Statements & Positions Archive

2020 Statements & Positions
December 1, 2020 EHR Association Letter to Senate on Patient Identification
November 9, 2020 EHR Association Comments to ONC on the Standards Version Advancement Process
November 9, 2020 EHR Association Comments to ONC on the Interoperabiltiy Standards Advisory
November 2, 2020 EHR Association Comments to CMS on the COVID-19 CLIA IFC
October 5, 2020 EHR Association Comments to CMS on the EPCS RFI
October 1, 2020 EHR Association Comments on the Physician Fee Scheudle NPRM
September 4, 2020 EHR Association Comments to ONC on Patient Identity and Record Matching
August 10, 2020 EHR Association Comments to ONC on the EHR Reporting Program Draft Voluntary user Reported Criteria
July 30, 2020 EHR Association Telehealth Letter of Support- Senate
July 30, 2020 EHR Association Telehealth Letter of Support- House
July 30, 2020 EHR Association Comments to FDA Development of 21st Century Cures Act- Section 3060 RFI
July 10, 2020 EHR Association Comments to CMS on the 2021 IPPS Proposed Rule
June 23, 2020 EHR Association Hosts Congressional Briefing on Information Blocking: View Recording
June 23, 2020 EHR Association Hosts Congressional Briefing on Information Blocking: View Summary, Slides, and Panelist Bios
June 23, 2020 EHR Association Comments to the Office of Inspector General on Proposed Grants Contracts and Other Agreements
June 22, 2020 EHR Assocation Comments to the DEA on ePrescriptions for Controlled Substance Interim Final Rule
June 18, 2020 EHR Association Hosts Congressional Briefing on COVID-19: View Recording
June 18, 2020 EHR Association Hosts Congressional Briefing on COVID-19: View the Summary, Slides, and Panelist Bios
March 13, 2020 EHR Association Comments on 2020-2025 Federal Health IT Strategic Plan
January 29, 2020 EHR Association Response to CMS on Transparency in Coverage Proposed Rule
2019 Statements & Positions
December 20, 2019 EHR Association Response to FDA on Clinical Decision Support Software Draft Guidance
December 20, 2019 EHR Association Response to CMS and OIG on the Anti-Kickback Statute and Physician Self-Referral Regulations
December 16, 2019 EHR Association Response to Cures 2.0 Request for Information
November 8, 2019 EHR Association Letter of Support for the CONNECT Act of 2019
October 25, 2019 EHR Association Comments to SAMSHA on Proposed 42 CFR pt. 2 Changes
October 11, 2019 EHR Association Response to RFI for the Development of a CMS Action Plan to Prevent Opioid Addiction
October 3, 2019 EHR Association Letter to ONC Regarding Additional Feedback to 21st Centruy Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Proposed Rule
September 27, 2019 EHR Association Comments to CMS' Reisions to Payment Policies Under the Physicians Fee Schedule
September 23, 2019 EHR Association Comments to the ONC 2019 Interoperability Standards Advisory (ISA)
August 28, 2019 EHR Association Letter to Senate Committee on Finance Regarding Prescription Drug Pricing Reduction Act
August 27, 2019 EHR Association Joins Industry Letter to Senate Committee on Appropriations on Patient Identification
August 20, 2019 EHR Association Response to Minnesota Department of Health RFI on a Connected Networks Approach to Health Information Exchange
August 16, 2019 EHR Association Response to CMS' Secure Electronic Prior Authorization for Medicare Part D Proposed Rule
August 12, 2019 EHR Association Response to CMS RFI: Reducing Administrative Burden to Put Patients Over Paperwork
June 25, 2019 EHR Association Congressional Briefing Summary: 21st Century Cures Act: Interoperability, Information Blocking, and the Impacts on Healthcare
June 24, 2019 EHR Association Comments to CMS on Hospital Inpatient Prospective Payment Systems
June 17, 2019 EHR Association Comments to the ONC Trusted Exchange Framework Draft 2
June 3, 2019 EHR Association Response to ONC' 21st Century Cures Act: Interoperability Information Blocking, and ONC Health IT Certification Program Propsed Rule
