Understanding the Digital Database Idea.

Last week, we presented a few ideas about the controversy surrounding a proposed digital database for insurance consumer information. The obvious faults that experts pointed out about the plan centered on the possibility that data-miners or corporate interests could easily access consumer information. Now we are going to take a look at the legislation that inspired the concept.

Back in July of this year, the Obama administration began announcing the features of the healthcare reform plan. Part of this plan was for every citizen to have an electronic medical record by 2014. This was motivated by the desire to make the process of healthcare easier, faster, and cheaper. A nationally-accessible database would prevent much of the pointless paperwork that takes up time and money in today’s system. It is around this point that things begin to get interesting.

The primary arguments today against this system are the potential for corporate interests to access private information. In actuality, privacy was one of the founding principles of the electronic database idea. In July, when the Health Information Technology for Economic and Clinical Health (HITECH) Act cam out, it required HHS to re-write HIPAA to strengthen privacy, security, and enforcement. The language used in HITECH is very similar to the language used to promote the electronic database:

• Expanding individuals' rights to access their information and to restrict certain kinds of disclosures of protected health information to health plans
• Requiring business associates of HIPAA-covered entities to follow most of the same rules as the covered entities
• Setting new limitations on the use and disclosure of protected health information for marketing and fund raising; and
• Prohibiting the sale of protected health information without patient authorization (From FierceHealthcare).

So now we have a system devised to protect privacy and security in response to a rule-change based in those same values. As long as the digital database functions as intended, it seems like a win-win scenario. Obviously, there is always the chance that an immoral healthcare worker could sell personal information to data-miners, but isn’t that just as possible today?

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. You can contact Pam at Pamela.Argeris@merrillcorp.com.

OPM Shows Little Concern for Privacy

OPM is making waves with their push toward a national database of health insurance customers. OPM’s argument is that such a database would provide "best value for both enrollees and taxpayers.” They also cite the potential efficiency such a system would offer. OPM also claims that the system would be “de-identified,” supposedly protecting individual customers from the healthcare data-mining that plagues the industry.

However, many are not satisfied with OPM’s vague claims. Harley Geiger, policy counsel for the Center for Democracy and Technology, tells Computerworld “[At this point,] there are far too many unknowns about the program for it to be acceptable.” Many questions are raised by the program: Are HIPAA and PHI going to be swirling around cyberspace? Exactly what measures are protecting consumers from data mining?

Most seem to agree that OPM’s notice is entirely too vague to garner any form of support for the new system. OPM’s plans to allow third-parties to access the material, including judicial and research groups, sends up further red-flags.

Until OPM is willing to release more specific information about the program, it is unlikely to be welcomed into the industry. Our concern should be for the protection and safety of consumers and average citizens, not for cost-cutting. If there is even a small potential for someone to profit from selling access of this database to commercial data-miners, then it is unacceptable as a system.

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. You can contact Pam at Pamela.Argeris@merrillcorp.com.

HHS, IT Infrastructure and Health Insurance Exchanges

Last week, HHS announced a new initiative that will provide competitive funding opportunities for states to design and initiate IT infrastructures that will be necessary for the operation of Health Insurance Exchanges. Because these Exchanges will need to be designed to present a large number of individuals and small businesses with affordable health care options by 2014, new and advanced IT systems will be necessary well before then.

Exchanges, as we know, will provide a form of one-stop shopping for individuals and small businesses, with interested parties being able to examine, select, and enroll in one of many available plans offered at competitive, affordable prices. However, while many are focused and debating the policy aspect of this initiative, what gets lost is the IT infrastructure that will need to be constructed in order to make this (or any) end goal possible. The infrastructure will need to be well thought out and be based on several best practice examples (especially in the areas of simplicity and approachablity) in order to allow the Exchanges to operate like other similar consumer industry sites.

To assist with this aspect, states can apply, through HHS, for “Early Innovator Grants.” The grants will provide states with the capital to get a head start on building these necessary infrastructure models. States are to be chosen based on their current efforts toward consumer-friendly IT infrastructure, as well as their leadership in cost-effective solutions.

The first round of winners will be announced before February 15^th, 2011, and will be followed by additional award announcements which all states – including those that already received funding – will be eligible to receive.

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. You can contact Pam at Pamela.Argeris@merrillcorp.com.