Unlisted SMART App Vetting Process

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jol...@smcpartners.com

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Jan 24, 2019, 12:48:33 PM1/24/19
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We are developing a SMART app for a client and they have reached out to us for information on what the vetting process is to move the app from the test environment to production. We will not be listing our app in the Cerner App Gallery so we are not planning on going through the Cerner CODE submission process. Are there any available resources related to this topic?

Yegor Hanov (Cerner)

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Jan 25, 2019, 10:30:17 AM1/25/19
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Who is going to own the IP rights for this application?  Is it the client?  Is this intended for use at multiple client sites after it goes live?

-Yegor (Cerner)

Mark Butler

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Jan 25, 2019, 2:13:10 PM1/25/19
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Tagging because I'm in the same boat.

In my case IP rights are going to remain with the client. 

Seth Merritt

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Jan 25, 2019, 2:20:51 PM1/25/19
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Same here. In our case, we will own the IP and will be working with multiple clients on an AD hoc basis.

L.H.D. Mulder

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Jan 25, 2019, 2:22:27 PM1/25/19
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Same here.

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yalini

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Jan 25, 2019, 2:38:35 PM1/25/19
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Same here.


---- On Fri, 25 Jan 2019 09:22:24 -1000 'L.H.D. Mulder' via Cerner FHIR Developers <cerner-fhir...@googlegroups.com> wrote ----

Yegor Hanov (Cerner)

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Feb 1, 2019, 4:03:05 PM2/1/19
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There are several different scenarios involved here with some variance based on whether the app ownership belongs to the client organization or developer.  There is also some additional considerations based on differences between provider apps and consumer apps.  There is also and an additional caveat for consumer apps related to scope of use of the API in relation to Meaningful User, Stage 3 definition of Common Clinical Data Set.  A lot of this is already described in some detail on our program website [1][2], but I will provide an abbreviated summary here as well.

1.  Application is "owned" by a Cerner client organization.  In this scenario, Cerner provides a set of tools and a support process to assist clients in development, testing and access provisioning of apps to their own domains.  App development and deployment is completely up to the client and no validation is needed, unless it is desired by the client.  We simply assist in moving things along as needed.  Sometimes clients contract with third party developers to help with actual coding with the expectation that ownership of the app at the end of development project stays with the client and there are no plans to market this app to other clients.  

2.  Third party developer building a provider application.  In the scenario developer has to enter into developer program agreement (DPA) with us [2].  DPA involves agreement on business terms and, generally, includes app validation by Cerner before it can be listed in the app gallery [3] and marketed to clients.  

3.  Third party developer building a consumer application within the scope of MU3 CCDS definition.  In this case, developer has to register the app in our system using self-service console [4] to make the app known to our API.  Developer do not have to enter into a program agreement with Cerner and do not have to go through validation, unless it is desired by the developer.  After app identity is created in our system developers can engage directly with our clients, who will in turn request provisioning of that app for access to their environment.  (Note - This has been a topic of hot debates in a variety of forums, including this group.  Our present position is that we have to have our client's approval before granting consumer app access to their environment.  We intend to keep improving the overall process and tooling as we mature our product and comply with anticipated regulatory requirements.)

4.  Third party developer building a consumer application outside of the scope of MU3 CCDS definition (eg Appointment Scheduling).  This is very similar to Scenario 2 above in that developer has to enter into program agreement with us and get the app validated, if applicable within DPA, before marketing it to our clients.


-Yegor (Cerner)


On Friday, January 25, 2019 at 1:38:35 PM UTC-6, yalini sen wrote:
Same here.


---- On Fri, 25 Jan 2019 09:22:24 -1000 'L.H.D. Mulder' via Cerner FHIR Developers <cerner-fhir-developers@googlegroups.com> wrote ----

Same here.

On Jan 25, 2019, at 2:20 PM, Seth Merritt <mash...@gmail.com> wrote:

Same here. In our case, we will own the IP and will be working with multiple clients on an AD hoc basis.

On Thursday, January 24, 2019 at 9:48:33 AM UTC-8, jol...@smcpartners.com wrote:
We are developing a SMART app for a client and they have reached out to us for information on what the vetting process is to move the app from the test environment to production. We will not be listing our app in the Cerner App Gallery so we are not planning on going through the Cerner CODE submission process. Are there any available resources related to this topic?

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Rob Dingwell

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Feb 1, 2019, 4:43:11 PM2/1/19
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Yegor, 

Thanks for that summary, it's very helpful.  

