We oppose unfettered access into a clinician EHR by a payer. There are ways for payers to alert providers of potential alternative treatments that would improve outcomes for patients with particular conditions that do not involve a fishing expedition in the EHR. Payers do NOT use EHR access to do this. They do similar notifications today based on claims data – for example, they can ID patients on certain meds based on claims data and notify clinicians that these specific patients may benefit from a switch. (This is done when plans are making formulary changes.)

Existing Wording:

The payer uses SPARQL to access the EHR's clinical data to identify such patients and make recommendations to the patient's capitated care provider.