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On the Notice of Privacy Practices

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Encryption and HHS are Taking Hits

[By D. Kellus Pruitt DDS]

1-darrellpruittIt is bad politics for the President’s Department of Health and Human Services to get caught deceiving voters.

Word gets around much faster than it did before transparency sucked the power from the entrenched.

The NoPP

You know those Notice of Privacy Practices (NoPP) forms we are asked to sign in doctors’ offices? Since it makes no difference to anyone whether patients sign them or not, why needlessly waste everyone’s time? The NoPP is not an agreement, and just because virtually everyone is tricked into signing it, does not mean anyone reads it. HIPAA has become a source of danger to patients, with no redeeming value.

HHS Estimates 

According to the US Department of Health and Human Services own recent estimate:

“… many centuries of time—nearly 35 centuries, in fact, or just short of 30.7 million hours—will be devoted each year by healthcare providers and patients for the dissemination to patients and their acknowledgement of HIPAA notices of privacy practices [NoPP] for protected healthcare information, HHS estimates. Even at just 3 minutes apiece, with 613 million of these routine privacy notices to be delivered, signed and stored, the time adds up…”

-Joseph Conn

… “HHS estimates 32.8 million hours of interaction required to comply with privacy, security rules” …

-ModernHealtcare.com [September 5, 2013]

http://www.modernhealthcare.com/article/20130904/BLOG/309049995?AllowView=VW8xUmo5Q21TcWJOb1gzb0tNN3RLZ0h0MWg5SVgra3NZRzROR3l0WWRMWGJYZjBGRWxyd01qUzMyWmVpNTNnWUpiV2s=&utm_source=link-20130904-BLOG-309049995&utm_medium=email&utm_campaign=hits

Censorship Concerns? 

I tried to bring attention to this absurdity over a year ago – back when HHS was still keeping unfavorable news about EHRs hidden from voters using censorship:

… “Put another way, the ONLY reason for a doctor to ask patients if they feel like signing the NoPP is to protect already busy doctors from a HIPAA fine. How is that not senseless, yet admittedly humorous bureaucratic waste?” …

On July 3, 2012, my opinion of the waste that HHS recently confirmed was censored by an HHS employee from the taxpayer-supported Linkedin site, Health IT and Electronic Health Records. If that is not against federal law, it damn sure should be.

http://www.linkedin.com/groups/IT-in-Healthcare-Why-Building-3993178.S.216432610?qid=bafac2e5-fb9c-4a39-8348-5a3074abff67&trk=groups_items_see_more-0-b-ttl

Among the items that HHS requires providers include in Notices of Privacy Practice is a one-sentence statement addressing data breaches:

…“We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information [unless it is encrypted]”…

http://www.hhs.gov/ocr/privacy/hipaa/npp_booklet_hc_provider.pdf

Now that it is widely known that encryption is no longer acceptably secure, protection from accountability is encryption vendors’ only remaining selling point. HIPAA stipulates that if breached patient information is encrypted according to standards set forth by the National Institute of Standards and Technology (NIST), doctors are freed from the tremendous cost of notifying (former) patients – even though patients’ privacy and security have been nevertheless compromised.

For example, two weeks ago, the NIST abandoned the very encryption standards that HIPAA demands. Oops! (See: “Government Standards Agency ‘Strongly’ Suggests Dropping its Own Encryption Standard,” by Jeff Larson and Justin Elliott, ProPublica, September 13, 2013).

http://www.propublica.org/article/standards-agency-strongly-suggests-dropping-its-own-encryption-standard

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eMR Privacy

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NSA Secrets 

US spy agency NSA’s secret success at decrypting previously impenetrable codes – which was revealed by former NSA contractor Edward Snowden – proves that today’s best encryption is tomorrow’s crossword puzzle. What’s more, once an individual’s medical identity is lost in the cloud, it can never be reeled back in.

And, when DNA records are included, a breach today could put the welfare of generations of Americans at risk.

A Gut-Check 

The ultimate gut-check: If your encrypted identity were fumbled, wouldn’t you want to be notified? Of course you would.

Assessment 

In my opinion, the HIPAA Rule should be immediately amended to demand notification of all individuals involved in all data breaches unless they allow opt out. Who knows? Some might prefer not to be bothered.

What is your opinion; doctor, patient and/or consultant?

Conclusion

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Gulf Cleanup Training Ignores Advice from Health Agency

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Concerned Workplace Safety Experts 

By Sasha Chavkin, ProPublica – June 17, 2010 2:05 pm EDT

As we’ve reported, workplace safety experts have expressed concern that Gulf oil spill responders aren’t getting enough safety training [1]. On Wednesday, we spoke with a federal official who said the four-hour safety course that BP is providing to Gulf cleanup workers lacks basic information on health risks and is too short to cover the necessary material.