June 3, 2019 EHR Association Response to CMS Proposed Rule on Interoperability and Patient Access
May 30, 2019 EHR Association Response to FDA Proposed Framework for Artificial Intelligence and Machine Learning-Based SaMD
March 26, 2019 EHR Association Response to Senator Warner's RFI on Advancing Security in the Healthcare Sector
March 4, 2019 EHR Association Response to Senate HELP Committee RFI on Reducing Healthcare Costs
March 4, 2019 EHR Association Letter to CMS Requesting Extension to Public Comment Period for the Interoperability and Patient Access Proposed Rule
March 4, 2019 EHR Association Letter to ONC Requesting Extension to Public Comment Perioid for 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Proposed Rule
February 9, 2019 EHR Association Letter to CMS Regarding Concerns and Recommendations for Promoting Interoperability Program
February 8, 2019 EHR Assocaition Response to OCR's Modifying HIPAA Rules to Improve Coordinated Care RFI
January 30, 2019 EHR Association Letter to FDA on the Role of EHR in Healping to Combat the Opioid Crisis
January 28, 2019 EHR Association Response to HHS Draft Strategy on Reducing Regulatory and Administrative Burden Relating to Use of Health IT and EHRs
2018 Statements & Positions
December 20, 2018	EHR Association Response to FDA on Clinical Decision Support Software Draft Guidance
December 20, 2018	EHR Association Response to CDC National Test Collaborative RFI
December 13, 2018	EHR Association Letter to ONC on Health IT Certification Program Guidance and Resources
October 26, 2018	EHR Association Response to OIG on the Anti-Kickback Statute RFI
October 17, 2018	EHR Association Response to 21^st Century Cures EHR Reporting Program RFI
October 10, 2018	EHR Association Comments to ONC on Certification Test Procedures and Test Data
October 1, 2018	EHR Association Comments to ONC 2018 Interoperability Standards Advisory (ISA)
September 10, 2018	EHR Association Comments to CMS' Medicare Program: Revisions to Payment Policies under Physician Fee Schedule
August 17, 2018	EHR Association Response to CMS' Request for Information on Physician Self-Referral Law
August 17, 2018	EHR Association Response to Health Care Innovation Caucus Request for Information
July 19, 2018	EHR Association Comments to FDA on Developing a Software Precertification Program: A Working Model v0.2
July 18, 2018	EHR Association Letter of Support for the National Guidelines Clearinghouse
June 28, 2018	EHR Association Response to FDA's Development of 21st Century Cures Act Section 3060 Required Report Request for Input
June 22, 2018	EHR Association Comments to CMS on 2019 Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System (IPPS)
June 20, 2018	EHR Association Letter of Support for Overdose Prevention and Patient Safety Act
June 6, 2018	EHR Association Congressional Briefing: Maximizing Health IT in the Fight Against the Opioid Crisis
May 31, 2018	EHR Association Letter to Congress Requesting Inclusion of Patient Identification and Matching Language to House FY19 Labor, Health and Human Services, and Education and Related Agencies (Labor-HHS) draft Appropriations Bill
May 31, 2018	EHR Association Comments to FDA on Fostering Medical Innovation: A Plan for Digital Health Devices; Software Precertification Pilot Program
May 25, 2018	EHR Association Response to CMMI Request for Information (RFI) on Direct Provider Contracting Models
May, 3, 2018	EHR Association Letter of Support for Improving Access to Behavioral Health IT Act
February 20, 2018	EHR Association Comments to ONC on Trusted Exchange Framework and Common Agreement
February 16, 2018	EHR Association Recommendations to Senate Committee on Finance Request on the Opioid Epidemic
February 6, 2018	EHR Association Comments to FDA on Clinical and Patient Decision Support Software Draft Guidance
February 6, 2018	EHR Association Comments to FDA on Changes to Existing Medical Software Policies
January 10, 2018	EHR Association Comments to CMS' Medicare Prescription Drug Benefit Programs

