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CommonWell Answers HIStalk Reader Questions

January 16, 2015 News 15 Comments

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David McCallie, Jr., MD, SVP of medical informatics for Cerner and co-founder of CommonWell Health Alliance, invited HIStalk readers to submit their questions about CommonWell. He obtained answers from the most appropriate CommonWell resource. These replies were provided by David along with Dan Schipfer (VP/GM of government for Cerner and CommonWell operating committee chair); Nick Knowlton (VP of business development for Brightree and CommonWell membership chair); Bob Robke (VP for Cerner and CommonWell treasurer); and Jitin Asnaani (director for Athenahealth and CommonWell operating committee co-chair).

How do organizations like CommonWell promote interoperable transfer of health information to non-members? If our goal is a national infrastructure for transfer of PHI, don’t these aggregations of health partners create barriers to a national solution?

From a strategic point of view, CommonWell’s founders created the network because they did not believe that any of the existing approaches met the need for national-scale federated query based on robust identity management and record locator services. CommonWell’s founders believe that regional and vendor-proprietary networks won’t meet the demand for universal query connectivity. In contrast, CommonWell membership is open to all HIT suppliers and their customers, nationwide. However, if other networks emerge that cover substantial portions of consumers, CommonWell is open to creation of bridging services that could interconnect with other networks.

More tactically today, we feel that CommonWell has already promoted interoperable transfer of health information by publicly calling out the important issue of the lack of a common patient identifier in US health care. Second, to advance the state of the art, CommonWell members have designed and published specifications that address the problem of the missing patient identifier. These specifications are available for any and all (i.e. members and non-members) to evaluate, improve, implement, and use under common open source licensing. 


Does CommonWell have any plans for taking the initiative outside of the US?

We’re taking it one step at a time. Currently, CommonWell’s focus is to deliver real-world interoperability services across the US.


Why did some folks refer to CommonWell (in its early days) as the "HIE killer" and is that still a valid point? Accordingly, do entities like Aetna (who has invested in Medicity) and Optum (with their Axolotl acquisition) consider CommonWell to be a threat?

It is difficult to speculate on behalf of “some folks,” but CommonWell is not attempting to “kill” any type of exchange. CommonWell is designed to offer a national-scale service because we believe that a patient’s provider should have access to that patient’s information regardless of where the information lives. Through this approach to “universal plumbing,” members can expect an increase in the access to health information for their providers and a decrease in the cost and time for providers and their patients to gain access to their health information.

By addressing shortcomings in existing exchange models (such as imprecise standards that inhibit vendor to vendor connectivity), CommonWell is drastically reducing time and associated expense to achieving health information exchange. Furthermore, in a world driving towards the triple aim, interoperability initiatives such as CommonWell are aligned with goals common to payers, patients, provider networks, and national healthcare delivery objectives.


How does CommonWell relate to the Argonaut project?

There is no formal relationship. The Argonaut Project is an industry-funded initiative to accelerate the development of technical standards (FHIR and OAuth) in conjunction with HL7. On the other hand, CommonWell is a trade association that is deploying a national network. The results of the Argonaut Project should complement CommonWell’s existing use of standards, which are partially based on FHIR, as well as on standard IHE profiles like XCA (for document-based exchange). The standards work stimulated by the Argonaut Project will be important to HIT in general. CommonWell hopes to leverage these new standards to provide enhanced services as they become formalized.


What fees will be collected for using CommonWell’s system, who pays those fees, and where does the money go?

CommonWell is a non-profit trade association that relies on two different fee sources to operate.

One is membership dues, as are common to most not-for-profit trade associations. The dues schedule is based upon an organization’s annual US HIT revenue and provides for the organizational expenses of running the Alliance. A more detailed breakdown of the membership fees is available on our website.

