September 4, 2020

Thank you, ONC for the opportunity you gave me to speak in June. Also, thank you for the format of your August meeting where the Zoom chat feature offered a wonderful venue for an inclusive commentary and discussion as the talks were happening. Beats lining up at the microphone any day.

Here is a brief recap of my suggestions, in no particular order:

Patient identity is not different from human identity. Working on healthcare-specific solutions is not only expensive, but also ineffective. As some of your speakers made clear, the economic value of patient ID requires access to social determinants of health, non-HIPAA wearables, social relationships, assisted living, and economic correlates. Access to these will not be covered by HIPAA so any solution that depends on HIPAA-derived federations, including the incumbent HIEs, is not going to work. The Surescripts approach, for example, may be surveilling 315 million people already but it’s a dead end.HIPAA does not provide a right to consent. Because HIPAA is not broad enough to drive the economic and social benefits of patient identity, a HIPAA-based solution cannot be effective in the long run. A national patient ID strategy must be based on consent. One way to introduce consent into the solution is to involve payer IDs. Although not everyone is insured, yet, those who are have every reason to provide strongly validated identity voluntarily. Leveraging the near-universal consensus against surprise medical bills will align incentives even further.TEFCA depends on patient identity on a scale that stresses probabilistic matching. As it stands, TEFCA is not guaranteed to succeed because it still depends on new regulation and enforcement. The incumbent state and vendor HIE interests have almost no economic reason to cooperate. Major integrated delivery networks invested in “Epic Everywhere” as a

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