CHIME also urges ONC to consider additional mechanisms for facilitating a dialogue regarding national health information exchange before issuing a notice of proposed rulemaking for NwHIN governance. In addition, the comments call for ONC to spend more time identifying best practices among existing HIEs. Finally, CHIME is uncomfortable with how NwHIN governance-related conditions for trusted exchange could impose requirements beyond what is required under HIPAA privacy and security rules.
The comments submitted by CHIME also answer specific questions from the request for comments. Click here to view the comments.
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