Existing Wording: Payers need to create complete, accurate risk profiles for members

Comment:

Risk profiles can be used to discriminate against patients or delay care. This use case fails to provide sufficient protections to ensure patient access to care. Profiling is often leveraged to deny claims or patient coverage for services and can increase burdensome prior authorization for a patient's needed medication, services, or devices. The AMA strongly recommends CDex use cases be scoped to accommodate payment, billing, and narrowly defined "health care operations".

Summary:

The creation of risk profiles could discriminate against vulnerable patients or lead to barriers to needed patient care. This use case needs the additiona of significant patient protections.