The complete clinical record will always reside with physicians/EHRs. Payers may have clinical data, beginning with USCDI, but this is NOT the complete clinical record. Recommend deleting “complete.” One of many examples – if care isn’t being paid for by insurer (patient chooses OOP), that clinical data does NOT go to the payer).

Existing Wording:

Payers want to create a complete clinical record of their members to improve care coordination and provide optimum medical care.

Proposed Wording:

Payers want to create a clinical record of their members to improve care coordination and provide optimum medical care.