For the scenario where a developer creates an open source smart on fhir capability I imagine that can basically fall into scenario 1.  In that case the Cerner site is choosing to host the application and installs it locally as if they own the application, correct? 

Rob 

On Fri, Feb 1, 2019 at 4:03 PM Yegor Hanov (Cerner) <yegor...@gmail.com> wrote:
There are several different scenarios involved here with some variance based on whether the app ownership belongs to the client organization or developer.  There is also some additional considerations based on differences between provider apps and consumer apps.  There is also and an additional caveat for consumer apps related to scope of use of the API in relation to Meaningful User, Stage 3 definition of Common Clinical Data Set.  A lot of this is already described in some detail on our program website [1][2], but I will provide an abbreviated summary here as well.

1.  Application is "owned" by a Cerner client organization.  In this scenario, Cerner provides a set of tools and a support process to assist clients in development, testing and access provisioning of apps to their own domains.  App development and deployment is completely up to the client and no validation is needed, unless it is desired by the client.  We simply assist in moving things along as needed.  Sometimes clients contract with third party developers to help with actual coding with the expectation that ownership of the app at the end of development project stays with the client and there are no plans to market this app to other clients.  

2.  Third party developer building a provider application.  In the scenario developer has to enter into developer program agreement (DPA) with us [2].  DPA involves agreement on business terms and, generally, includes app validation by Cerner before it can be listed in the app gallery [3] and marketed to clients.  

3.  Third party developer building a consumer application within the scope of MU3 CCDS definition.  In this case, developer has to register the app in our system using self-service console [4] to make the app known to our API.  Developer do not have to enter into a program agreement with Cerner and do not have to go through validation, unless it is desired by the developer.  After app identity is created in our system developers can engage directly with our clients, who will in turn request provisioning of that app for access to their environment.  (Note - This has been a topic of hot debates in a variety of forums, including this group.  Our present position is that we have to have our client's approval before granting consumer app access to their environment.  We intend to keep improving the overall process and tooling as we mature our product and comply with anticipated regulatory requirements.)

4.  Third party developer building a consumer application outside of the scope of MU3 CCDS definition (eg Appointment Scheduling).  This is very similar to Scenario 2 above in that developer has to enter into program agreement with us and get the app validated, if applicable within DPA, before marketing it to our clients.


-Yegor (Cerner)


On Friday, January 25, 2019 at 1:38:35 PM UTC-6, yalini sen wrote:
Same here.


---- On Fri, 25 Jan 2019 09:22:24 -1000 'L.H.D. Mulder' via Cerner FHIR Developers <cerner-fhir...@googlegroups.com> wrote ----

Same here.

On Jan 25, 2019, at 2:20 PM, Seth Merritt <mash...@gmail.com> wrote:

Same here. In our case, we will own the IP and will be working with multiple clients on an AD hoc basis.

On Thursday, January 24, 2019 at 9:48:33 AM UTC-8, jol...@smcpartners.com wrote:
We are developing a SMART app for a client and they have reached out to us for information on what the vetting process is to move the app from the test environment to production. We will not be listing our app in the Cerner App Gallery so we are not planning on going through the Cerner CODE submission process. Are there any available resources related to this topic?

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L.H.D. Mulder

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Feb 1, 2019, 4:43:51 PM2/1/19
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Yegor,

Thank you for taking the time to explain. I am not aware of the “hot debates” mentioned under point (3), so I may re-iterate what has been said before, for which I apologize if this is the case:
Regarding (3), I feel that having to go through a client on a client-by-client basis is very impractical for those of us marketing directly to the general patient population. We work for the patient, not for a health system. We do not know beforehand which patients will use our app and to which health system they belong. Once a patient wants to use the app and would like access through it to his/her own data, the process outlined under (3) may take way too long and the patient's interest will be gone. With your competitor Epic, we do not have this issue. Once the FHIR endpoints are exposed by the client, any app registered with Epic can use those endpoints, regardless of app/Epic client combination. It would definitely be very helpful if Cerner and its clients would offer the same approach.

Thanks again for the support from your company on this forum, it is great. Just hoping to move you in the direction outlined above.

Denis (SanteCure).



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Yegor Hanov (Cerner)

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Feb 4, 2019, 2:45:33 PM2/4/19
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Hi, Rob!  Yes, this is what we have seen with several of our clients so far.


