HRBA submits comments on Cures Act 2.0 to Representatives Diana DeGette and Larry Bucshon MD
22 July 2024: HRBA submits comments on Cures Act 2.0 to Representatives Diana DeGette and Larry Bucshon MD.
8 August 2023: HRBA submits comments to Federal Trade Commission on their Breach Notification Proposed Rule Making, pointing out the inherent security weaknesses of TEFCA.
25 January 2023: HRBA submits comments to an RFI from the White House Office of Science and Technology Policy on Clinical Research Infrastructure and Emergency Clinical Trials.
25 January 2023: HRBA submits comments to an RFI from the White House Office of Science and Technology Policy on Data Capture for Emergency Clinical Trials and Interoperability Pilot.
6 December 2022: HRBA submits comments to CMS on National Provider Directory.
17 September 2021: HRBA sends comments to ONC and its “Recognized Coordinating Entity” (RCE) to show how the RCE’s plans for the “Qualified Health Information Network Technical Framework” conflict with the 21st Century Cures Act, and thus should be abandoned and re-drafted to comply with the Act.
1 June 2021: HRBA sends a letter to ONC's Dr. Micky Tripathi requesting elimination of the Broadcast Query and advocating for a new structural layer in US healthcare based on Problem-Oriented Health Data Banks.
1 June 2021: HRBA sends a letter to the Honorables Diana DeGette and Fred Upton, principal authors of the 21st Century Cures Act, recommending engineering and policy pillars for Cures Act 2.0 anchored on Problem-Oriented Health Data Banks.
6 April 2021: HRBA’s 2021 Systems Design Proposal for Interoperable Health Data Exchange Under the Cures Act. This overview describes HRBA’s systems design for nationwide exchange of digital health data. We explain “Health Data Banks.” Consumers will have accounts like checking accounts, but for health data instead of money. Individuals’ data will be gathered from doctor and hospital visits. This will soon be possible – assuming new federal “interoperability” regulations are faithfully implemented under the 21st Century Cures Act of 2016. Enabling technology mandated by the Cures Act means most health data exchange can be point-to-point, such as hospital to patient, patient to doctor, or individual to medical research project, avoiding older, more complex data interchange architectures.
4 January 2021: HRBA submits comments to CMS on their proposed rule to Reduce Provider and Patient Burden and Promote Patients’ Electronic Access to Health Information.
9 February 2020: HRBA submits letter to HHS Secretary Alex Azar.
24 January 2020: HRBA Letter to the Office of Management and Budget concerning the Proposed Rule to implement the 21st Century Cures Act.
17 June 2019: HRBA Comments on ONC TEFCA2, submitted to ONC.
3 June 2019: HRBA Comments on ONC Proposed Rule on 21st Century Cures Act, submitted to ONC.
4 September 2018: HRBA Comments on Centers for Medicare and Medicaid Services (CMS) CY19 Physician Fee Schedule Proposed Revisions, submitted to CMS.
24 June 2018: HRBA Comments on Centers for Medicare and Medicaid Services (CMS) CY19 Inpatient Prospective Payment System Proposed Revisions, submitted to CMS.
20 Feb 2018: HRBA Comments on Draft Trusted Exchange Framework and Common Agreement (TEFCA), submitted to ONC.
24 Aug 2017: HRBA Comments on 21st Century Cures Act rule making, submitted to ONC.
Also, HRBA has written a white paper on a National Health Data Exchange Standard (4 June 2018).
8 August 2023: HRBA submits comments to Federal Trade Commission on their Breach Notification Proposed Rule Making, pointing out the inherent security weaknesses of TEFCA.
25 January 2023: HRBA submits comments to an RFI from the White House Office of Science and Technology Policy on Clinical Research Infrastructure and Emergency Clinical Trials.
25 January 2023: HRBA submits comments to an RFI from the White House Office of Science and Technology Policy on Data Capture for Emergency Clinical Trials and Interoperability Pilot.
6 December 2022: HRBA submits comments to CMS on National Provider Directory.
17 September 2021: HRBA sends comments to ONC and its “Recognized Coordinating Entity” (RCE) to show how the RCE’s plans for the “Qualified Health Information Network Technical Framework” conflict with the 21st Century Cures Act, and thus should be abandoned and re-drafted to comply with the Act.
1 June 2021: HRBA sends a letter to ONC's Dr. Micky Tripathi requesting elimination of the Broadcast Query and advocating for a new structural layer in US healthcare based on Problem-Oriented Health Data Banks.
