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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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