eHealth Privacy and Security

The first six months of 2010 have gone by ever so quickly. I started my blog in May 2009 - Older Americans Month - and intended to have a "year in review" entry in May of this year, but in the amount of time I've allotted for computer related activities, I've just been too busy attending meetings (mostly teleconferences), reading transcripts and minutes of meetings, reading whitepapers, reviewing nutrition literature and entering data for the McFarland Senior Outreach Program via the Social Assistance Management System (SAMS) application to find the time to write the "year in review" entry.

On March 27, 2010 I filed a HIPAA privacy and security complaint with the Office for Civil Rights (OCR) based upon my belief that the Dane County Area Agency on Aging (AAA), the Bureau of Aging and Disability Resources (BADR), the Administration on Aging (AoA) and Harmony Inc. in its use and configuration of Harmony Inc.'s SAMS system violated (and continue to violate) HIPAA privacy and security rules. A complete copy of my complaint can be found on my website at: http://www.metasteward.net/.

At the state level, I have been closely following the deliberations of the Wisconsin Relay of Electronic Data (WIRED) for Health Board that was created in December 2009. At the national level I am following the deliberations of the new Privacy and Security Tiger Team that was organized by the Office of the National Coordinator for Health IT (ONC) under the auspices of the HIT Policy Committee. The new tiger team is composed of members from the HIT Policy Committee, the HIT Standards Committee and the National Committee for Vital and Health Statistics (NCVHS).

Many who have membership on the federal advisory committees are also members of Wisconsin's WIRED Board and/or its subcommittees. As a member of the HITSP Consumers Preferences Tiger Team (that directly reported to the ONC)I have come to know a several individuals who now participate on Wisconsin's e-Health Board and/or subcommittees.

I am very pleased that the NCVHS has formally been acknowledged for its ongoing efforts and is participating in the deliberations of the Tiger Team. Walter Suarez co-chaired the Consumer Preferences Tiger Team and is a member of the NCVHS Security and Privacy Sub-Committee that has addressed many of the same issues that the new work group will be addressing.

The National Committee on Vital and Health Statistics brings a different perspective to considerations in that membership is based on expertise in subject matter rather than representing an organization. NCVHS brings to the discussion the concept of "Health Data Stewardship".

Toward the end of the June 22 meeting of the Privacy and Security Tiger Team, I made the comment that the Administration on Aging should be involved in discussions of security and privacy. It has been nearly three years since I became aware of the absence of a sense of "data stewardship" by the administrators in the aging programs.

(to be continued)