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:

• Some payers create a complete clinical record for each of their members to facilitate data exchange with providers. Payers use this clinical record to give providers the adequate information to execute care coordination decisions.

(Comment 3 - imported by: Jean Duteau)