2017 Statements & Positions

November 20, 2017	EHR Association Response to CMS: Innovation Center New Direction Request for Information (RFI)
November 17, 2017	EHR Association Comments to ONC's 2018 Interoperability Standards Advisory (ISA)
November 9, 2017	EHR Association Statement for the Record to the Senate HELP Committee Hearing on Implementation of 21 ^st Century Cures
October 26, 2017	EHR Association Comments on HHS Draft Strategic Plan FY2018 - 2022
September 11, 2017	EHR Association Comments to CMS' Physician Fee Schedule Proposed Rule
August 25, 2017	EHR Association Submission to Medicare Red Tape Relief Project
August 23, 2017	EHR Association Comments to ONC's Trusted Exchange Framework & Common Agreement
August 21, 2017	EHR Association Comments to CMS' 2018 Quality Payment Program Proposed Rule
July 24, 2017	EHR Association Comments to ONC's Proposed Interoperability Standards Measurement Framework
June 30, 2017	EHR Association Comments to CDS Coalition's Draft Industry Guidelines
June 22, 2017	EHR Association Highlights from Congressional Briefing "Examining the Role of Health IT in Value-Based Care"
January 26, 2017	EHR Association Letter to National Governors Association on "Getting the Right Information to the Right Health Care Providers at the Right Time: A Road Map for States to Improve Health Information Flow Between Providers."
January 26, 2017	EHR Association Response to CDC RFI on Adherence to Clinical Guidelines & Information Flow

2016 Statements & Positions

December 19, 2016

EHR Association Response to CMS on MACRA Final Rule

November 21, 2016

EHR Association Comments to ONC 2015 Edition Certification Test Procedures

November 15, 2016

EHR Association Letter to Senate HELP Committee on Proposed Ratings System for Health IT

October 27, 2016

EHR Association Response to CMS RFI on State Innovation Model Concepts

October 24, 2016

EHR Association Comments to ONC 2017 Draft Interoperability Standards Advisory

October 18, 2016

EHR Association Response to API Task Force Final Recommendations on Privacy & Security Considerations

September 6, 2016

EHR Association Comments to CMS Physician Fee Schedule NPRM

September 1, 2016

EHR Association Comments to CMS Hospital Outpatient Prospective Payment NPRM

August 2016

EHR Association Interoperability FAQs

July 18, 2016

EHR Association Comments to FDA on the Role of EHR Data in Clinical Investigations

July 6, 2016

EHR Association Statement to National Committee on Vital and Health Statistics on "Minimum Necessary" Standard

June 27, 2016

EHR Association Submits Comments to CMS on MACRA/MIPS Proposed Rule

June 7, 2016

EHR Association Sponsors Congressional Briefing in Washington D.C. and Publishes Fact Sheet on Interoperability

June 3, 2016

EHR Association Responds to ONC's RFI on Measuring Interoperability

May 2, 2016

EHR Association Submits Comments on the ONC Health IT Certification Program: Enhanced Oversight and Accountability NPRM

April 29, 2016

EHR Association Submits Letter to API Task Force Regarding Privacy and Security Recommendations

April 21, 2016

EHR Association Submits Comments on ONC's 2016 Interoperability Standards Advisory

April 11, 2016

EHR Association Submits Comments on HHS' SAMHSA Substance Abuse Confidentiality Regulations Proposed Rule

April 1, 2016

EHR Association Letter to ONC and CMS regarding the EHR Incentive Program for Stage 3

February 7, 2016

EHR Association Submits Letter to API Task Force Regarding Privacy and Security Recommendations

January 29, 2016

EHR Association Submits Letter to API Task Force Regarding Privacy and Security Recommendations

2015 Statements & Positions
December 2015	EHR Association Testimony for HITPC Certified Technology Comparison Task Force
December 15, 2015	EHR Association Submits Comments on CMS’ Meaningful Use, Stage 3 Proposed Rule
November 30, 2015	EHR Association Responds to ONC’s Proposed 2015 Edition Certification Criteria
November 17, 2015	EHR Association Responds to CMS’ RFI on new provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA): Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APMs) and physician-focused payment models (PFPMs)
November 6, 2015	EHR Association Provides Insights to ONC on Interoperability Standards Advisory
October 14, 2015	EHR Association Comments on ONC's Proposed Patient Safety Collaboratory
September 8, 2015	EHR Association Comments on Physician Fee Schedule Proposed Rule
July 1, 2015	EHR Association Interoperability FAQs
June 15, 2015	EHR Association Responds to Proposed Modifications to the Meaningful Use Program
May 22, 2015	EHR Association Chair Presents to Institute for eHealth Policy on Interoperability
May 7, 2015	EHR Association Responds to ONC's Standards Advisory Proposal
April 3, 2015	EHR Association Responds to ONC's 10 Year Interoperability Roadmap
February 6, 2015	EHR Association Responds to the Federal Health IT Strategic Plan
January 2015	EHR Associations Interoperability Roadmap and Response to Jason Task Force

