| Page # |
Line # |
Comments |
| 20 |
29-32 |
Given the complexity of physician practice relationships across the health care system there are significant challenges related to defining a "practice" and implementing consent on a per practice basis. An alternative approach and one that does not encumber the existing flow of information as a physician moves across care settings or provides care through larger covered entities should be considered, such as a single consent for each health information exchange, or a per-covered entity consent which would conform with the covered entity's Notice of Privacy Practices on sharing of protected health information |
| 20 |
29-32 |
Requiring each practice to gain written consent could represent a significant burden on health care providers and greatly impact the adoption, use and value of health information exchanges. Alternatives to requiring each practice to gain written patient consent should allow patients to manage such consents on-line, as well as offer patients the option of selecting a per RHIO consent should they prefer the ease of an approach that does not require multiple consents or complex consent management. |
| 23 |
36-37 |
We are concerned about the requirement to support data filtering and each institution's ability to support such data filtering. |