On Friday, February 1, 2019 at 3:43:11 PM UTC-6, Rob Dingwell wrote:
Yegor, 

Thanks for that summary, it's very helpful.  

For the scenario where a developer creates an open source smart on fhir capability I imagine that can basically fall into scenario 1.  In that case the Cerner site is choosing to host the application and installs it locally as if they own the application, correct? 

Rob 

On Fri, Feb 1, 2019 at 4:03 PM Yegor Hanov (Cerner) <yegor...@gmail.com> wrote:
There are several different scenarios involved here with some variance based on whether the app ownership belongs to the client organization or developer.  There is also some additional considerations based on differences between provider apps and consumer apps.  There is also and an additional caveat for consumer apps related to scope of use of the API in relation to Meaningful User, Stage 3 definition of Common Clinical Data Set.  A lot of this is already described in some detail on our program website [1][2], but I will provide an abbreviated summary here as well.

1.  Application is "owned" by a Cerner client organization.  In this scenario, Cerner provides a set of tools and a support process to assist clients in development, testing and access provisioning of apps to their own domains.  App development and deployment is completely up to the client and no validation is needed, unless it is desired by the client.  We simply assist in moving things along as needed.  Sometimes clients contract with third party developers to help with actual coding with the expectation that ownership of the app at the end of development project stays with the client and there are no plans to market this app to other clients.  

2.  Third party developer building a provider application.  In the scenario developer has to enter into developer program agreement (DPA) with us [2].  DPA involves agreement on business terms and, generally, includes app validation by Cerner before it can be listed in the app gallery [3] and marketed to clients.  

3.  Third party developer building a consumer application within the scope of MU3 CCDS definition.  In this case, developer has to register the app in our system using self-service console [4] to make the app known to our API.  Developer do not have to enter into a program agreement with Cerner and do not have to go through validation, unless it is desired by the developer.  After app identity is created in our system developers can engage directly with our clients, who will in turn request provisioning of that app for access to their environment.  (Note - This has been a topic of hot debates in a variety of forums, including this group.  Our present position is that we have to have our client's approval before granting consumer app access to their environment.  We intend to keep improving the overall process and tooling as we mature our product and comply with anticipated regulatory requirements.)

4.  Third party developer building a consumer application outside of the scope of MU3 CCDS definition (eg Appointment Scheduling).  This is very similar to Scenario 2 above in that developer has to enter into program agreement with us and get the app validated, if applicable within DPA, before marketing it to our clients.


-Yegor (Cerner)


On Friday, January 25, 2019 at 1:38:35 PM UTC-6, yalini sen wrote:
Same here.


---- On Fri, 25 Jan 2019 09:22:24 -1000 'L.H.D. Mulder' via Cerner FHIR Developers <cerner-fhir-developers@googlegroups.com> wrote ----

Same here.

On Jan 25, 2019, at 2:20 PM, Seth Merritt <mash...@gmail.com> wrote:

Same here. In our case, we will own the IP and will be working with multiple clients on an AD hoc basis.

On Thursday, January 24, 2019 at 9:48:33 AM UTC-8, jol...@smcpartners.com wrote:
We are developing a SMART app for a client and they have reached out to us for information on what the vetting process is to move the app from the test environment to production. We will not be listing our app in the Cerner App Gallery so we are not planning on going through the Cerner CODE submission process. Are there any available resources related to this topic?

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Yegor Hanov (Cerner)

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Feb 4, 2019, 2:49:15 PM2/4/19
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Hi, Denis!

Yes, we understand that the current state is not ideal.  We are looking to improve the operational approach to provisioning access, while keeping our clients in the loop on the decision to publish API end points.  What I described in my post is current state, but certainly not the future state we seek to implement.

-Yegor (Cerner)

philip...@mycoralhealth.com

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Feb 4, 2019, 4:58:18 PM2/4/19
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Hi Yegor,

Thanks for the really useful info! Could you provide a bit more information on #3? My company has been working with the CMIO of a Cerner client that would like to approve our consumer facing app, but the CMIO and his Cerner lead weren't able to figure out how exactly to do that. Is there a standard process for a Cerner client to approve a consumer facing app, or a specific team at Cerner that handles those client requests?

Thanks!
Phil


On Friday, February 1, 2019 at 4:03:05 PM UTC-5, Yegor Hanov (Cerner) wrote:
There are several different scenarios involved here with some variance based on whether the app ownership belongs to the client organization or developer.  There is also some additional considerations based on differences between provider apps and consumer apps.  There is also and an additional caveat for consumer apps related to scope of use of the API in relation to Meaningful User, Stage 3 definition of Common Clinical Data Set.  A lot of this is already described in some detail on our program website [1][2], but I will provide an abbreviated summary here as well.

