On April 14, NYeC submitted comments to the Office for Civil Rights’ (OCR) on the Proposed Modifications to the HIPAA Privacy Rule. Comments reflect NYeC’s support of the proposed revisions to remove barriers to coordinated care and enhance the individual right of access, while ensuring the privacy and security of patient health information. Among other things, we urge OCR to provide regulatory clarity and guidance on the scope of an HIE’s permissions under HIPAA, as well as proposed definitions of electronic health record, healthcare operations, and community based organizations. Our comments reflect experiences from the SHIN-NY in facilitating HIPAA permitted disclosures, including individual access to health information and exchange with community based organizations.
Read the full letter here