CCHF Submits Comments on HIPAA to Federal Government

February 12, 2019

Secretary Alex M. Azar II
U.S. Department of Health and Human Services
Office of Civil Rights
Attention: RFI, RIN 0945-AA00
Hubert H. Humphrey Building
Room 509F
200 Independence Avenue SW
Washington, D.C. 20201

RE: “Request for Information on Modifying HIPAA Rules to Improve Coordinated Care” (RIN 945—AA00)

Dear Secretary Azar,

Thank you for requesting information from the public on modifying HIPAA prior to issuing a Notice of Proposed Rulemaking (NPRM). We support the right of patients to keep their private medical information confidential, thus we have long opposed HIPAA due to its intrusion on the patient-doctor relationship and its infringement of privacy rights. Our opposition continues today and has only grown with the EHR mandate, MIPS/APMs, HIEs, eHealth Exchange, and interoperability mandates.

As we often say, “He who holds the data makes the rules.” Thus, protecting patient privacy protects not only the confidentiality of private information, but the individual freedom and choices of citizens. Our organization, Citizens’ Council for Health Freedom (CCHF), has been engaged in a two-decade campaign to inform Americans that despite what they’ve long been told by the news media, government agencies, health plans, legislators, Congress, hospitals, and doctor’s offices: 

·       HIPAA is not a privacy rule. 

·       HIPAA gives outsiders legal license to share, use, analyze, link, and sell patient data.

·       HIPAA empowers corporations, government, health plans and others to profit from access to and use of confidential patient information without the patient’s consent. 

Therefore, we appreciate this opportunity to share our concerns about HIPAA for your consideration before publication of the NPRM. The following are general comments on privacy, HIPAA, and the value-based health care purpose of the OCR RFI, followed by answers to several specific questions.

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