UCSF CENTER FOR DIGITAL HEALTH INNOVATION’S COMMENTS ON PROPOSED REGULATIONS TO IMPLEMENT 21ST CENTURY CURES ACT’S PROVISIONS ON INTEROPERABILITY AND PATIENT ACCESS, FILE NO. CMS-9115-P

Dear Administrator Verma:

The University of California, San Francisco’s Center for Digital Health Innovation submits these comments on the Centers for Medicare & Medicaid Services’s draft regulations to implement the 21st Century Cures Act’s provisions on interoperability and patient access, published March 4, 2019. The University of California, San Francisco (UCSF) is a worldwide leader in health care delivery, discovery, and education. Consistent with this public imperative, UCSF invests heavily in developing a variety of health information technology, innovation, and management resources and best practices to give health care providers and patients,1 researchers and scientists, educators and students, the interoperability and transformative tools to succeed in this rapidly evolving digital health age. We thank you for the opportunity to provide these comments.

LettersSarah Taylor