Comments by Amelia Shapiro Posted on February 1, 2008

Page #	Line #	Comments/Criticisms	Suggested Alternatives
15	1-13	Please clarify how a Record Locator Service (RLS) or Master Patient Index (MPI) will impact the classification of a RHIO as a Custodial CDR versus an Owner CDR. Many RHIOs will manage a RLS or MPI which incorporates data from all RHIO participants. Data included in the RLS or MPI will often include patient demographics as well as an indicator linking the patient to a facility or provider and possibly some basic clinical information. * Will the existence of an RLS or MPI affect the classification of a RHIO as a Custodial CDR versus an Owner CDR?* Will the existence of clinical data in the RLS or MPI affect the classification of a RHIO as a Custodial CDR versus an Owner CDR?
20	25-27	The white paper highlights the importance of interoperability and states that a standardized consent policy will enable consistency across RHIOs. But, the minimum patient consent requirements differ for Custodial CDRs and Owner CDRs; Custodial CDRs are required to follow the policies outlined in the white paper, while Owner CDRs are required to obtain a HIPAA authorization in addition to the policies outlined in the white paper. Because of this policy difference, Owner CDRs and Custodial CDRs will have difficultly interoperating with each other, as the minimum requirements differ for these two models.	To encourage interoperability, we recommend that all RHIOs be subject to the same patient consent requirements. This will result in a technology-neutral solution, rather than a solution that makes coordination between Owner CDRs and Custodial CDRs difficult.