before the National Committee on Vital and Health Statistics
Subcommittee
on Privacy and Confidentiality
February 3, 1997
My name is David L. Larsen, and I am Director of Health Care Services at Intermountain Health Care. Based in Salt Lake City, Utah, IHC is an integrated, not-for-profit health care system consisting of 23 hospitals, 33 clinics, 16 home health agencies, 300 employed physicians, and IHC Health Plans -- a mixed model HMO with an enrollment of 350,000 members including Medicare and Medicaid beneficiaries.
Today I am testifying on behalf of the American Association of Health Plans which represents 1,000 HMOs, PPOs, and similar network plans providing care to over 120 million Americans. I appreciate the opportunity to participate in today's hearing.
AAHP supports this Committee's efforts to protect against the unauthorized and inappropriate use of patient information while at the same time facilitate the coordination and delivery of high quality, network-based health care. It is important that your recommendations recognize the special needs of integrated delivery systems.
Network-based care relies on the coordination of patient care by providers and effective quality enhancing activities which include: quality assurance programs; data analysis for disease management activities; outcomes research on safety, efficacy, cost-effectiveness, and quality of life; accreditation and certification activities; and provider screening and profiling.
A significant number of these activities -- which I will elaborate on later -- require the use of individually identifiable information. In addition, even in cases where nonidentifiable information can be used, health plans must be able to link the nonidentifiable information back to a specific individual in the event that a more effective treatment protocol or a previously unknown health risk is identified.
For example, a portion of IHC's efforts to improve clinical and service quality centers on the development of Care Process Models or practice guidelines. In developing Care Process Models for chronic conditions such as asthma and diabetes, individual patient information is used to identify members at risk of complications or who are not receiving care consistent with the best care guidelines. IHC reaches out and communicates directly with those patients and their primary care physicians concerning the patients' profile of care and use of medical services.
As an integrated delivery system, IHC is responsible for the health outcomes of the patients who seek care from our system. In order to manage and improve the health outcomes of the population we insure, we must be able to share information among IHC corporate entities -- our physicians, hospitals, and health plans. IHC has developed electronic medical records and common databases to facilitate this communication. Preventing the creation of these common databases, limiting the type of data which can be shared within the IHC integrated delivery system, or requiring a patient's authorization for each and every transaction and transfer of data, would severely limit IHC's ability to measure and improve the health outcomes of our enrollees.
IHC has invested in many efforts to ensure security and confidentiality of health information. Included in these efforts are:
IHC has spent significant time and effort in addressing the issues surrounding the appropriate use of medical records information. Use of this information is critical to our delivery system's operations and efforts to improve our members' health outcomes.
I look forward to providing you with more specific information on how IHC uses and protects identifiable information.