Joseph Hughes, director of the worker training program at the National Institute for Environmental Health Sciences, said the course fails to incorporate important information. Among the subjects not included are chemical inhalation, the health effects of dispersants, and the risks of direct contact with weathered crude oil.

Hughes’ agency, part of the Department of Health and Human Services, helped develop the training. “We tried to recommend what we thought the right training topics were, but all of those were not included,” he said.

ProPublica Reports

As we reported on Wednesday, cleanup workers are continuing to suffer health problems [2] [2] that they believe to be related to chemical exposure, including vomiting, dizziness, and nose and throat irritation.

Hughes also said the course’s four-hour duration — a fraction of the 24-hour training usually required for cleanup workers [3] [3] who may be exposed to hazardous materials — is insufficient and rests upon a faulty interpretation of safety regulations. In 1990, the Occupational Safety and Health Administration issued a directive following the Exxon-Valdez disaster that allowed the minimum training to be cut to four hours [4] [4] for workers performing low-risk tasks such as beach cleanup.

“The idea of the Exxon-Valdez exemption is that they would not have direct contact with crude oil or weathered oil,” Hughes said. However, he said that some spill responders receiving the four-hour training, such as booming and skimming workers on vessels, are “definitely having direct oil contact.”

The BP Spokesman

BP spokesman Toby Odone stated that the safety trainings are appropriate for the work people are doing. “Training for Vessels of Opportunity and shoreline workers is 4+ hours and includes properties of oil, insect bites, heat, marine operations such as laying and collecting boom,” Odone wrote in an e-mail. The Vessels of Opportunity program employs local boat operators and crews in cleanup activities.

Odone also wrote that workers going into oiled areas are accompanied by a technician with 40 hours of training, and that the training was approved by the government. “It was developed with OSHA and approved by OSHA and the US Coast Guard,” he wrote.

OSHA is in charge of monitoring workplace safety for the cleanup. We at ProPublica have been trying to get in touch with officials there since Monday to discuss the safety trainings, but haven’t yet gotten a response.

Hughes said that his office is pressing Unified Command — the interagency spill response team that consists of BP, Transocean, the Coast Guard and numerous federal agencies — to implement an eight-hour training course for those at greater risk of contact with hazardous materials. The course would include the chemical exposure curriculum that is not provided in the current trainings.

“The group that I’m still concerned about is the booming and skimming workers,” Hughes said. “There’s an effort under way to increase the training of those workers that’s being discussed at the highest level.”

On Wednesday, Aubrey Miller, senior medical adviser in Hughes’ agency, testified to a House subcommittee that OSHA is “working with BP to develop a new eight-hour curriculum [5] [5] for worker safety and health training,” according to a transcript of his remarks provided by the agency.

Hughes said he had not heard any dates for when this eight-hour training program would start.

wind

Assessment

As it stands, Hughes said the training goes against the precautionary principle — the concept that the possibility of harm is enough to warrant action to reduce the risks to public health.

We thought it was backwards,” he said of the current curriculum,“that it had a reduced amount of protection for workers.”

Link: http://www.propublica.org/feature/gulf-cleanup-training-ignores-advice-from-health-agency-official-says

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PR Firm Behind Propaganda Videos Wins HIT Stimulus Contract

Ketchum Deep in Controversy

By Sebastian Jones and Michael Grabell

ProPublica – March 30, 2010 12:26 pm EDT

President Obama’s push for electronic medical records [1] has faced resistance from those who question whether health information technology systems can protect patient privacy. So last week, the U.S Department of Health and Human Services hired a public relations firm to try to win consumer trust.

The irony?

The firm chosen for the job — Ketchum Inc. [2] — was hip-deep in controversy a few years ago for producing a series of fake TV news stories that violated a federal ban on propaganda. The company also drew fire for channeling taxpayer funds to a conservative pundit to promote the Bush administration’s education policies.

About Ketchum

Ketchum, based in New York, is one of the world’s largest public relations firms, with a host of large corporate clients and a history of winning government contracts. Company spokeswoman Alicia Stetzer declined to answer questions about the $25.8 million contract, funded by the federal stimulus package. Nancy Szemraj, a spokeswoman for the government’s health IT initiative, said the PR firm won the contract over four other companies because of its ability to attract public acceptance. “Ketchum has a long rich history of doing outstanding communication outreach work for large social marketing endeavors,” Szemraj said. “They are very capable of moving the needle, with has to happen here.”