1 June 2021: HRBA sends a letter to the Honorables Diana DeGette and Fred Upton, principal authors of the 21st Century Cures Act, recommending engineering and policy pillars for Cures Act 2.0 anchored on Problem-Oriented Health Data Banks.
6 April 2021: HRBA’s 2021 Systems Design Proposal for Interoperable Health Data Exchange Under the Cures Act. This overview describes HRBA’s systems design for nationwide exchange of digital health data. We explain “Health Data Banks.” Consumers will have accounts like checking accounts, but for health data instead of money. Individuals’ data will be gathered from doctor and hospital visits. This will soon be possible – assuming new federal “interoperability” regulations are faithfully implemented under the 21st Century Cures Act of 2016. Enabling technology mandated by the Cures Act means most health data exchange can be point-to-point, such as hospital to patient, patient to doctor, or individual to medical research project, avoiding older, more complex data interchange architectures.
4 January 2021: HRBA submits comments to CMS on their proposed rule to Reduce Provider and Patient Burden and Promote Patients’ Electronic Access to Health Information.
9 February 2020: HRBA submits letter to HHS Secretary Alex Azar.
24 January 2020: HRBA Letter to the Office of Management and Budget concerning the Proposed Rule to implement the 21st Century Cures Act.
17 June 2019: HRBA Comments on ONC TEFCA2, submitted to ONC.
3 June 2019: HRBA Comments on ONC Proposed Rule on 21st Century Cures Act, submitted to ONC.
4 September 2018: HRBA Comments on Centers for Medicare and Medicaid Services (CMS) CY19 Physician Fee Schedule Proposed Revisions, submitted to CMS.
24 June 2018: HRBA Comments on Centers for Medicare and Medicaid Services (CMS) CY19 Inpatient Prospective Payment System Proposed Revisions, submitted to CMS.
20 Feb 2018: HRBA Comments on Draft Trusted Exchange Framework and Common Agreement (TEFCA), submitted to ONC.
24 Aug 2017: HRBA Comments on 21st Century Cures Act rule making, submitted to ONC.
Also, HRBA has written a white paper on a National Health Data Exchange Standard (4 June 2018).
WHAT IS THE HRBA?
HRBA Vision
Every consumer can own a secure, consolidated, digital lifetime health record that they may share with doctors, researchers, and others for better health and health care.
HRBA Mission
The non-profit Health Record Banking Alliance advocates for a trusted network of private sector organizations that offer accounts to solve the problem of scattered health information plaguing consumers today.
The Health Record Banking Alliance (HRBA) is a 501(c)(6) non-profit membership organization with the goal of establishing accurate, secure, and comprehensive health records that can be accessed by both patients and their health care providers under the control of the individual patient. We do not sell anything and we are not developing a product. We are a think tank, an education group, a discussion forum, and an advocacy organization for each consumer having their own comprehensive, lifetime, unified health record. We are supported by membership fees from individuals, small companies, and corporations who believe in our mission and vision. We are evaluating personal health record/health record bank services and products now and will be posting our assessments as they occur.
WHAT IS A HEALTH RECORD BANK?
A Health Record Bank (HRB) is a repository that stores a copy of the medical records that each of a patient's providers keeps in his or her office's electronic health record for that patient. The patient controls who may access which parts of the information in his or her HRB account. When patients seek care, they give permission for their health care provider to access some or all of their up-to-date health records. When care is complete, the new records from that encounter are deposited into the HRB and securely stored for future use under the patient’s control. If a consumer changes insurance, switches providers, or moves to another community, they still have all of their health records in one place, ready to inform any new provider that they might see. Providers benefit from health record banks by being able to go to just one place to learn about most or all of the patient's previous medical visits.
Modern Personal Health Records (PHRs) and Health Record Banks (HRBs) are largely the same thing. However, unlike PHRs of the past, HRBs collect and reconcile copies of professional health records for a patient in such a way that providers can rely on them as authentic as if the provider had requested records directly from each of the other providers seeing the patient. Modern PHRs and HRBs store not only copies of office medical records, but also records and diagnostic images (like X-rays, CT scans, and MRI studies) from labs, outpatient facilities, hospitals, skilled nursing facilities, and long-term care organizations. Consumers can also upload personally-entered data from their mobile phones and their personal and home devices for viewing alongside their professional medical records.
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