Monday, December 15, 2008

ONCHIT Issues Nationwide Privacy and Security Framework for Electronic Exchange of Health Information

Today the Office of the National Coordinator for Health Information Technology (ONCHIT) issued The Nationwide Privacy and Security Framework for Electronic Exchange of Individually Identifiable Health Information. The summary states that the framework creates a set of consistent principles to:
". . .address the privacy and security challenges related to electronic health information exchange through a network for all persons, regardless of the legal framework that may apply to a particular organization. The goal of this effort is to establish a policy framework for electronic health information exchange that can help guide the Nation's adoption of health information technologies and help improve the availability of health information and health care quality. The principles have been designed to establish the roles of individuals and the responsibilities of those who hold and exchange electronic individually identifiable health information through a network."
Along with the Nationwide Privacy and Security Framework the Department of Health and Human Services (HHS) has issued The Health IT Privacy and Security Toolkit. The Toolkit includes new HIPAA Privacy Rule guidance documents developed by the ONCHIT and the Office for Civil Rights (OCR) to help facilitate the electronic exchange of health information.

Of particular interest to many interested in PHRs will be the OCR's guidance on Personal Health Records and the HIPAA Privacy Rule and the draft Draft Model Personal Health Record (PHR) Privacy Notice & Facts-At-A-Glance (the "Leavitt Label").

The Toolkit provides information and guidance focused around these key areas:
  • Individual Access Principle - Individuals should be provided with a simple and timely means to access and obtain their individually identifiable health information in a readable form and format.
  • Correction Principle - Individuals should be provided with a timely means to dispute the accuracy or integrity of their individually identifiable health information, and to have erroneous information corrected or to have a dispute documented if their requests are denied.
  • Openness and Transparency Principle - There should be openness and transparency about policies, procedures, and technologies that directly affect individuals and/or their individually identifiable health information.
  • Individual Choice Principle - Individuals should be provided a reasonable opportunity and capability to make informed decisions about the collection, use, and disclosure of their individually identifiable health information.
  • Collection, Use, and Disclosure Limitation Principle - Individually identifiable health information should be collected, used, and/or disclosed only to the extent necessary to accomplish a specified purpose(s) and never to discriminate inappropriately.
  • Data Quality and Integrity Principle - Persons and entities should take reasonable steps to ensure that individually identifiable health information is complete, accurate, and up-to-date to the extent necessary for the person's or entity's intended purposes and has not been altered or destroyed in an unauthorized manner.
  • Safeguards Principle - Individually identifiable health information should be protected with reasonable administrative, technical, and physical safeguards to ensure its confidentiality, integrity, and availability and to prevent unauthorized or inappropriate access, use, or disclosure.
  • Accountability Principle - These principles should be implemented, and adherence assured, through appropriate monitoring and other means and methods should be in place to report and mitigate non-adherence and breaches.
I have only made an initial pass though the information and guidance documents. There is a lot to read and digest over the holidays. Please post in the comments your thoughts on the new federal principles and guidelines.

1 comment:

Anonymous said...

Thanks for the quick review Bob. I plan to take a very close look at this as well, particularly as it pertains to personal control of health records and the nascent PHR sector. Will be interesting to see how much of this is a parroting of previous work from Markle and also how much is in alignment with what CCHIT is currently proposing for PHR certification. Will put up an initial post over at Chilmark Research later today - certainly reference your post as well.