The second fee, a Service Fee, covers the cost of the core services provided by CommonWell to its members to facilitate data exchange and includes the identity management and record locator services. By doing this at the vendor level, CommonWell is able to achieve unprecedented economy of scale gains for streamlining connectivity. Members who provide access to CommonWell to their customers are free to charge (or not charge) for those services as they see fit. As a non-profit trade association, CommonWell has chosen not to mark up these costs to membership.

CommonWell cannot set the fees charged by member companies to their customers. However, our expectation is that those fees will be modest compared to the value of the services delivered and will be assessed in the “commodity service” philosophy espoused in our founding principles. As noted in CommonWell Board Chairman Jeremy Delinsky’s recent blog, athenahealth’s service fee equals about one-tenth of one-percent of their annual revenue.

What’s costly for everyone is the need to build numerous point-to-point interfaces and reinvent the wheel of patient identity management for every exchange scenario. Connecting once to a nationwide network, as the health care industry has done in other instances, has proven to be a better model for widespread data exchange.


Will EHR vendors pay a competitor (McKesson and CommonWell’s IT provider RelayHealth) to exchange information with other systems?

CommonWell Health Alliance delivers the services to the HIT members. RelayHealth is CommonWell’s initial contracted network service provider. As with any service offering that requires hardware and software, the services fees paid by the member to the Alliance help to offset the Alliance’s network service provider investment and compensate them for the costs of providing that service.


I heard it costs $2 million to become a member of CommonWell. What is the ROI for those members?

As noted above, if a vendor chooses to offer CommonWell Services to its clients, the vendor is charged a Service Fee in addition to the Membership dues. The Alliance currently charges an annual Service Fee to cover the cost of the core services. The Service Fee is based upon the Member’s annual HIT revenue. This annual fee allows the Member to onboard an unlimited number of clients onto the CommonWell Network.

CommonWell plans to publically post the Service Fee schedule on our website later this year, but for the vast majority of members, the costs will be far below that amount.


If I’m an Epic shop, what can CommonWell do that I can’t already do through Epic? What are the cost comparisons?

CommonWell provides a national-scale identity management service, nationwide record locator service, and universal connectivity to any vendor that offers the service. A single connection to the CommonWell network will enable providers and the patients they serve to access to their health information at all those various systems and organizations and won’t require peer-to-peer contracting for each provider you need to reach. The identity management and record locator services reduce matching errors and make it seamless for the provider since the patient does not have to remember the places where they have records. We don’t know of any single vendor network that can enable access to a patient’s health data regardless of where they have been seen.


Why would providers want a few publicly traded vendors running a fee-based backbone instead of pushing the government to create freely usable standards available to all vendors?

CommonWell’s founders believed that identity management and record locator services were necessary for effective national-scale query connectivity. Those services have to be organized and paid for by someone and the existing government-related approaches were not committed to delivering those services. Additionally, the founders believed that the vendor community was in the best position to “build in” support for efficient, seamless connectivity. The standards on which CommonWell is based are indeed freely available, but the national scale services that make those standards useful require an organization and appropriate organizational governance.


How are health plans and payers represented in the CommonWell alliance? Medicare’s risk adjustment have always demanded better access to and merging of administrative and clinical data. Now that the ACA demands risk adjustment for commercial population the need for this marriage is even greater. The ability for health plans to better assign risk to their members and the ability for providers to help close care gaps and meet their CMS-mandated obligations for data exchange can be greatly facilitated by providing improved attribution mechanisms for identifying members, providers, and specific encounters. And there should be a common means for plans to provide care gap info.

Right now, CommonWell is made up of 17 health IT vendor organizations, but we encourage membership to any organizations, including payors, that share the association’s values and vision for interoperability. In the early days of the Alliance, we had to remain focused on designing, building, and deploying our core services. These existing services offered by the Alliance are well aligned with offering improved delivery of healthcare for the nation, and that inherently provides benefits for all stakeholders – including patients, providers, and payors.

