FTC Staff Comment Before the Office of the National Coordinator For Health Information Technology, Regarding Its Draft Shared Nationwide Interoperability Roadmap For Health Information Technology Systems

FTC staff submitted a comment to ONC, in response to ONC’s request for comments on its draft Shared Nationwide Interoperability Roadmap. The comment offered guidance on promoting competition (as well as the privacy and security of consumer data) as part of ONC’s plan to increase the adoption of interoperable health IT systems by 2024. With respect to competition issues, the comment encouraged ONC to consider how the economic interests of health care providers and health IT vendors align with the benefits of interoperability, such as lower health care costs, improved population health, empowered consumers and ongoing innovation. The comment also offered guidance on shared governance mechanisms and the development of technical standards. To balance the benefits of standard setting, such as lower switching costs and reduced barriers to entry, with its potential risks, the staff comment encouraged ONC “to consider taking steps to ensure that coordinated governance by market participants does not unduly distort competition.”