Patient Request for Corrections FHIR Implementation Guide Project (PSS in Confluence)

Now that patients have the ability to download their data into FHIR applications, they are finding errors in their data. Currently, no FHIR implementation guide exists to standardize the method of electronically exchanging the required information to facilitate the patient’s request for corrections to their information. This implementation guide will provide a FHIR based standard for the communication of required data elements according to the HIPAA implementation guidelines.

HIPAA has a very detailed implementation specification for a patient’s request for corrections to their information. (See regulation here: https://www.govinfo.gov/content/pkg/CFR-2003-title45-vol1/xml/CFR-2003-title45-vol1-sec164-526.xml) This process is usually handled via mail or phone conversations, making a “paper trail” more difficult to manage. It is also very burdensome for patients and health organizations because of the lengthy process of exchange of information through mail or multiple phone calls. As portals have become more popular since the initial release of this HIPAA regulation, some patients and health organizations have begun to manage the request electronically.

HIPAA and GDPR are very similar in their regulations concerning patients’ rights to have their data corrected. There are minor differences in the period of time for covered entities to respond to the patient’s initial request for corrections and the preference in GDPR for a means for patient requests to be made electronically. GDPR has no detailed implementation specification, so we will use the HIPAA specifications for our basis because it includes the patient rights outlined in both regulations. Our goal is to consider patient corrections in a global context but our focus in this guide is to follow the HIPAA implementation guidelines due to the details provided in that guide.