She noted that Ketchum’s work helped HHS enroll 35 million people in the Medicare prescription drug program. And she said all of the firm’s marketing ideas would be reviewed by senior managers at HHS.

Consumer advocates warned that the PR contract will only heighten skepticism about the security of online health records. A poll [3] conducted last year by NPR, the Kaiser Family Foundation and the Harvard School of Public Health found that roughly six in 10 Americans lack confidence in the privacy of online health records.

Public Suspicions

“The public has always been very suspicious over whether electronic health information will be safe,” said Dr. Deborah C. Peel, a physician and founder of the Coalition for Patient Privacy, which includes consumer, privacy and health groups. Peel called Ketchum a “very, very troubling choice because the last thing the public needs are more tricks being pulled on them.”

During the Bush administration, Ketchum and its former lobbying arm, the Washington Group, had several prominent Republicans on the payroll, including former New York Rep. Susan Molinari. In the last year, it has beefed up its Democratic credentials, hiring Jonathan Kopp, a member of the Obama campaign’s national media team, and Donald J. Foley, a longtime Democratic strategist.

Ketchum has continued to draw government work – particularly from HHS – despite a series of reports in 2004 [4] and 2005 [5], in which Government Accountability Office investigators found it had produced a series of video news releases that constituted “covert propaganda” because they did not disclose they were paid for by the federal government.

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The segments aired during local television broadcasts on at least 40 stations across the country. Designed to look like news reports, each concluded with a paid actor posing as a journalist reporting from Washington.

One series was produced for HHS in an effort to promote the Medicare prescription drug program to seniors. The others were paid for by the Department of Education. Overall, video news releases have become increasingly common, used by large public relations firms and companies to repackage advertisements as news. [6]

Prior Controversy

Ketchum was involved in a separate controversy in 2005, when reports surfaced that it had used taxpayer funds to pay syndicated columnist Armstrong Williams $240,000 to promote the No Child Left Behind [7] education bill during radio broadcasts as part of outreach to the African-American community.

In both instances, Ketchum defended its tactics. Stetzer referred reporters to a 2005 PR Week article, in which CEO Ray Kotcher said, “There is no indication that it was ever the intent of Ketchum or any of our people to mislead anyone.”

This time around, HHS has hired Ketchum to provide a “comprehensive campaign for communications and education,” to encourage doctors and hospitals to adopt health IT and to assure the public that their information will be safe.

Assessment

The campaign is part of the administration’s $26 billion health IT program, also backed by the stimulus package, which aims to spearhead the transition to online medical records through grants, bonuses to doctors and hospitals, and the development of national standards.

Link: http://www.propublica.org/ion/stimulus/item/pr-firm-behind-propaganda-videos-wins-stimulus-contract

Conclusion

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Protected Health Information Data Breaches

Affecting 500 or More Individuals

[By Staff Reporters]

As required by section 13402(e)(4) of the HITECH Act, the Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals.

The following breaches have been reported to the Secretary of the US Department of Health and Human Services [DHHS].

Full Report

This link was sent in by our own investigative reporter Darrell K. Pruitt, DDS.

Link: http://www.hhs.gov/ocr/privacy/hipaa/administrative/breachnotificationrule/postedbreaches.html

Assessment

Shall we await a response from Kathleen Sebelius, who was sworn in as the 21st Secretary of the Department of Health and Human Services (HHS) on April 28, 2009?

Currently, she leads the principal agency charged with keeping Americans healthy, ensuring they get the health care they need, and providing children, families, and seniors with the essential human services they depend on. She also oversees one of the largest civilian departments in the federal government, with nearly 80,000 employees.

Conclusion

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The Time Costs of Internal HIPAA Complaints

On Hospital Compliance

By Staff Reporters

The privacy regulations of HIPAA require that each hospital have an internal process to allow an individual to file a complaint concerning the covered entity’s compliance with privacy policies and procedures. This requires hospitals to designate a contact person to be responsible for receiving and documenting the complaint as well as the disposition.

A formal response to the person is not required as part of this rule; therefore it is estimated that each complaint, even though rare, will take ten minutes to document.

Recent Data

Recent data reveals that the most frequent complaints received either by hospitals or ultimately by DHHS include the following:

  • impermissible use or disclosure of individual PHI (most occurrences were curiosity or accidental, yet were reported);
  • lack of safeguards to protect PHI;
  • refusal or failure to provide an individual with access to or a copy of his or her record;
  • disclosure of more information than is minimally necessary; and
  • failure to have the individual’s valid authorization for a disclosure that requires one.

Assessment

Most hospitals have documented and logged such complaints; have reviewed the situation; and have resolved the problem internally.

Conclusion

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