MO-VITLA INFORMATION MANAGEMENT

January 6, 2011 Response to 42 CFR 133: File code CMS-2346-P We welcome this opportunity to submit our response to the request for comments. The underlying premise of our approach, practically identical to the one delineated in your proposal, is that to really improve healthcare, a system must be designed from the ground up, relinquishing all previous and obsolete conventions, assumptions, and legacy software and patchwork systems. Health care services have evolved beyond the capabilities of current infra-and supra-structures. A new and robust system, utilizing existing and coming advances in science, medicine, technology, and business, is needed to service the varied and complex interactions between the three sets of primary health care constituents: users, providers and managers/payers. Although the entire process is a continuum which can be described with a single lexicography and set of data, each set of customers utilizes only a portion of that universe and requires a different perspective, management and data presentation. Consequently, each set of customers utilizes the data differently, and the need for different perspectives, desires, and applications gives rise to different software products and services. To satisfy those needs we have developed an integrated software system that addresses the unique needs of each of the above referenced healthcare customers. It is our version of a Service Oriented Architecture. This suite of software tools operate under patented processes and copyright protected platforms. Simply stated, our goals are to provide a secure and better quality of health care at a lower cost, to improve the accuracy, efficiency and functionality of health care providers, and to supply the managers/payers with the tools to budget, forecast, and control the use and costs of resources. Please read file to find out how we intend to accomplish all of this. J. A. Marchosky, MD CEO