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    • Icon: Change Request Change Request
    • Resolution: Not Persuasive with Modification
    • Icon: Highest Highest
    • National Directory of Healthcare Providers and Services (NDH) (FHIR)
    • current
    • Patient Administration
    • Attestation Implementation Guidance
    • 11.1.2
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      Clarify the process for determining "restricted" information and the suggested method of restricting access by downstream directories (e.g. via a data use agreement)

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      Clarify the process for determining "restricted" information and the suggested method of restricting access by downstream directories (e.g. via a data use agreement)
    • Bob Dieterle / David Pike : 6-0-0
    • Clarification
    • Non-substantive

    Description

      See sentence:

      "Attesters SHALL NOT be able to make independent decisions regarding which information is considered restricted."

      Comment:

      An NDH should limit sensitive or unreliable data to internal use (e.g., non-discoverable) until individuals listed in the NDH can see the data, provide input, and then choose whether to make data consumer-facing. Physicians can face discrimination and may have strong preferences if their demographic information is public. Physicians should be allowed to first review and approve their potentially sensitive data. For example, race, ethnicity, or other demographic data should not be included in a public-facing directory approved by the individual.

      Additionally, directories should not include personal information such as home address, cell phone, or personal email address. Additionally, a mechanism should be established for physicians to opt-out of being listed in the NDA altogether. Our members have been the target of stalking, harassment, and violence to the point of requiring legal interventions. There has been a significant increase in these instances since the Dobbs ruling. Lacking sufficient privacy protections and controls, an NDH could escalate physician harassment.

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            Unassigned Unassigned
            celine_lefebvre Celine Lefebvre
            Celine Lefebvre
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              Created:
              Updated:
              Resolved: