If you use Nostr, then you’ve seen this separation of concern already in action.
The base protocol (NIP-01) specifies how “valid” events are signed by user private keys, and how a client may publish these events to any number of relays.
NIP-05 and NIP-65 specifies how users may indicate their preferred read and write relays.
NIP-44 specifies how any event may be encrypted (and decrypted) by signing apps (and extensions).
Accordingly, most every Nostr client already allows end users to publish these immutable events to relays of their choosing, for storage and retrieval. An EHR app could simply allow encryption and decryption (of certain event content) by user private keys.
Of course, details matter… but an identity and data lifecycle such as this could keep users in control at all times, and reduce exposure for client apps from certain data privacy regulations.
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