MGMA submitted comments in response to an Office for Civil Rights (OCR) Request for Information (RFI) on modifying HIPAA to facilitate care coordination and support value-based care. MGMA identified opportunities to reduce administrative burden, particularly with regards to patient acknowledgement of practice privacy policies. The Association pushed back on forcing practices to disclose patient records when requested by other providers or business associates, arguing clinicians should be permitted to use professional judgement to determine when a disclosure is appropriate. Also, MGMA strongly opposed the expansion of the current accounting of disclosures report to include disclosures made for purposes of treatment, payment, or healthcare operations. OCR is expected to publish regulations later this year.