Ann Geyer
President and CEO
Healthcare Data Information Corporation
Phone:
510-631-1244 Fax: 510-631-6640 Email: 71023.2375@compuserve.com
The Healthcare Data Information Corporation (HDIC) is a California non-profit organization which acts as an industry initiative to facilitate the existence of a statewide health information network designed to: collect and appropriately make available information to foster improved quality of care; reduce the costs and complexity of administrative and clinical transactions; and use electronic communications to improve healthcare processes and decision-making.
HDIC membership is open to any organization which has an interest in improving the use of information systems and technology within the healthcare industry. Current members are primarily healthcare providers, health plans, and purchasers with representation from government, pharmaceuticals, information technology, and public interest organizations.
My remarks will not necessarily reflect the perspectives of any specific member, many of whom you have heard from directly during these hearings; rather they describe the direction which HDIC as an organization will take and thus are an amalgamation of different member positions.
HDIC supports the strictest possible privacy provisions that can be implemented with existing technology. Our Public Policy Committee feels strongly that pressure to accelerate the implementation of electronic transactions without provisions for privacy, confidentiality, and security serious compromise patient rights.
HDIC would like to see the Committee take a leadership position in its recommendations to Congress on these issues. Implementation of information systems and networks will act to expose the weaknesses in the present policies and procedures as well as present new opportunities for breaching confidentiality. We believe that it must become a business imperative to promote heightened awareness of privacy and confidentiality in order to maintain the individual's trust in the industry. This is particularly so in managed care markets where the managed care system has greatly expanded the number of parties who interact with patient information as a routine job function.
I have provided a copy of HDIC's White Paper on Public Policies for your review.
These policies are the result of two years of deliberation by a cross section of the California industry and with the addition of several consumer rights organizations. The policies are currently under review to determine what changes may be necessary to address HDIC's recent decision to adopt the use of the Internet as our information infrastructure.
HDIC supports the creation of a unique individual identification system for healthcare records. Unique individual identification is a cornerstone of many of HDIC's initiatives and we believe it is a pre-requisite for administrative simplification of many existing processes. We suggest there are really two issues to be considered. The creation of individual identifiers and the process of using identifiers as data tracking or linking mechanisms. HDIC proposes that all individual identifying information should be encrypted and revealed only to authenticated users. This proposal includes any unique patient identifier number(s). HDIC believes the technology exists for this purpose although the costs of implementation are still under consideration.
Many HDIC health system members are currently engaged in the search for a workable MPI. We have observed these efforts and the difficulties associated with linking data post-hoc within a single organization with a common management structure. These efforts have convinced me that it is not the time to take on the extra-enterprise version of linking data across organizations. Instead we have turned our efforts to address unique identification at the point and time of enrollment. We are currently investigating the technologies of public key infrastructure, smart cards, universal card readers, and other such options that are being developed to support electronic commerce over the Internet. It is my belief that several new technologies will become cost-effective options for healthcare in the next 2-3 years.
Establishing data standards for the 10 transactions named in the legislation is only the first step toward implementing administrative simplification. As HDIC's EDI workgroup has determined, it is very difficult to get consistent EDI implementation even when the same implementation guide is being used. To facilitate more efficient efforts, we recommend that the Committee establish one standard per transaction. Most HDIC members admit to the benefit of a single common standard and who prefer one rather than several. Implementation must be accomplished broadly throughout the industry including any EDI intermediaries to effect administrative simplification.
HDIC would recommend that the Committee direct the standards bodies to create implementation data test sets as part of each implementation guide. Further we would like to see the appointment of independent agents to act as mediators or arbitrators of disputes regarding inconsistent standards implementation. Trading partners contracts would determine the use of such arbitration and who would pay. There should be several such agents to encourage competitiveness in services and pricing and provide protection against bureaucracy.
Administrative simplification is challenged by the structure of managed care industry and the need for basic information infrastructure. For example, we believe enrollment, eligibility, and determination of benefit should be evaluated as a single information flow from the simplification objective. Much of the dissatisfaction with the quality of eligibility information can be traced to the quality of enrollment data. We encourage the Committee to establish objectives of administrative simplification which assess the complete information flow.
Finally, I suggest that the goal of administrative simplification should be to point the industry in the right direction and force the initial steps. Thereafter critical mass and competitive factors will carry the efforts forward. I am encouraged by the number of different forums already in existence to promote such efforts and support the continued success.
I would like to thank the Committee for coming to California for these hearings. I have personally benefited from the many points and suggestions raised during these two days. It is clear that there is strong interest as well as concern on how to best determine the HIPAA provisions. I would like to invite the Committee back after recommendations have been issued to continue the opportunity for interaction.