Comments by Calvin E. Twoguns Posted on January 31, 2008

Page # Line # Comments/Criticisms Suggested Alternatives
7 34 - 40 When redefining consumers' rights (patient's), the question remains - Will the language be determined by the clinical side if the house to lawmakers in the State Assembly and Senate? It is very broad and vague and will be a challenge for community buy in from those who utilize the system. Consumers' (patient's) of this proposal must be involved (Consumer Comittee) in every facet for clarity in the manner of language of any bill which restricts the usage of personal information. If we look at the "Denver Principles" for those living with HIV/AIDS their involvement is unique and should carry some critical thought in the process of restricting personal data/accessing data which should be determined more by them than their clinician. If it isn't then they (clinicians) can make false assumptions as to the will of the consumers' as to the depth of the information released.
13 10 to 20 Even through RHIO may offer large networks of clinicians and providers information available that consumers' don't see, the problem here is the lack of education to the consumer once it is brought forward as a possibility to treatment. It goes without saying that an educated consumer is a smart consumer and choices regarding information available for course of treatment should be made available at every step. The second concern to this is that the socio-environment between clinicians and providers are different in both urban and rural settings and there may be parts of each RHIO area where providers in the area may not want to be part of a complex system that woud impede upon their limited resources because of their size. So the questions is "How do you convince them to but in..is there a re-imbursement of monies spent to meet this RHIO mandate? Clinicians and consumers must be brought together in all steps of accessability not only to services, but treatment protocols. Too often consumers' are left out in the dark trying to understand the technical portions of their treatment plans. To make this work physicians, clinicians and service providers must and should constantly be aware that the consumers' health and welfare is dependent upon their openess to work with the consumers.
15 1 to 5 "If a provider leaves the RHIO, the providers data must be returned or destroyed". Powerful statement, but the major concern is this. Why would the data be destroyed (couldn't it be utilized when a new provider is found for the consumer)? The data should be saved in a historical archive for reconstruction for the new provider. This would save endless redunancy and a new medical record would not have to be reconstructed from "scratch". I would like to believe that the consumers' life is on the table and the longer it takes to reconstrut the history of a consumer, the more damage may be taking place in the health. I believe this will save time, energy and money to have this capability. It gives the new provider the opportunity "instantly" to see the history of the patient rather than second-guessing.
17 12 to 16 This goes to saying that "one shoe doesn't fit all sizes". Current policies and procedures are already difficult in their interpretations of language that is too broad and vague, and yes providers may elect not to participate, and therefore the question is how will this system affect them and the use of such data if consumers go to those providers who are not on board this system???? The relevency of the data within the proposed RHIO system must be (1) very flexible for the end users (2) able to be utilized on cross-platforms of current systems. There must be commonality within software applications in its development both on a local and regional level. If it isn't than hundreds of millions of dollars will be spent to play catch up in the development and implementation phase of this project.
29 7 to 10 Patients feel misled when they learn their insurer has gained access to their information, without regard to the actual language contained in the consent form. There is no mechanism in place to ensure the privacy of the data once it is released to the insurers. Thousands of claims are processed daily and the issue here is unfortunately the ability of information be leaked out in the process of transcribing the data and tranmitting data over (unsecured lines) since there is nothing in the report saying that RHIO Networks will be utilizing secured dedicated lines for transmission of this data. What about bio-metrics? Consumers' have to be present to open the medical record and after receiving services present to close the record. This prevents fraudenlent billing for services never rendered and bio-metrics can also be utilized to lock and unlock information to those that need to see it and keep away those who eyes it was unattended to. This would the ultimate confidential system available. A patient has to be alive to unlock their medical records for their appointments. One cannot just fill out a sheet of paper and then create a medicalrecord without a human body in front of them and say they performed some type of service.