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APTA agrees with and supports the ONC’s proposed definition of interoperability with a focus on semantic interoperability that allows access, exchange, and use of electronically accessible data, as well as native data capture that supports the export of standardized data between entities. Integrated technology plays a vital role in a provider’s ability to function in a value-based care system. To date, ONC, as well as the Centers for Medicare and Medicaid Services (CMS) have been very exclusive in their development of policies related to electronic health records (EHRs), interoperability, and more, focusing primarily on physicians and hospitals, to the exclusion of physical therapist private practices, postacute care organizations, and other provider types. It is disappointing that “smaller” providers, who do not have the same leverage and market share as health systems and large organized provider groups do, are left out of many policy discussions. We recommend that greater attention be focused on the “end-game,” which is better performance by all health care providers and improved health outcomes.

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