FHIN Public Comment - Central Florida RHIO

Florida Health Information Network – Request for Public Comment Date Submitted: December 11, 2006 Submitted by: John R. Schooler, FACHE VP & CIO Orlando Regional Healthcare 1414 Kuhl Avenue MP5 Orlando, Florida 32806-2093 (321) 841-8000 (office) (407) 648-0053 (fax) rick.schooler@orhs.org - 1 - Florida Health Information Network – Request for Public Comment 1. The impetus for considering a FHIN is to achieve interoperability of health information technologies used in the delivery of care in Florida as specified in s. 408.062, (5), F.S. Is the working definition of the Florida Health Information Network provided by the Agency in the white paper appropriate? Should it be modified? And if so, in what way? Comment: In general, it seems the intent of achieving interoperability could be met as defined in the Draft White Paper, although certain aspects of the technical architecture and related functionalities should be further considered. While robust, the Draft White Paper presents a FHIN design that may result in extreme transaction volumes and functional processing given established RHIOs throughout the state of Florida. More specifically, it is suggested that further discussion be held with RHIO stakeholders regarding the following: User credentialing and authorization – consider information capture and FHIN/RHIO authorization to occur at the local RHIO level, with credentialing information to be passed to the FHIN from the RHIO. ...