- 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.