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The issues you bring up are well known and I couldn’t agree more. Interoperability needs to be better. See my comment further up.
I am across the pond from you and as far as my knowledge goes laws are even more strict here.
I am not a medical professional, but I did accounting for a lot of them and from what I have seen them pay for the relevant authentication hardware and software it seems to be nightmarish to navigate.
While I am very pro data security and people being the owners of their own data, this goes the other way for me too. I own the data about my health, so I should be able to decide that I am fine with having it on my phone.
The medication rollback I mentioned would have been completely unnecessary if that option existed. It was Ibuprofen, which my SO shouldn’t due to an already stressed kidney. Now that I know that I can look out for it too, provided I am allowed to go with.
One of the issues you are touching on is what we refer to as Medication Reconciliation. At least in the US, the standard of care is to verify the current medications a patient is taking at every visit - whether it be an office visit, ED visit, or a hospitalization. Our local pharmacies also play a part in checking for medication interaction. This does not extend to over the counter medications however.
The US is the same in that the patient owns their own information. However, private entities are charged with the responsibility with holding and securing that data. Unfortunately, there is no central repository for it here.
More advanced systems in the US do allow for data access via phone. But it is not uniformly available or applied.