Stream: patient empowerment
Topic: Presentation to CARIN BB bi-weekly meeting (2021-07-08)
Ryan Harrison (Jul 08 2021 at 20:01):
Call: CARIN BB Payer Implementer Forum Weekly Meeting
Thursday, July 8⋅2:00 – 3:00pm
Policy principles
-
Rooted in HIPAA Privacy Rule, specifically the correction principle.
- HIPAA provides very specific Implementation Specifications for a Patient's Request to Amend their record
- Information clinic must give a patient
- Information for request denial
- HIPAA provides very specific Implementation Specifications for a Patient's Request to Amend their record
-
With inspiration from EU GDPR Right to Rectification
In scope
- Communication of request from patient to Health Care Provider CEs (Covered Entity)
- Roadmap: Covered Entity (Providers, Clinical) --> Covered Entity (Payers, EOB)
- Corrections/Rectifications (starting with clinical corrections to providers)
-
Where corrections are applied as attachments, meaning attachments _could_ be
- Existing patient-directed clinical exchange IGs, and their underlying attributes
- Any patient-directed clinical exchange attribute
- Non-clinical patient-directed exchanges, e.g. Payers/EOBs
Feedback from CARIN Payer community
- Payers make a distinction between communications and grievances/rights/appeals.
- The IG could be useful for communications, e.g. routine corrections of spelling, DoB, Address updates
- However it could be a minefield with respect to payments or grievances.
- Understanding that your current focus is on the transport mechanism (CommunicationRequest, etc interaction), to ease adoption, consider:
- Aligning your "communication attachments" with the business/logical data elements described by USCDI/CPCDS
- Publishing "communication attachment" guidance specific to the most popular consumer-directed IGs
- e.g. ONC --> Provider --> US Core
- e.g. CMS --> Payer --> C4BB
- While Payers may expose clinical data, workflows that involve a patient --> payer --> provider flow will be much more complicated that the payer --> provider/payer workflow (because one must involve an intermediate entity without access to the source system). Therefore, consider intermediated flows only _after_ direct patient --> CE (Covered Entity) flows.
cc @Ryan Howells @Mark Roberts @Debi Willis @Virginia Lorenzi
Last updated: Apr 12 2022 at 19:14 UTC