While this is a great start, we recognize that there are other opportunities to provide value for how healthcare is delivered and CommonWell certainly has an opportunity to build upon the established model to provide additional value. The Alliance welcomes participation from and conversations with payors and other healthcare stakeholders outside of the core EHR community. We have engaged early conversations with several payors that share our vision and understand how crucial interoperability and data liquidity are to improving care.

To complement this, the Alliance has established a process for reviewing member-proposed potential service line extensions and welcomes payors to help determine if the identity management and record locator services offered could add additional value to the patient populations represented by the members in the Alliance, through examples such as care gap closure, without compromising any of our core principles.


What factors convinced Cerner to join the CommonWell and what is Cerner’s play after the three years of free services?

The early days of CommonWell have been focused on getting the network deployed as widely as possible to ensure that meaningful health information is delivered. We understand that the value of the network depends upon how widespread the usage is. Cerner wants to remove as many barriers as possible to help speed deployment. Removing financial barriers to early adoption was a straightforward decision for us. After the initial three years, we expect that the costs associated with the services will be in line with other EDI like transactions and will be considered minimal in comparison to the value a client receives.

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Currently there are "15 comments" on this Article:

  1. I am posting this with the full intent of provocation.

    Dear CommonWell and Argonaut,

    Stop proposing models that will screw the providers.

    With all due respect to Dr. McCallie, I believe his characterization of CommonWell vs Argonaut is disingenuous at best and deceiving at the least. Both are industry-led and funded and neither organization is offering up these solutions out of the goodness of their hearts. They are doing this because they clearly see there is money to be made. Just like the banking industry did with its ATM/EFT network. in almost all date exchange models, it is the receiver that pays because they benefit the most from the data. Frankly, HIE (the verb) has been sorely lacking in a sustainable financial model but here’s where I diverge from that statement because healthcare is notable in that it is the supplier of the data that pays. To put it my kids vernacular: “Really???!”. Yes, really.

    Unlike the banking model where the banks own and store their data, healthcare’s treasure trove is not centrally stored, meaning the docs are the ones who are paying for the privilege of enriching the companies. I’ve yet to hear a company say that they will not charge a doc a transaction fee. If these companies were genuine in what they are doing, their business model will include some type of metering and payment to every doc that generates a document/message/image for HIE. Don’t think for one second that the docs wouldn’t buy into that.

    The only reason I tolerate paying for an electronic claim is because it’s a short ROI for me. I get paid in 14 days or less for a clean claim. I’ll take ten cents on the dollar anytime to get my receivables below net 30 days. Pay a dollar for a 270/271? No problem. Reduces my bad debt on the front end. HIE clearly lacks this incentive model for the docs. Figure it out and I’ll come running. To quote Rod Tidwell: “Show me the money!” and I’ll make the investment to move as much data as I can. It ends up being worth it for me to do so rather than being charged by a vendor every time I do. None of this does one thing to reduce my cost. in fact, it doesn’t nothing but drive the cost of healthcare up, not down. Not to mention that even if you figured it all out, I would still have to buy one of the systems to do it. Really!?!?!? Yes, really.

    Yes, I am interested in sharing data for the improvement of care and safety…no question. I should have even had to type that sentence but I know people will lambast me for what on the surface looks like a total materialistic approach. However, I cannot continue to kill my utilization and imperil the financial health of my practice to do so but that’s exactly what the government is asking me to do. The vendors make great toys and for the most part, they are useful despite being hyped and over-promised.

    And by the way, many of my patients already think I have all of this HIE capability and send their information to any doc on the planet at the click of a button. Really!? I hate telling them that I don’t and no one in healthcare does. They have a really hard time believing that.

    I certainly don’t expect that Dr. McCallie or any of the other board members to imperil their employment by proposing something that would hurt their company’s revenue streams. My point simply is Caveat Emptor. Making money for their companies is the penultimate in motivation and should be view with the requisite suspicion.

