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Comment: update to sensitive health data content.

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  • The old health plan does not have the original provider order (e.g.: MedicationRequest, ServiceRequest, etc.) and all they have is the claim or dispense record (e.g.: from a PBM).

2. Sensitive health data

  • consider the privacy requirements at the state-level.
  • consider the source of the old health plans if there were several.
  • assumption: the most recent (last) plan are the source for all health sensitive data management. - focus is on continuity of care, not member portability.