Should "EHI export" be limited to patients/representatives?

[jmandel]

In service to innovative and patient-centric approaches, a health IT developer could develop a method that allows the patient using a technology application (e.g., portal or “app”) to execute the request without needing a provider to do so on their behalf. We seek comment on whether this portion of the criterion should be made more prescriptive to only allow the patient and his or her authorized representative to be the requestor of their EHI, similar to how we have previously scoped such criteria as “view, download, and transmit to 3rd party” (§ 170.315(e)(1)).

[jmandel]

• Don't only allow the patient/representative to request an export
• Do require that the patient/representative has a way to request an export without assistance (e.g., a feature in the portal)