  2. As stated CommonWell’s primary focus is on ” national scale ID management”.

    After 45 years in HIT I can safely say this is not a technical problem, nor is it a marketing one (as I suspect CommonWell thinks it is). It is a political and sociological problem. It is the nexus of privacy and need to know. And a real public concern not unjustified given all the recurring privacy and security breaches.

    I’d like to hear how CW is going to address this very real issue, if not I predict CW will be another failed marketing plan.

  3. “I’ve yet to hear a company say that they will not charge a doc a transaction fee. If these companies were genuine in what they are doing, their business model will include some type of metering and payment to every doc that generates a document/message/image for HIE. Don’t think for one second that the docs wouldn’t buy into that.”

    athenahealth used exactly that business model until the OIG stepped in to put a stop to it (see OIG Advisory Opinion 11-18 and related termination for all of the details).

  4. I can’t even begin to express how heartwarming it is to hear (presumably) doctors expressing eagerness to sell patient information to the highest bidder within our modern “Show me the money!” ethical framework.
    “For the improvement of care and safety…no question”.
    And at the same time lambasting another entrepreneurial effort to capitalize on patient private information for the same reason. “For the improvement of care and safety…no question”.

  5. http://xkcd.com/927/

    More seriously, 703 is right on the money; any charge to the provider will doom any attempt at interoperability, OIG or not. If that provider bears some financial risk for the well being of the member it might help. So Commonwell doesn’t solve the real problem here; ACOs (and good ol’ fashioned HMOs) might.

  6. I didn’t hear the answer to the obvious question –

    Will Relay Health unequivocally commit to never sell or sell access to the data?

    Every Relay Health agreement and every earnings call from McKesson tout the revenue from Relay.

    Where is the absolute commitment?

    Can’t anyone in this group make it?

  7. Commonwell is indeed a trade organization.

    Like all other trade organizations, Commonwell’s goals include influencing public policy and standards in a way that is beneficial to its corporate members. As an example, Commonwell advocates for universal identification numbers, without making any statements about impact on privacy.

    Ultimately, Commonwell is not about interoperability. Commonwell exists to maximize the profits of its corporate members.

  8. Thank you to the readers who have contributed to the CommonWell Q&A discussion. We appreciate your interest and feedback. Here are a few remarks in response to some of your comments.

    First, let us be clear that neither CommonWell Health Alliance nor our Service Provider will sell patient data. Our contracts do not allow that. CommonWell charges a fee to recover the costs of operating a national-scale service, but not to make a profit.

    We agree that patients expect that their providers should have access to their complete record. The question of who should pay for that capability is complex. Should the patient pay? Should the payer pay? Should the government pay? We are all paying for health data exchange today, but in an inefficient and costly manner. CommonWell’s approach is to deploy an efficient, national-scale system that makes such a service as seamless and inexpensive as possible. We then let our members decide what to do about passing that cost along.

    CommonWell takes patient privacy very seriously. CommonWell is an opt-in service. If a patient doesn’t want their providers to use the service, then they can simply choose not to enroll with CommonWell. We plan to provide more granular control in the future, but for now, any patient can simply decline to enroll. CommonWell works as an MPI that links existing “strong identifiers” (such as a driver’s license) and therefore does not create a new national identity.

    On security – CommonWell’s members are all HIT companies who deal with securing patient data every day. There are no non-HIT companies involved in the service, by design.

    And finally, the Argonaut effort is a group of vendors and providers funding the acceleration of standards development. There is no “product” to sell.

    Thank you – David, Jitin, Nick, Dan, and Bob.

