage point of care tests.
35Leverage Health Information Exchanges (HIEs) or cross-sector health data sharing
platforms to collect data across sectors including electronic health record data,
emergency room (EMR) encounters, emergency medical services (EMS) data,
public health surveillance data, etc.
• States have the authority to declare and deputize an HIE to collect coronavirus
information and should consider the role HIEs may play in enabling automatic
submission of syndromic surveillance information to the state health department, and
the collection of COVID-19 test data from hospitals, public health labs, EMS systems,
and community test sites (e.g. churches, drug stores, other retailers). Such a process
could reduce the data reporting obligations of providers.
• States may also engage HIEs and local and state epidemiologists to create COVID-19
dashboards that leverage aggregated and anonymized location data from social
media sources and support the creation of disease prevention maps. Concrete
examples of this can be found in the states of Washington and Indiana.
• Moreover, given the socio-economic impacts of COVID-19, states should consider
how HIEs can support clinical and public health workforce needs, care coordination,
and in the management of data related to the Social Determinants Of Health (SDOH),
which are crucial to the delivery of care to vulnerable populations.
36Future Forward – State Health IT & Emergency Response Planning
• Research on the impact of restricted personal
freedoms, including privacy and other human
rights given the outgrowth of surveillance,
potential data exploitation, and misinformation
are being tested across the world.
• Legacy technology and legacy policies (e.g.
remote working, issuing devices)
• Digitization of services (convenience reframed as
essential services)
• A lot of band aids across agencies taking a
siloed approach to modernization of services –
virtual services
• States will need to realize an enterprise strategy
• How many critical health systems are on
outdated IT systems?
o Anticipate modernized systems or
infrastructure packaged in the future Aid
Package
o Also modernizing the business processes that
were reliant on paper processes
37Stay Tuned for Future Updates
VALERIE N ROGERS, MPH
Director, Government Relations
HIMSS
vrogers@himss.org
https://www.himss.org/news/coronavirus
33Questions?
39HIMSS COVID-19 Policy Resources
• CARES Act (PL 116-136) Health Provisions
• CARES Act- Support for Data Elemental to Health Campaign
• Telehealth in the COVID-19 Spotlight
• Remote Patient Monitoring: COVID-19 Applications and Policy Challenges
• States Tackling COVID-19 Using Information and Technology
• In Times of Crisis, HIEs are Front and Center
• Immediate State and Local Strategies for a Public Health Emergency
40ONC and CMS Interoperability Final Regulations
• Final ONC Interoperability Regulation: What You Need to Know
• Final CMS Interoperability Regulation: What You Need to Know
• CMS Interoperability Regulation: Conditions of Participation Fact Sheet
• ONC Interoperability Regulation: Provisions Related to Quality Program Reporting for
Certified EHR Technology
• ONC and CMS Announce Enforcement Discretion for Interoperability Regulations
• HHS OIG Releases Proposed Regulation on Information Blocking Civil Money Penalties
Recently Submitted Public Comment Letters
• HIMSS and PCHAlliance Submit Letter in Support of FCC Actions to Address COVID-19
• HIMSS and PCHAlliance Comment on Federal Health IT Strategic Plan
41Thank You!
• David Gray, Sr. Manager, Government Relations & Connected Health Policy
• dgray@himss.org
• Ashley Delosh, JD, Sr. Manager, Government Relations
• adelosh@himss.org
• Jeff Coughlin, MPP, Sr. Director, Government Relations
• jcoughlin@himss.org
• Valerie Rogers, MPH, Director, Government Relations
• vrogers@himss.org
42You can also read
