Perhaps we are misunderstanding what “their local practitioner registry” refers to, but if it is taking information housed by a practitioner and syncing it to a different registry, doesn’t the payer need to seek appropriate permissions to do so from the local practitioner registry? Will likely depend (from a HIPAA perspective) on the purpose of the synchronization. Also would require a way to deal with PHI requiring additional consents from the patient prior to redisclosure (e.g., Part 2 data).

Existing Wording:

A payer is synchronizing their local practitioner registry with a centralized registry