  9. I work for Cerner, one of the member companies, but I’m speaking as a patient and parent. I’m glad something like CommonWell will be there. I have an autoimmune condition and have had to see a variety of specialists over the years – GI, endocrinologist, rheumatologist/immunologist, dermatologist to mention a few. One of my kids has multiple chronic conditions and has also seen a variety of docs. I have a parent with cancer, and I manage his records. We all need the ability to give consent and have our ‘next’ physician be able to pull our records together. Having 12 portals to manage isn’t doing it for me. 🙂 I’ve had the chance to drop in on one or two CommonWell meetings, and the people there are busy talking about how to solve problems, not how to make money. Relay isn’t CommonWell, they’re a contracted service provider to CommonWell. I don’t know any not-for-profit who expects their vendors to work for free, so it doesn’t bother me in the slightest. At Cerner, Neal has told associates (employees) that interop doesn’t yield a competitive advantage – because ultimately everyone has to be ‘in’ for it to work. It’s just the right thing to do. As far as waiting for the federal government does, when Farzad was ONC Director, he expressly said that there were problems the federal government wasn’t going to solve and he practically implored the private sector to step up with solutions. CommonWell’s scope is limited to things that didn’t have a federal solution. From my understanding, it’s designed to fill gaps.
    Once Cerner & Siemens close in a few weeks, CommonWell members will represent 50% of the acute space (going by KLAS market share). It’s enough to make a meaningful difference for patients. I hope Meditech & Epic join. Or if they don’t, I at least hope they consider forming their own network with similar properties that can connect with CommonWell. I want to be able to give consent and have my next doc be able to pull together my records, or my son’s, or my dad’s.

  10. Patient/parent,

    Could just be my bias, but seems a bit strange to me that you think the best solution to your personal health data portability needs (and most of us are in your shoes for ourselves and/or our loved ones) is to have your employer, noble as they might be, be the controller of who can and can’t have access to the data that you and your loved ones want to make available to any provider (no matter what vendor product they do/don’t use, where in the world they are located, or even if they do/don’t have an EHR).

    It’s YOUR data!

    Don’t you also want control of your own copy of those records so you can be sure that any provider of any kind anywhere in the world can access them any time you say so – whether they are on the CommonWell network or not? So that you can donate your data for clinical research to help advance cures for your conditions and those of your loved ones, if you so choose? So that the data is available when you use tele-health services, or ad-hoc urgent care, or a small concierge healthcare provider, or a community pharmacist? So that you can connect any personal health monitoring devices, any smartphone-OS APIs and apps, etc. you choose?

    Or do you think all those agendas will best be served by leaving it to the large HIT vendors to control/manage that for you, build networks of contractual relationships among each other, and thereby determine what the scope of the sharing of your data should be (as an example as per your note – either the 50% of the acute space that controls your data will or won’t join up with the other half – you can only “hope” they will…).

    Not saying there is anything wrong with CommonWell, and I am also an interested party here (and not commenting anonymously)… I believe Mr. H. is going to soon be publishing an article of mine that tries to deliver this message in a less direct way…

    Best of health to you and your family!

    Brian Weiss
    Carebox Healthcare Solutions, Inc.

  11. Brian Cox, I couldn’t agree more that it’s my (damn) data. 🙂 I’m a big believer in the idea of independent health record banks. I would actually like to be able to ‘will’ my health data to my children and/or science. I use the Blue Button for my dad’s VA EHR data; despite some limitations, I like it. I think of CommonWell as an ‘AND’ – not an ‘OR.’ CW is something that is possible and improves care today – and does so by going straight to the sources of the data, the vendors. CommonWell views my consent as essential to the process of gathering records. I like that I can give that consent ahead of time if I want. If I’m wheeled into an ER unconscious, there’s a record of my consent to have my records brought together.

    The CW bylaws would never allow Relay or any members to hoard or block my data. They would lose complete credibility. The future of CW is definitely to allow a means for patients themselves to view and download their own data. Dr. McCallie or one of the interviewees can probably speak better to the barriers and practical issues that have to be solved. I would love for the federal government to have already solved the interop issue. 50% of my data is better than 0% of my data. And since it works and it’s open to all vendors, I’m optimistic the other companies will join, too, or at least figure out a way to connect and share.


