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 out of the Waterloo Wellington LHIN 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.