Thank you for this opportunity to comment on the draft Strategy on Reducing Burden Relating to the Use of Health IT and EHRs.  

I agree that providers and patients will benefit greatly from greater leverage of Health IT, particularly in regards to prior authorization and interoperability.  

However, the draft Strategy does not appear to recognize the investment that providers must make to train staff, procure and implement new systems, migrate and secure data, and respond to patient requests for assistance with healthcare data.  

For example, for the past several years my PCP requires an annual fee of $150 to help offset the cost of compliance with insurer and regulator IT standards.  We just received a letter notifying us that his annual fee will raise to $1,800.00 per patient in 2019.  My family of six cannot afford to spend $10,800 to be his patients.  Neither can my elderly family members who were patients of the same PCP but who now struggle to find local providers who accept Medicare patients.

HHS can begin to address these issues with a recognition of the costs and challenges faced by providers-- and ultimately their patients. 

For example, the CMS fee schedules should be revised to reflect the costs of training, IT infrastructure maintenance, and patient educaton.  The cost of annual IT Security training should included as directly attributable to the cost of care.

HHS should also recognize that many providers and healthcare organizations lack a sufficient background in IT security, data integrity, network interoperability, etc.  This has added an additional layer of costs as providers and healthcare organizations are forced to rely on expensive consultants.  Likewise, providers are locked into vendor relationships due to the high cost of migrating data and training staff.  As a result, providers and healthcare organizations are reluctant to make the significant investments that will drive industry-wide improvements in Healthcare IT.  HHS has a unqiue platform to offer fundamental training in cybersecurity, data management, vendor oversight, and practice management-- and a ready and willing audience.

Thank you for your time and attention.

Sincrely, 

Martin O'Connor
Cincinnati, Ohio