  12. Hello Brian,

    What you are describing sounds a lot like a Health Record Bank (HRB.) We (at Cerner) have long been fans of the HRB model. In fact, we lobbied Congress aggressively (pre-HITECH) for legislation that would smooth the creation of patient-controlled HRBs.

    But HRBs have lots of problems:

    * So far, no one has found a way to fund them.
    * Providers are less likely to trust clinical data that is managed outside of HIPAA and under consumer control. This is largely because provider-authored documents are not (yet) digitally signed, and thus could be easily tampered with.
    * HRBs would require consumers to take charge of their record, and so far, no one has found the right incentives to cause that to happen at anywhere near the scale it would take to be successful.
    * Providers would have to all agree to a consensus standard on how to connect their EHRs to the HRBs. No such technical or political consensus exists.
    * Providers would have to all agree on a way to identify their patients to the right HRB, since patients won’t always be able (or interested) in providing a verifiable HRB identity for the providers.
    * HRBs would require central storage of large aggregations of PHI, which to many would present an unacceptable security risk, especially if the data was managed outside of a HIPAA environment.

    Of course, these are not unsolvable problems, but we (founders of CommonWell) believe that a non-centralized, EHR-based, federated model is an easier way to get most of the benefits of a HRB model.

    * The patient is in control. They can choose to enroll, or not.
    * The patient does not have to take any action other than to enroll.
    * It’s free to patients.
    * The data is already in a secure location (the various EHRs)
    * The data is already protected under the HIPAA privacy and security rules.
    * The data is already trusted by providers (via secure provider to provider access under a cryptographic trust model.)
    * The MPI and Record Locator problems are solvable, as CommonWell has demonstrated.
    * Query and access of remote documents (via XCA) is already built in to the workflow of most EHRs, so there minimal changes for providers.

    As you can imagine, it would not be a large step for CommonWell to provide consumers with access to their own record, and to enable consumer download of a full copy. I am not (in this reply) speaking for CommonWell but I am pretty sure CommonWell will enable that functionality in the future. In the mean time, CommonWell seems very close to the vision of each patient being able to grant provider access to their full record. That seems like a pretty good starting point.

  13. David,

    Thanks for the thoughtful response.

    HRB model is a reasonable initial characterization, though in a post-MU2 world we need to update some of the thinking associated with that term. What I am describing is not tough to characterize – I’ve founded a company focused on making it work and it’s described on my web site linked from this comment.

    So that we’re on the same page, we’re talking about the patient in the role of CUSTODIAN (not PHR-style active editor) of their data. Let’s get providers to be good EHR editors before we get consumers to try and do that – no argument there… The degree to which consumers need to “take charge” of their records is to know there is a copy in a safe place that they (or any caregiver or provider of their choosing anywhere in the world at any time) can access, and that allows the consumer to decide who else gets a copy (in addition to everyone who already does today, in processes in which the consumer has no say – like everyone in CommonWell, in the payment chain, etc). That’s it.

    No need to leave the framework of HIPAA. Not at all clear to me why CDAs stored on a very well governed and audited (and HIPAA-compliant) platform like Box are more at risk of being tampered with than those in the data stores of any current CommonWell participant. But I’m sure we can work out whatever is required for you to be comfortable there.

    I don’t think we need any new standards or political will. Not even FHIR. All we need is for everyone to follow the spirit and the letter of HIPAA and MU2 as already in place. MU2-compliant CDAs are imperfect, but they’re more than enough to get started. They can also be digitally signed (though I personally think that is total overkill).

    The elusive “EHR-HRB” interface can be as simple as MU2 CDA over DIRECT. The verifiable identity is a DIRECT address (which can be keyed to a consumer’s regular e-mail address). If you want to do it with XCA, that’s fine.

