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CDT's Comments on the Bermuda Regulatory Authority's Open Internet Consultation

CDT submitted comments as part of the Bermuda Regulatory Authority’s Open Internet Consultation. CDT believes that the Regulatory Authority of Bermuda has crafted a strong set of proposals that are likely to provide adequate safeguards to preserve internet openness. We generally take a positive view of all the proposals in the consultation document and offer more specific recommendations on the policies for zero-rating, traffic management, ISP obligations, and end-users’ right to access and distribute content of their choice.

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CDT Comments to Centers for Medicare & Medicaid Services on Interoperability, Patient Access, and Privacy

In June 2019, CDT submitted comments on the Department of Health and Human Services Centers for Medicare and Medicaid Services’s proposed rule on interoperability and patient access. The rules would require covered entities to provide access to patient records through an application program interface to third parties designated by the patient. While CDT applauds the goal of giving patients better access to and ability to port their health information, we are concerned about the lack of privacy protections covering this sensitive information once it leaves the hands of an entity covered by the Health Insurance Portability and Accountability Act Privacy Rule.

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