CCHC's Comments on Centralized Medicare Database

We are concerned not only about the eleven Routine Uses proposed for the data, for which you asked for comment, but also about the new Centralization of patient data on our nation's senior citizens, and its potential for privacy abuses and health care rationing.

Federal Medical Privacy Regulations (Final Rule)

Federal Medical Privacy Regulations (proposed)

Medicare's OASIS home health data collection system

There is no obligation on the part of private patients to contribute to the Medicare OASIS database. Yet, OASIS regulations seek to collect data on all patients in the home health system. There is no statutory basis for coercion of non-subsidized patients into the federal data collection process. In fact, the Fourth Amendment prohibits such collection without patient consent.

OASIS home health data system (final rule)

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.

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...

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.