1.  Application is "owned" by a Cerner client organization.  In this scenario, Cerner provides a set of tools and a support process to assist clients in development, testing and access provisioning of apps to their own domains.  App development and deployment is completely up to the client and no validation is needed, unless it is desired by the client.  We simply assist in moving things along as needed.  Sometimes clients contract with third party developers to help with actual coding with the expectation that ownership of the app at the end of development project stays with the client and there are no plans to market this app to other clients.  

2.  Third party developer building a provider application.  In the scenario developer has to enter into developer program agreement (DPA) with us [2].  DPA involves agreement on business terms and, generally, includes app validation by Cerner before it can be listed in the app gallery [3] and marketed to clients.  

3.  Third party developer building a consumer application within the scope of MU3 CCDS definition.  In this case, developer has to register the app in our system using self-service console [4] to make the app known to our API.  Developer do not have to enter into a program agreement with Cerner and do not have to go through validation, unless it is desired by the developer.  After app identity is created in our system developers can engage directly with our clients, who will in turn request provisioning of that app for access to their environment.  (Note - This has been a topic of hot debates in a variety of forums, including this group.  Our present position is that we have to have our client's approval before granting consumer app access to their environment.  We intend to keep improving the overall process and tooling as we mature our product and comply with anticipated regulatory requirements.)

4.  Third party developer building a consumer application outside of the scope of MU3 CCDS definition (eg Appointment Scheduling).  This is very similar to Scenario 2 above in that developer has to enter into program agreement with us and get the app validated, if applicable within DPA, before marketing it to our clients.


-Yegor (Cerner)


On Friday, January 25, 2019 at 1:38:35 PM UTC-6, yalini sen wrote:
Same here.


---- On Fri, 25 Jan 2019 09:22:24 -1000 'L.H.D. Mulder' via Cerner FHIR Developers <cerner-fhir...@googlegroups.com> wrote ----

Same here.

On Jan 25, 2019, at 2:20 PM, Seth Merritt <mash...@gmail.com> wrote:

Same here. In our case, we will own the IP and will be working with multiple clients on an AD hoc basis.

On Thursday, January 24, 2019 at 9:48:33 AM UTC-8, jol...@smcpartners.com wrote:
We are developing a SMART app for a client and they have reached out to us for information on what the vetting process is to move the app from the test environment to production. We will not be listing our app in the Cerner App Gallery so we are not planning on going through the Cerner CODE submission process. Are there any available resources related to this topic?

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L.H.D. Mulder

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Feb 4, 2019, 5:17:10 PM2/4/19
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Hi Yegor,

Probably preaching to the choir, but Phil’s is another experience to suggest that the process for (3) would be so much easier for everybody if we could skip the hideous client-by-client individual app approval. You mentioned that the current process is certainly not the future state you seek to implement. Any idea about timeframe?

Thanks again for your help.

Denis.

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Adrian Gropper

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Feb 4, 2019, 7:58:22 PM2/4/19
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We're in the same position, hoping that Cerner's policies would at least track Epic's if not actually mirror how they deal with Apple. We're already well into 2019 and HIMSS is around the corner. Our app has already been approved by CMS for production access to Medicare records.

Please, many of us building patient-facing apps are not in a position to negotiate with each hospital individually for what's already accepted as a patient right.

Please help!

Adrian


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Yegor Hanov (Cerner)

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Feb 5, 2019, 10:20:37 PM2/5/19
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Hi, Phil!

Yes, we are seeing quite a bit of confusion in regards to new regulatory requirements among our clients. A few of them have well-developed policy recommendation like Banner Health [1], most of them are working to define their approach.  Please refer your client and their Cerner lead to our reference pages [2] for documented collateral or to our client discussion group [3] for questions (both of these last two links are accessible to clients only).


-Yegor (Cerner)

Yegor Hanov (Cerner)

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Feb 5, 2019, 10:25:58 PM2/5/19
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Hi, Denis!

Couple clarifications.  App registration is required only once to create app identity in our system.  We host a centrally deployed API, so once your app is registered it becomes available to all clients.  What is required client-by-client is their approval to make their end point available to your application.  Fundamentally, it is our clients' decision to develop policy on making their patients' data available to third parties and establishing governance for apps they want to connect.

