Thread by @amalec

1/

Who is a Heath Information Network under #CuresNPRM?

Easy, right? a HIN is a network that shares health information, yes?

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"Health Information Network or HIN means an individual or entity that satisfies one or both of the following—
(1) Determines, oversees, administers, controls, or substantially influences policies or agreements that define business, operational, technical, or…"

3/

"other conditions or requirements for enabling or facilitating access, exchange, or use of electronic health information between or among two or more unaffiliated individuals or entities."

4/

"(2) Provides, manages, controls, or substantially influences any technology or service that enables or facilitates the access, exchange, or use of electronic health information between or among two or more unaffiliated individuals or entities."

5/

OK & let's always remember that "electronic health information" is "Any… information that identifies the individual, or with respect to which there is a reasonable basis to believe the information can be used to identify the individual and…"

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"is transmitted by or maintained in electronic media,… that relates to the past, present, or future health or condition…; the provision of health care…; or the past, present, or future payment for the provision of health care to an individual."

7/

So, is @CarequalityNet an HIN subject to penalty? "Determines, oversees, administers, controls, or substantially influences policies or agreements" ✅

Vendor of exchange technology who does not provide services? "Provides…any technology" ✅

8/

Clearinghouse? "enables or facilitates the access, exchange, or use of EHI [past present, or future payment] between or among two or more unaffiliated individuals or entities" ✅

Billing service? ✅

9/

Bank, ACH, card payment? Surely a bank isn't an HIN?

"past present, or future payment", linked back to remit/claim, which identifies the patient, "two or more unaffiliated individuals or entities" ✅

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Records retrieval service? ✅

@AledadeACO? ✅

The challenge is identifying what's *NOT* an HIN....

11/

Is that OK?

Only if you are comfortable with your pricing compliance to 171.204/206....

Which you aren't

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