Patient Privacy

Comments on Security and Electronic Signature Standards

We cannot support the proposed security standard because it does not establish a security standard as mandated, nor is it enforceable. Rather the Secretary of DHHS has proposed to allow each organization to create a system based on its own prioritization of risk, cost, confidentiality and security.

CCHC Public Comment: National Standard Employer Identifier

While the desire for efficiency is understandable, the implementation of the National Standard Employer Identifier will permit unwarranted federal monitoring of patient care, and linking of medical records through employers. This invasion of personal and medical privacy will diminish the excellence of the American health care system by creating barriers of distrust between doctors and patients and employers and employees. 

Unique Employer Identification number for Medical Records

CCHC cannot support mandatory submission, use, and reporting of the EIN which can be linked with other individually-identifiable information to build citizen profiles which will include confidential and sensitive medical record information. The implementation of yet another number for tracking citizens through their use of health care services&emdash;a time of great personal vulnerability&emdash;is not acceptable in a free society regardless of the apparent convenience and efficiency that would result. Citizens in a free society must be free to protect their privacy and their persons from unwarranted government oversight and monitoring.

United HealthCare (UHC) and Medical Confidentiality

Portions of Testimony by David S. Miller, Director, Health System Services, UHC, on the Unique Patient Identification Number at the National Committee on Vital Health Statistics hearing in Chicago, July 21, 1998

Testimony on Unique Patient Identifiers

We cannot support the implementation of standardized government-issued unique patient identifiers for individuals. Despite the fact that Congress passed the HIPAA law, this enumeration and surveillance system will clearly be detrimental to the liberty, privacy, and security of every United States citizen. Not only will this surveillance system allow government officials to use doctors to track citizens at their most vulnerable times when they have no where else to go...

Portion of Testimony from Chris Chute of the Mayo Foundation

Database Integration

Integration of Databases Nationwide

Immunization Registries

Total of 122 medical clinics currently participating (about 16% of the state's total clinics that provide childhood immunization) according to the Minnesota Health Department on June 1, 1998.

Testimony on Immunization Registries

No one who is under mandatory government surveillance is free. Privacy is quintessential to freedom. If we wish to preserve the freedom that has made our nation great and has beckoned people from every nation who have been persecuted and pursued by their own governments, then we must not strive to emulate the countries which they, and many of our forefathers, left.

CCHF Opposes National Provider Indentification Number (ID)

We seek more informaiton on the NPI number and enforcement, and do not support mandatory enumeration of all providers, the proposed broad data collection that goes well beyond identification, the violation of statute regarding security of information exchanged, the addition of two transactions, the waiver proposal, or the central registry option.