2014 Statements & Positions
October 21, 2014	EHR Association Responds to the PCAST Report, Big Data and Privacy: A Technological Perspective
September 11, 2014	EHR Association Responds to ONC's Request for Input on the 10-Year Interoperability Roadmap
September 2, 2014	EHR Association Response to CMS' Proposed Rule on Changes to the Physician Fee Schedule
August 27, 2014	EHR Association Cypress Letter
August 12, 2014	EHR Association Responds to Senate Finance Committee Request re Healthcare Data Sharing
July 21, 2014	EHR Association Responds to House Committee on Energy and Commerce White Paper, "A Path to 21st Century Cures"
July 10, 2014	EHR Association Responds to ONC and CMS on Proposed Rule to Add Flexibility to the 2014 Meaningful Use Program
July 7, 2014	EHR Association Submits Response to FDASIA Report, A Proposed Strategy and Recommendations for a Risk-Based Framework
July 3, 2014	EHR Association Responds to JASON Report on "A Robust Health Data Infrastructure"
July 2, 2014	EHR Association Responds to Unexpected Changes to Meaningful Use FAQs from CMS
June 30, 2014	EHR Association Comments on Proposed IPPS Rule to Align Quality Measure Programs
May 7, 2014	EHR Association Testimony for ONC HIT Policy Committee Certification Hearing
April 22, 2014	EHR Association Responds to ONC's Voluntary 2015 Edition EHR Certification Criteria; Interoperability Updates and Regulatory Improvements
January 28, 2014	EHR Association Provides Guidance on MU2 Secure Transport
January 16, 2014	EHR Association Comments on SAFER Guides

2013 Statements & Positions
November 22, 2013	EHR Association QRDA Letter
November 12, 2013	EHR Association Responds to Congressional Proposal to Permanently Repeal the Sustainable Growth Rate (SGR) Formula Payment System
November 6, 2013	EHR Association Responds to FDASIA Recommendations on Health IT Regulation
September 5, 2013	EHR Association Responds to CMS Physician Fee Schedule Proposed Rule
September 5, 2013	CQM Development Timelines
June 30, 2013	EHR Association Responds to FDASIA RFC on the Development of a Risk-Based Regulatory Framework and Strategy for Health Information Technology
June 25, 2013	EHR Association Responds to CMS IPPS Proposed Rule
June 10, 2013	EHR Association Responds to Proposed Changes to Stark Anti-Kickback Regulations
May 16, 2013	EHR Association Responds to Senators' White Paper, "Reboot: Re-examining the Strategies Needed to Successfully Adopt Health IT
April 18, 2013	EHR Association Responses to RFI on Advancing Interoperability and Healthcare Information Exchange
April 10, 2013	EHR Association Responds to Proposed EHR User Fee
February 4, 2013	EHR Association Responds to ONC Health Information Technology Patient Safety Action & Surveillance Plan for Public Comment
February 1, 2013	EHR Association Responds to the CMS RFI on Readiness for Electronic Quality Reporting
January 14, 2013	EHR Association Responds to RFC Regarding the Stage 3 Definition of Meaningful Use of Electronic Health Records (EHRs)

