Data Segmentation of Sensitive Information

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Comment

Is Federally required accurate?

Federally required, MU2015 this was an optional certification criteria at the document level for DS4P, is Federally required accurate if optional or does that apply to use of this IG?

CDA DS4P segmentation applied to section level. CDA Privacy Segmented Section-may apply to any section of a C-CDA document if that section metadata (sensitivity, confidentiality) is different than the document's overall

This IG needs further development.  The concept that a section is more private then the document is pointless. The Document privacy should be inherited from the most private section. Esp. when the MU2015 optional certification was limited to document level privacy. 

Pharmacy HIT Collaborative's Comments on ONC's Proposed 2018 ISA

The Pharmacy HIT Collaborative supports the use of Consolidated HL7 Implementation Guide: Data Segmentation for Privacy (DS4P), Release 1; HL7 Clinical Document Architecture (CDA), Release 2.0, Final Edition and IHE IT Infrastructure Technical Framework Volume 4 – National Extensions – Section 3.1 Data Segmentation for Privacy (DS4P). The Collaborative also supports Consent2Share FHIR Consent Profile Design, which is in development.