Good morning, I am Kathleen Fyffe, Director of Operational Systems at the Health Insurance Association of America, also known as "HIAA". HIAA is a trade association representing 300 commercial health insurance companies, managed care plans and Blue Cross Plans. Our member companies provide products such as health insurance, dental insurance, disability income insurance, long term care insurance and Medicare Supplemental insurance.
We are grateful for the opportunity to provide testimony about health confidentiality issues to this committee.
HIAA whole-heartedly agrees that protection of personal health information is vitally important to the people of the United States and is an important aspect of health care reform.
Our member companies have much respect for the confidentiality of health information which is under their control for payment purposes. Typical policies and procedures involve the signing of confidentiality statements by Health Insurance Company employees which expressly forbid them to disclose confidential data about patients and most importantly the statement includes consequences, so that if such disclosure occurs the employees are terminated from employment. We respectfully request that, as this committee formulates its recommendations about privacy legislation for the Secretary, the following points be carefully considered:
1. The recommendations be consistent with the ultimate goals of Administrative Simplification in health care which are:
2. Please be mindful that well - intentioned, but onerous, administrative burdens placed on providers or payers can increase costs to patients.
3. It is important that private recommendations be flexible, that is flexible enough to suit the fluid organizational changes of the health care marketplace.
4. The recommendations should exercise caution with respect to the procedures for correcting or amending protected health information. There have been legislative proposals which imply that patients are qualified to make changes to medical records. We believe that any changes to medical records should be managed through a patient's physician, or other provider, who is appropriately qualified to make determinations regarding such changes.
5. It is very important to our member companies that Federal Law supersede state laws in the area of privacy of health information. Our members have multi-state operations and it is a difficult and expressive administrative burden to comply with varying state laws.
6. Lastly, we firmly believe that Privacy protections should allow for coordinated patient care services in network based health care plans. Such health care plans offer coordinated health services to patients and therefore it makes sense to enable patients to provide a single authorization for:
This single authorization enables coordinated patient care and facilitate efficient and appropriate sharing of information among health care providers and plans in order to provide patients with high quality health care services.
Again, the HIAA appreciates greatly the opportunity to testify before this Subcommittee this morning. I would be happy to answer your questions.