    I believe we will find it is actually quite trivial to “incentivize” patients to give their e-mail address to every provider, lab, clinic, pharmacy, urgent care center, tele-health service, wearable device network, etc. in exchange for having an up-to-date copy of their record deposited in their Carebox with zero effort on their part.

    Carebox will be free for patients and I don’t think we’ll have any problem getting everyone (other than the EHR vendors) to fund this for consumers in exchange for data access that patients can authorize.

    I’d like to be worried about the fact that if everyone had their data in Carebox (effetively, in Box) it would be too “centralized” and dangerous (as opposed to say, everything else in cloud storage in the world today). Right now I’m just trying to get the next round of funding for my startup, so you’ll forgive me for being more worried about how much data is centralized in the largest Cerner or Epic installations right now – or in Medicare or the VA.

    How about we write it up and put it to a vote here on HISTalk? You outline what’s good about your model and bad about mine as you’ve started to do above, and I’ll do the same? Let’s ask consumers whose definition of “consumer control” they prefer. Let’s ask providers (not EHR vendors) if they would trust something queried and pulled from the CommonWell XDS repository or their local HIE using your MPI matching algorithm but not from an alternate XDS repository keyed to a patient-provided e-mail address. The source data is identical – CDAs flowing from the EHR system of the provider that generated the data.

    Anyway, I’m sure my little company doesn’t have it all figured out yet. Very encouraged to hear that Cerner is a supporter of this direction as I have no doubt you and others there can help surface the challenges and get us to converge on better solutions. I look forward to continuing the discussion, if you and others at Cerner are interested.

    Indeed it would be trivial for CommonWell to deposit a patient’s record in Carebox and a patient’s request. This would also instantly provide Patient/parent above with the ability to access all CommonWell data in any context – including visiting a provider using a non-CommonWell EHR.

    I think a developer of mine and one of yours can have a prototype working in a week or two. We can limit availability initially to only those consumers/patients who provided their providers with a verified e-mail address (like the one they use to access the provider’s patient portal). Can be commercially ready by HIMSS. Along the way we’d be helping all your customers with MU2 compliance on the part everyone is crying about (getting 5% of patients their data).

    When do we get started?


  14. Patient/parent,

    We’re on the same page for sure. CommonWell can indeed be a step in the right direction… or not.

    I don’t want to get you in hot water with your current employer… but I encourage you to not take high-sounding answers at face value… “secure provider to provider access under a cryptographic trust model”… “providers won’t trust the data”… “can’t digitally sign it”… “no way to fund it”… “consumers are not incentivized enough…”. To quote one of the critics on my recently posted article… Really?

    The CW bylaws don’t block or hoard your data? Great! So why don’t you have a copy right now? HIPAA says you are absolutely entitled to it and every MU2-compliant EHR or patient portal can give it to you TODAY in the same format CommonWell is interchanging.

    You can sign up for a pre-release version Carebox on my site. You even get a QR scan-code for your pocket or mobile device that anyone can use to get at your CW (and other) data in an emergency (HIPAA says in emergency settings they can “break the glass” without advance consent) – even if you happen to get wheeled into an ER overseas or at a provider not yet in CommonWell. But someone like you who is already using Blue Button can manage just fine without Carebox as well, so don’t let that be your gate…

    Please join me in asking CommonWell members and the providers using their systems to make it easy for you (as they absolutely can using only features already in their MU2-compliant EHRs, and as the letter and spirit of the law say they should) to get your data (including what they can query using CommonWell) into Carebox (or anywhere else you want). And when they explain to you “the barriers and practical issues that have to be solved” – please send those my way and then you can be the judge of their claims and my counter-claims.

    Just tell them you’re already incentivized and self-funded…. 🙂

    And be sure to let me know if a doctor that you send your CDA to (you can do that for free using Box and DIRECT – I’m already tooting my own horn here too much, so contact me offline for details on that) doesn’t trust it because they think you tampered with it…


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