ganization. This entity—whether identified among existing
groups or created anew—may also require seed funding and
assistance in launching these activities.
Second, government agencies should consider policies to
advance a nationwide strategy. ONC could update its certification criteria to add minimum data sets or other best practices, evaluate how to measure matching between facilities,
and foster development of a universal data sharing agreement
(which ONC is expected to release this year21). The Centers for
Medicare and Medicaid Services could consider revising its
policies, such as by amending its conditions of participation,
working with the Joint Commission on adding patient matching practices to hospital accreditation, or developing other
regulatory clarifications needed to assuage concerns about
sharing data. Given that Congress has prevented the federal
government from establishing a national patient identifier,
lawmakers should assess whether additional clarifications
are needed for agencies to support a nationwide strategy. State
governments can also clarify or harmonize privacy policies
that inhibit matching or data exchange.
Finally, legal and cultural challenges must be considered.
Some organizations may fear liability when sharing data or
resist increased patient control. And some individuals may be
uncomfortable using biometrics or other technologies, or they
may be concerned about the security of medical information
used for matching. Congress should assess whether the imple-
mentation of a nationwide strategy would benefit from appro-
priate clarifications, work with the private sector in enacting
policies, and evaluate the need for additional safeguards to
protect privacy while still ensuring that medically appropriate
data can be communicated.
By enacting a nationwide strategy that embodies these characteristics, hospitals, technology developers, and the broader
healthcare ecosystem can tackle one of medicine’s greatest
challenges: the ability to better link patients to their records to
improve care coordination and reduce costs. ¢
1. Lippi, Giuseppe et al. “Patient and Sample Identification.
Out of the Maze?” Journal of Medical Biochemistry 36, no.
2 (April 22, 2017): 107-112. https://doi.org/10.1515/jomb-
2. Harris Health System. “Harris County Hospital District
Puts Patient Safety in the Palm of Your Hand.” www.pr-
3. College of Healthcare Information Management Executives. “Summary of CHIME Survey on Patient Da-
Advancing a Nationwide