-Yegor (Cerner)
Denis.

Same here.

Same here.

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Denis Mulder

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Feb 5, 2019, 10:50:34 PM2/5/19
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Hi Yegor,

You wrote: “Fundamentally, it is our clients' decision to develop policy on making their patients' data available to third parties”

Let’s not forget this is about making patients’ data available to the patients (the rightful owners of their own data), not third parties. It is the patient who decides to trust the app to get their own data for them.

I understand Cerner cannot force their clients to implement patient-centric policies. But in a time where patient-centricity and patient engagement are seen as highly beneficial for outcomes, help to make it easier for those patients to get to their data is required from all stakeholders. 

Market leaders like Cerner can play a very useful role by at least offering the option to their clients to make their endpoints automatically (i.e. without app-by-app authorization on a client-by-client basis) useable by apps registered by Cerner. I believe this is what Epic has implemented and it is the only process that can work for mass-patient facing apps.

Anyway, thanks for your team’s and company’s tireless and quality support on this forum! That is really useful as well.

Denis.
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Adrian Gropper

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Feb 5, 2019, 11:08:23 PM2/5/19
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The decision to block patient-directed access may be local, but at least we can expect a public list of patient-access endpoints or which facilities allow patient access.

Who other than Cerner is able to publish this list? As Denis says quite clearly, market leaders can play a positive and transparent role.

Adrian

Denis.

Same here.

Same here.

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Yegor Hanov (Cerner)

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Feb 6, 2019, 10:35:18 AM2/6/19
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Hi, Denis!  

Appreciate your commentary.  We continue to monitor regulatory environment and work with our clients and developer community on facilitating consumer access.  We are all learning in the process and I expect many changes to the ecosystem in coming months and years.

-Yegor (Cerner)
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Yegor Hanov (Cerner)

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Feb 6, 2019, 10:37:12 AM2/6/19
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Hi, Adrian!

Your commentary is spot-on as always.  Do you have an app registered in our system?  We have no issue making it available to our clients for provisioning of access.

-Yegor (Cerner)


On Tuesday, February 5, 2019 at 10:08:23 PM UTC-6, Adrian Gropper wrote:
The decision to block patient-directed access may be local, but at least we can expect a public list of patient-access endpoints or which facilities allow patient access.

Who other than Cerner is able to publish this list? As Denis says quite clearly, market leaders can play a positive and transparent role.

Adrian

Denis.

Same here.

Same here.

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Adrian Gropper

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Feb 6, 2019, 12:38:02 PM2/6/19
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Hi Yegor,
 
Thank you for the engagement and the encouragement, but note that my question was about publishing a list of accessible endpoints the way Epic does: https://open.epic.com/MyApps/Endpoints

That way, if we or anyone else registers their patient-facing app with Cerner, we have a way of telling patients whether their records are available. Without such a public list, we would have to interact with each hospital first and so would every other company that's doing what we're doing. I don't see why the EHR vendors would want to favor Apple and other giant business that can negotiate with hundreds of FHIR endpoints one by one over smaller entities like the ones on this list.

So, to be clear, why would we register our app with Cerner if there's no list of accessible endpoints? If Cerner has such a list, why wouldn't it be public like Epic's?

Adrian

On Wed, Feb 6, 2019 at 10:37 AM Yegor Hanov (Cerner) <yegor...@gmail.com> wrote:
Hi, Adrian!

Your commentary is spot-on as always.  Do you have an app registered in our system?  We have no issue making it available to our clients for provisioning of access.

-Yegor (Cerner)

On Tuesday, February 5, 2019 at 10:08:23 PM UTC-6, Adrian Gropper wrote:
The decision to block patient-directed access may be local, but at least we can expect a public list of patient-access endpoints or which facilities allow patient access.

Who other than Cerner is able to publish this list? As Denis says quite clearly, market leaders can play a positive and transparent role.

Adrian

Denis.

Same here.

Same here.

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PROTECT YOUR FUTURE - RESTORE Health Privacy!
HELP us fight for the right to control personal health data.

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L.H.D. Mulder

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Feb 6, 2019, 12:45:31 PM2/6/19
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Adrian,

I found something here:


Is this a list of endpoints that would accept third party apps without further authorization on a client-by-client, app-by-app basis?? Not sure.

Vishal Goel

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Feb 14, 2019, 5:12:24 PM2/14/19