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Next month, DPH will be holding public hearings and accepting public comment online on their proposed plan for health information exchange for Connecticut. The plan includes a controversial privacy policy recommendation to default all patients into the system, unless they affirmative opt-out. Under the opt-out plan, providers would be responsible for removing any sensitive information (HIV, behavioral health, reproductive health issues, etc.) from shared records. Providers accessing information from the system will not know if the patient records are complete or whether any medications or treatments have been removed. Advocates have raised concerns about this policy. Health information technology holds great promise to improve the quality of care, patient safety and reduce costs; it is critical that privacy be a high priority to ensure public trust and the integrity of the system, especially in the case of any breach of information. Consumers must fully understand the system and their rights, both benefits and risks. Last year eHealthCT, a nonprofit dedicated to expanding health information exchange in CT , convened a privacy and security committee of CT stakeholders including providers, consumer advocates, state agency staff, legal and technology experts for a Medicaid pilot health information exchange. After an extensive public process, that group recommended an opt-in policy including patient information only after they have affirmatively agreed to participate. Massachusetts conducted an well designed, extensive, effective public education campaign that included significant consumer input for their opt-in policy and over 90% of patients choose to participate. Vermont’s exchange began with an opt-out policy, similar to DPH’s recommendation, but after operating the exchange has changed policy to opt-in. DPH intends to send their recommendations to the federal Office of National Coordinator for Health Information Technology (ONC) to access millions in federal grants to create CT’s health information exchange. DPH’s health information technology committee includes no consumer representatives.
The hearings will be August 19th from 5 to 7pm in Room 2E of the Legislative Office Building and August 26th from 9 to 11am at the Holliday Inn, 201 Washington Ave, North Haven. Online comment will be accepted August 16 thru 27 at www.ct.gov/dph. DPH reportedly expects to submit the recommendations to ONC Sept 7th.
Ellen Andrews