Andrew Tomlinson’s Post

📣FAQ Sheet, Get your HTI-2 FAQ Sheet🗞️ Mega 🎩 tip to Tara O'Donnell for pulling together an excellent FAQ on all you need to know about HTI-2 at a high level. Key provisions in the rule include: - ePA APIs (if you thought they wouldn’t involve the EHR you thought wrong) - Public health certification criterion -New info blocking exceptions (surprise!) and a couple of revisions (double surprise!) - Updates to incorporate USCDI v4 by 2028 - TEFCA governance rules - And a myriad of other fun health IT technical requirements If you’re an AHIMA member and you want to know more, make sure you contact Tara and I at advocacy@ahima.org! Seriously, big ups to Tara. She keeps me sane during the busy regulatory time and we are lucky to have such a talented health IT SME on the team. FAQ available here: https://lnkd.in/ebY4NJ4d

Alya Sulaiman provides a good summary of not only Corner Post but how that ruling in tandem with Loper Bright paints a new landscape for regulatory activity long term.

I want to clear up a few pieces of “Chevron” confusion for anyone who is anxiously trying to make sense of what has transpired over the last few weeks. 1. Just so we are crystal clear in what we are discussing. The decision is Loper Bright Enterprises v. Raimondo and it relates to the Chevron Doctrine as opposed to being the “Chevron Decision.” Nuanced, I know, but I just want to make sure we are clear on what we are discussing since multiple cases have dealt with the Chevron Doctrine in the past. 2. This does not invalidate any regulations that are currently viewed as “ambiguous” and nothing changes related to compliance in healthcare as of the writing of this post. If you were impacted by regulations pertaining to Loper Bright v. Raimondo then obviously you’ve got some requirements that have changed. (Although, if I have anyone on here that is a dual health IT/commercial fishing industry entrepreneur I want to learn more about your business!) 3. For a piece of regulation to be “rolled back,” “cancelled,” or “overturned” it will need to be challenged in court and even then that may not change compliance expectations while the case is in litigation. A court would need to decide that the rule is suspended while it is litigated for any current compliance expectations to change. Expect any regulation that is challenged to go through multiple appeals if it is deemed an important policy initiative to the administration in power. 4. We do not know yet how this will change the way Congress drafts bills or how agencies engage in active rulemaking. All rulemaking will continue for the foreseeable future - including payment rules and the forthcoming HTI-2 - unless we are told otherwise. You should continue forward with business as usual until further notice and that includes proceeding with compliance activities. 5. Everyone is learning this in real time. Considering how the regulatory landscape has functioned for the last two decades these are uncharted waters. We are all going to get something wrong or have our expectations change while this unravels. Be kind to yourself and your experts as you learn along with the rest of the space. Heck - some of what I’ve written here may even change in the coming weeks or not be completely accurate based on someone else’s interpretation.

Read about the HHS OCR updated guidance for breach notification in response to the Change Healthcare attack in the summary Tara O'Donnell and I pulled together. Available Here: https://lnkd.in/edAT82fw

Hope you can make it!

What a great event today and wonderful panel. Thank you to McDermott Will & Emery for including AHIMA and to Kristen O'Brien for moderating!

Already an exciting day here on the Hill!