On February 12, 2019, AHIP submitted comments in response to the Department of Health and Human Services’ (HHS) Request for Information (RFI) on opportunities for modifying the Health Insurance Portability and Accountability Act (HIPAA) rules to improve coordinated care.
Our comments make clear that the HIPAA Privacy Rule has served as a solid framework and overall is working well for protecting individuals’ health information. While the HIPAA Privacy Rule was written when paper-based records were predominantly used, the current policy considerations should take into account the ability to support interoperable and secure health information technology, as well as value-based payment models (e.g., e-measures). Our letter highlights several areas where we believe the agency should focus its resources.