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. |