Monday, June 1, 2009

Review of My Concerns Relating to the Social Assistance Management System (SAMS)

Before I review my concerns relating to the Social Assistance Management System (SAMS) I'd like to direct your attention to the McFarland Area Senior News for the month of June found at: http://tinyurl.com/nn4d8d

The June issue has many items of interest that will help us, as seniors, to prepare for situations that we might encounter in the future. The article, INGRID'S INSIGHTS, is of particular importance as it deals with preparing for situations when we can no long pay our bills because of a medical or mental condition. Most of us have our Wills and Power of Attorney for Health Care documents completed and updated. But one thing, that many of us overlook, is preparing for a situation where we can no longer pay our bills because of a medical or mental condition.

In the Insights article, Ingrid Thompson, who is Director of the McFarland Senior Outreach Program, describes a document called "Wisconsin Basic Power of Attorney for Finances and Property". This document is superior to other financial management options and should be considered in preparing for the future. As Ingrid says, "Life can change in an instant, and it's best to be ready for any possible situation. Having 'Plan B' in place and never using it is far better than having nothing at all."

I am reviewing my concerns at this point in time, as it appears that the Department of Health Services (DHS) and Dane County Area Agency on Aging will successfully prohibit any public discussion of issues relating to the Social Assistance Management System (SAMS). It's an unusual set of circumstances that finds me, as an Older American, simultaneously looking at that system from the perspectives of:
  • Congregate Meals participant

  • Volunteer Data Entry Operator for McFarland's Senior Outreach Program including the Congregate Meal Program and the Home Delivered Meal Program

  • Volunteer member of the Health Information Standards Panel (HITSP) and its subcommittees including: Medication Terminology Harmonization, Information Interchange, and Security and Privacy, and

  • President and CEO of Metasteward LLC, a member of the American National Standards Institute (ANSI)

January 29, 2008 -

In my capacity as a volunteer data entry operator, I received an email forwarded by (Ingrid Thompson) the Director of the Senior Outreach Program from the Nutrition Specialist mandating that effective March 1, 2008, the Social Assistance Management System (SAMS) be used to track client information from the new "Nutrition Screening Form" that all programs had been required to implement by January 1, 2008.

Data entry instructions were located at: http://dhfsbadr.org/docs/sams/nutritioncheck/. That Website appeared to me to be an official site of Department of Health and Family Services (DHFS) Bureau of Aging and Developmental Resources (BADR), but as I was to find out, was actually a site privately owned by the SAMS' system administrator. The intended use of the tracking system was to show nutrition "outcomes" at both the local and state levels.

January 31, 2008 -
I sent an email to the Nutrition Specialist and SAMS system administrator telling of the visceral reaction I experienced that the SAMS' tracking process violated my rights to privacy. I attached a DHFS form that followed proper protocol as to specifying the law underlying the form and the consequences that would follow if the form was not completed

February 18, 2008 -
I inadvertently gained access and control of the Web programs and host computers at Harmony Inc.’s data centers. Security holes had already been identified by the current systems administrator and–as I recently found–by a systems installer, as recorded in his service order notes, dated 3/24/2004. In a list of the top ten security flaws in Web programs, the security hole I inadvertently found is described as, “Broken access control – in which restrictions on authorized users are not enforced.” Cyber thieves are well aware of semantic technologies and crawl the Web looking for such vulnerabilities.

March through December 2008 -
During 2008, I assembled the following letters and documents which I anticipate will form the basis for a case study (that I hope to complete by January 2010) concerning repercussions of the failure of the federal Administration on Aging (AoA) to take the lead in defining a minimum data set (MDS) and in setting security requirements for Older American Act Programs. AoA’s failure has resulted in Wisconsin’s State Unit on Aging (SUA) and Dane County’s Area Agency on Aging (AAA) in configuring a software-as-a-service (SaaS) system in such a way as to systematically deprive the elderly and disabled of their constitutional rights to privacy. Both Wisconsin’s SUA and Dane County’s AAA are currently implementing an electronic record tracking system that ignores and violates both state and federal privacy laws.

Letter to: Rea Holmes, Executive Assistant, DHFS and Tonya Harmon, CEO, Harmony Inc.
Attachments:
1-ScreenShotsRemoteAccess.pdf
2-HolmesHarmonLetters.pdf
3-FairfaxCountyAudit2006.pdf
4-OpenRecordsRequest.pdf
Open Records:
5-Nutrition Committee Minutes.pdf
6-BADR’s Contract for the Social Assistance Management System (SAMS).pdf
7-Minutes of DHFS Data Stewardship Council.pdf
Other Records:
8-Report to HIPAA Metadata Registry Coalition.pdf
9- Comments to Area Agency on Aging Board - Legislative Committee – 11/12/2008
10-Comments to Health and Human Needs Committee – 11/18/2008
Attachment: HHN111808
Minutes of 11/18/2008 Meeting
11-Comments to HHN, HSB, LTS and AAA Boards – 12/02/2008
Attachment: Combined Boards 120208
12-Comments to Area Agency on Aging Board - Legislative Committee – 12/17/2008

(to be continued)