Washington, D.C., April 4, 2002 - The Association of American Medical Colleges (AAMC) issued the following statement today, regarding the U.S. Department of Health and Human Services' proposed modification to the Standards for the Privacy of Individually Identifiable Health Information:

When the Secretary of the Department of Health and Human Services allowed the federal medical privacy rule to take effect in April of 2001, the Association of American Medical Colleges expressed grave concern that the rule's complex procedural barriers to the use of protected health information and the associated liability borne by hospitals and providers will seriously impede healthcare delivery, research, and medical education. Today, on behalf of the AAMC, I commend the Secretary's willingness, as evidenced in the notice of proposed rulemaking (NPRM), to increase the rule's "workability" by reducing the significant obstacles that the rule erects to the conduct of essential biomedical, epidemiological, and health services research and the provision of healthcare.

The AAMC represents the nation's 125 accredited medical schools, over 400 major teaching hospitals and health care systems, more than 105,000 faculty in 98 academic and scientific societies, and the nation's 67,000 medical students and 102,000 residents. We are committed to promoting integrity in all the core missions of academic medicine - teaching, research, patient care, and community service. A longstanding advocate for federal legislation to protect medical privacy, the AAMC has consistently underscored the importance of respecting patient autonomy and the privacy and confidentiality of individually identifiable medical information.

We firmly believe that strong protections for the privacy of medical information can be accomplished without jeopardizing either medical care or health research. The changes proposed in the NPRM go far to correct the imbalances contained in the privacy regulation. Among the changes of particular significance for research, the Secretary has proposed to condense the new privacy forms that a patient must review before participating in clinical trials and to refocus the waiver criteria for research on the adequacy of a researcher's plans to safeguard patients' information. The Secretary's proposal would also remedy the rule's inexplicably burdensome requirement that providers track and account for disclosures of which the patient is already aware.

With this NPRM the Secretary moves substantially toward restoration of the necessary balance between medical privacy and other equally important public interests, including quality healthcare and research-related advances in treatment and prevention. The AAMC offers our strong endorsement of the proposals in the NPRM. We note, however, that additional progress is needed if the privacy rule is to become a truly workable standard that does not unduly impede patient care and research. Among the necessary improvements are modifications to the de-identification standard and the fundraising provisions, further reductions in the rule's burdensome accounting requirements, and revisions that would permit academic medical centers to designate all their components, including the medical school, as part of either a hybrid or affiliated entity for the purposes of HIPAA compliance. A draft of our comment letter detailing our specific response to the NPRM is available.

The AAMC recognizes that the Secretary never intended that the Privacy Rule should compromise or prevent vital biomedical and public health research, and we are grateful to the Secretary and the Department for their responsiveness to the concerns raised by the scientific community.

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The Association of American Medical Colleges represents the 125 accredited U.S. medical schools; the 16 accredited Canadian medical schools; some 400 major teaching hospitals, including Veterans Administration medical centers; more than 105,000 faculty in 98 academic and scientific societies; and the nation's 66,000 medical students and 97,000 residents. Additional information about the AAMC and U.S. medical schools and teaching hospitals is available at www.aamc.org/newsroom.

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The Association of American Medical Colleges is a not-for-profit association representing all 129 accredited U.S. and 17 accredited Canadian medical schools; nearly 400 major teaching hospitals and health systems, including 68 Department of Veterans Affairs medical centers; and 94 academic and scientific societies. Through these institutions and organizations, the AAMC represents 109,000 faculty members, 67,000 medical students, and 104,000 resident physicians. Additional information about the AAMC and U.S. medical schools and teaching hospitals is available at www.aamc.org/newsroom.

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