April 9, 2020

ACHP and our member plans plans are dedicated to interoperable health data exchange. However, COVID-19 has forced plans to temporarily suspended efforts to implement interoperability. While this crisis underscores the importance and need for these final rules, implementing this enormous undertaking under the current timeline would result in industry-wide strain at a time of already limited resources. As such, ACHP respectfully requests that CMS delay the deadlines of the final rules.