"The proposal would require covered entities to act on access requests 'as soon as practicable' and would shorten the deadline for action from 30 to 15 days.... Health plan participants could, however, instruct their health plan to request EHRs from covered health care providers, which would then be required to disclose the requested EHRs directly to the plan.... The proposal would clarify that health plans' care coordination and case management activities -- whether based on broad populations or particular individuals -- are considered health care operations."