Sept. 4, 2020 – CommonWell Health Alliance submitted comments to the Office of National Coordinator (ONC) at the Department of Health and Human Services regarding its Request for Information on experiences with patient matching. As part of our work as a national network enabling access to patient records for multiple use cases including both providers and patients themselves, CommonWell has come to understand that there are two distinct issues at play when it comes to the problem of patient identity and matching: – first, the need to properly identify that a person is who they claim to be, and second, the need to match a person’s records across systems and to the identity of the person.
CommonWell encourages a system that applies a high level of trust to the identity of a person as well as a unique healthcare patient identifier that can be matched with that identity. This system should be a multi-method approach that takes into account the identification issues inherent in the population of the United States.
CommonWell supports ONC and our shared efforts to improve patient outcomes across the health care continuum, provide safe and secure access to clinical records for those who have a right to them, and safeguard against wrongful disclosures. We encourage ONC to work across agencies to build upon the person identity work that is already in process.