What information can I make available to my members to educate them about the risks and opportunities that come from connecting their health data to health apps?

One requirement of the CMS Interoperability and Patient Access rule is to make available consumer education about sharing their health data with third-party apps.

One advantage of the adoption of FHIR by payers as the basis of the Patient Access APIs is that the APIs all act in a similar way. The types of data being displayed fall into 4 broad categories:

  • Claims
  • Clinical
  • Drug Formulary
  • Provider and Pharmacy Directories

The Office of the National Coordinator for Health IT (ONC) have made a number of resources available on their web site. These public resources can be referenced to provide trusted education to health plan members.

This includes:

When a consumer authorizes the sharing of their data they are essentially providing consent. For information about Consent there is are resources that cover Consent in relation to data interoperability:

Consent should not be a “check-the-box” exercise. Meaningful consent occurs when the patient makes an informed decision and the choice is properly recorded and maintained. Specifically, a meaningful consent decision has six aspects. The decision should be:

  • made only after the patient has had sufficient time to review educational material,
  • commensurate with circumstances for why health information is exchanged (i.e., the further the information-sharing strays from a reasonable patient expectation, the more time and education is required for the patient before he or she makes a decision),
  • not used for discriminatory purposes or as condition for receiving medical treatment,
  • commensurate with circumstances for why individually identifiable health information is exchanged,
  • consistent with patient expectations, and
  • revocable at any time.

Meaningful consent is the intersection of:

  • Patient Education and Engagement
  • Technology
  • Law and Policy

NOTE: This page is also reproduced in the SAFHIR FAQ.