| Page # |
Line # |
Comments/Criticisms |
Suggested Alternatives |
| 19 |
34 |
In the definition of "one-to-one" delivery - results to the clinician who ordered the test is spelled out, there is not a reference to the cc'd physicians. |
Our recommendation is that results to the cc'd physicians should be included in the exclusion because it is common practice in results reporting today (under the current HIPAA authorization/consent) and would cause problems with current systems and workflow if we now required additional consent for information being received today. |
| 23 |
36 |
The statement "Clinicians must have the discretion, in consultation with their patients, to withhold information from the health information exchange" appears contrary to the rest of the document. |
We have 4 different options for dealing with this: 1) Get rid of the paragraph; 2) Anonymize patient ID at the data source to protect the patient identity in the RHIO; 3) restrict data access (submit data to exchange but tag the record to deny access to all except one-to-one exchange; 4) change "clinician" to "entity"; 5) record the visit in a paper chart |
| 25 |
16 |
The statement "RHIOs must conform to consumer education program standards developed by a statewide collaboration process and approved by the DOH" left us with a question… When? |
If there is a target date for these program standards - please publish. |
| 32 |
20 |
Relative to "Consent policies and procedures relating to minors"… When? |
If there is a target date for these PPs - please publish. |
