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  1. FHIR Specification Feedback
  2. FHIR-35623

Clarify: what happens when the CP shares that info with the CBO or other agency assisting with the Food Insecurity?

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    • Icon: Change Request Change Request
    • Resolution: Persuasive with Modification
    • Icon: Highest Highest
    • US SDOH Clinical Care (FHIR)
    • 1.1.0
    • Patient Care
    • Functional Use Cases [deprecated]
    • 5.1.0.1
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      This guide is silent on the relationship between a covered entity and the CP.  It may be a Business Assoicate (BA) or not.  If it is a BA then we provide an example of the covered entity exchanging a consent resource indicating that the patient has provided consent for the CP (BA) to release their information to a non-covered entity.  If the CP is not a BA, then the consent to release information should be obtained by the covered entity and held in their records.  The release of information to the CP should only be done if the patient has consented.  If the CP is a BA and does not receive the patient's consent to disclose, then the CP should not share the information with an entity that is not a covered entity or under a BA relationship.

      Informing the patient depends on the workflow of the covered entity the CP and the patient.  We are not requiring a specific method of informing the patient.

       

      Add this description to the IG and provide cross reference between the flow diagrams and the use case descriptions. 

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      This guide is silent on the relationship between a covered entity and the CP.  It may be a Business Assoicate (BA) or not.  If it is a BA then we provide an example of the covered entity exchanging a consent resource indicating that the patient has provided consent for the CP (BA) to release their information to a non-covered entity.  If the CP is not a BA, then the consent to release information should be obtained by the covered entity and held in their records.  The release of information to the CP should only be done if the patient has consented.  If the CP is a BA and does not receive the patient's consent to disclose, then the CP should not share the information with an entity that is not a covered entity or under a BA relationship. Informing the patient depends on the workflow of the covered entity the CP and the patient.  We are not requiring a specific method of informing the patient.   Add this description to the IG and provide cross reference between the flow diagrams and the use case descriptions. 
    • Bob Dieterle / Jay Lyle : 7-0-1
    • Clarification
    • Non-substantive

    Description

      We recognize based on the language above that this guide envisions the CP being a BA of the provider, rendering the CP covered by HIPAA, but what happens when the CP shares that info with the CBO or other agency assisting with the Food Insecurity? When and how is the patient informed of this data exchange? Will CPs only share data with organizations/agencies covered by HIPAA?

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            Unassigned Unassigned
            molly.malavey@ama-assn.org Molly Reese (Inactive)
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              Updated:
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