2012 Statements & Positions
September 21, 2012	EHR Association Responds to the AHRQ RFI on Quality Measurement Enabled by Health IT
July 31, 2012	EHR Association Letter on Meaningful Use, Stage 2 Timelines
July 16, 2012	EHR Association Comments on the QDM and Style Guide
June 20, 2012	EHR Association Responds to ONC Request for Information on NwHIN Governance
May 3, 2012	EHR Association Responds to the ONC's Proposed Rule on EHR 2014 Edition Certification Criteria
May 3, 2012	EHR Association Responds to the CMS' Proposed Rule on the EHR Incentive Program, Stage 2
March 8, 2012	EHR Association Responds to Health Affairs Study and New York Times Article on Health IT and Increased Physician Ordering
February 21, 2012	The EHR Association Publishes Patient Safety Statement of Commitment
January 20, 2012	EHR Association Offers Comments on MAP/CQM

2011 Statements & Positions
December 15, 2011	EHR Association Implementation Experience with NwHIN Exchange Specifications Shared with ONC Health IT Steering Committee
November 9, 2011	EHR Association Comments on the NIST EUP
October 13, 2011	EHR Association Response to FDA Draft Guidance for Mobile Medical Applications
September 26, 2011	EHR Association Comments on the Health IT Standards Committee NwHIN Power Team Evaluation and Draft Recommendations
September 23, 2011	EHR Association Comments on the ANPRM for Metadata
August 1, 2011	EHR Association Comments on Accounting for Disclosures
January 19, 2011	EHR Association Response to PCAST Report

2010 Statements & Positions
July 10, 2010	EHR Association Testimony to House Ways & Means Committee on Meaningful Use
June 4, 2010	EHR Association Response to NHIN Direct "IHE Concrete Implementation"
March 12, 2010	EHR Association Response to ONC HITECH Initial Set IFR
March 12, 2010	EHR Association Response to CMS' Proposed Rule on Meaningful Use

2009 Statements & Positions
December 16, 2009	Position: Statement to NHIN Workgroup of the HIT Policy Committee
October 27, 2009	EHR Association Response to HIT Standards Committee Implementation Work Group
July 13, 2009	EHR Association Response to HIT Policy Committee Certification/Adoption Work Group
June 26, 2009	EHR Association Response to HIT Policy Committee on Meaningful Use
April 21, 2009	EHR Association Position Statement on ARRA Meaningful User & EHR Certification Criteria - Hospital
April 14, 2009	EHR Association Position Statement on ARRA Meaningful User & EHR Certification Criteria - Eligible Professional (Ambulatory)
January 7, 2009	EHR Association Position Statement on Privacy
January 7, 2009	EHR Association Position Statement on National Health IT Leadership

2008 Statements & Positions
December 2, 2008	EHR Association Position Statement on Government Funded EHR
October 17, 2008	EHR Association Position Statement on CMS Tamper Resistant Printed Prescriptions
May 2008	EHR Vendors Association Support National Standards to Promote/Adopt/Improve Interoperability In Electronic Health Records
2008	EHR Vendors Association CCHIT - HITSP Readiness Survey Results

2007 Statements & Positions
September 17, 2007	EHR Vendors Association Statement to OIM on ONC Standards Activities
August 20, 2007	EHR Vendors Association Position Statement on CCHIT Use Cases
July 20, 2007	EHR Vendors Association Position Statement to AHIC Use Case
August 8, 2007	EHR Vendors Association Proposal on Inpatient – Ambulatory Connectivity for ONC/AHIC
January 18, 2007	EHR Vendors Association Response to National Coordinator Health Information Technology (ONCHIT) Request for Information (RFI)

Code of Conduct (Version 1) As of July 1, 2017, Version 1 is no longer valid and cannot be referenced as current adoption. Health IT companies are encouraged to review and take steps to adopt Version 2.
June 11, 2013	EHR Developer Code of Conduct FAQ (Updated January 2017)
June 11, 2013	EHR Developer Code of Conduct Implementation Guidance
June 11, 2013	EHR Developer Code of Conduct Badge

2020 Statements & Positions

2019 Statements & Positions

2018 Statements & Positions

2017 Statements & Positions

2016 Statements & Positions

2015 Statements & Positi​ons

2014 Statements & Positions

2013 Statements & Positions

2012 Statements & Positions

2011 Statements & Positions

2010 Statements & Positions

2009 Statements & Positions

2008 Statements & Positions

2007 Statements & Positions

Code of Conduct (Version 1)

2015 Statements & Positions