| Page # |
Line # |
Comments |
| 20 |
29-32 |
Some patients have expressed the desire to complete one form to allow appropriate access for all their providers as access is needed. The concern of patients and particularly parents is the hassle to keep track of where you need to set up consents and where you dont. In the event of consumer portals that capture patient consent would such a patient selected option still be acceptable, where a patient could over ride the requirement to provide a written consent per practice. |
| 20 |
29-32 |
Requiring a WRITTEN consent for every practice will require practices to continually check to see if the patient has provided consent for that practice when the patient shows up in an office. (Otherwise they are continually handing out the consent form when a patient shows up) An alternative approach might allow electronic consents for subsequent practices after the initial RHIO written consent has been obtained, or patients providing a password of token to the office to grant access. |
| 20 |
39-41 |
In the event of a consumer portal where patients can manage access, it would Not Be the providers or payers obtaining consent but the patient granting it per practice or organization (or how they selected to grant such consent - see above) |
| 22 |
7-9 |
Would a RHIO sending data to another owner-CDR based on the results being ordered by a physician that was part of the organization on the one-to-one model, still require a consent form to send results. As an example, an IPA has a clinically integrated CDR, one of their participating physicians orders a test for their patient, the RHIO in the one to one model sends those results to the physician whose data is housed on the integrated CDR. |
| 22 |
36-39 |
"Any entity accessing information must have had a relationship" does not seem to anticipate consultants and specialists accessing results or clinical history prior to a new patient's physical visit. The current analog approach of a primary care physician sending along practice notes or test results to a consulting physician would seem to be prevented under this approach. Would there not be a facility for a referring physician to grant access to a specialists on a referral/patient by patient basis. |
| 23 |
36-37 |
While "clinicians must have the discretion to withhold information" this seems in conflict with the above sentence 34 that RHIOs and their participants are not required to screen such information. |
| 24 |
7-9 |
When will the form be complete? |
| 24 |
7-9 |
Participants are constantly changing in a RHIO, including them on the consent form will make such form both voluminous and too dynamic to preprint. Providing a web site with a list of participants or a summary of participants on a patient Q&A would be a preferred approach |
