CognisantMD generally acts as a Electronic Service Provider (ESP) under PHIPA, particularly in the capacity of providing hosted software to facilitate patient engagement technology. We do not handle PHI, which is protected by client-side encryption.
In some cases, we act as a Health Information Network Provider (HINP), specifically in the context of Ocean eReferrals, which allow Health Information Custodians (HICs) to share Personal Health Information (PHI) with other HICs.
A special case exists for the System Coordinated Access Program in Ontario. In this eReferral project, Ocean's role is as an ESP with HINP responsibilities residing with the CFFM Care Innovations, a not-for-profit organization.