We submitted comments in response to the HHS Office for Civil Rights (OCR) proposed rule that proposes modifications to the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule to support coordinated care. The proposed rule seeks to expand a patient’s right to access and inspect health information and support timely disclosure of protected health information (PHI); clarify the ability to disclose health information to third parties for care coordination; encourage disclosures of PHI to help patients in behavioral health crisis and emergency circumstances, among others.
We support the intent of the rule to promote coordinated care and ease access to PHI and provide a number of recommendations in the letter. Our comments focus on anticipated workflow redesign issues for providers and compliance barriers for proposed disclosure timelines; pediatric-specific considerations, including the confidentiality of sensitive PHI, implications for children receiving care across state lines and family or legal dynamics related to disclosure; and additional clarification on the ability to share PHI with community based organizations, including schools, for care coordination purposes. Thank you to those children’s hospitals that provided feedback to inform our comments.
