The AAMC Feb. 11 submitted comments to the Health and Human Services Office of Civil Rights (OCR) in response to its Request for Information on seeking input on how the Health Insurance Portability and Accountability Act (HIPAA, P.L. 104-191) can be modified to promote coordinated, value-based care [see Washington Highlights, Dec. 14, 2018].
In its comments, the AAMC expressed appreciation that the OCR is concerned that HIPAA privacy rules may create obstacles to efficient care coordination, case management, and the transformation to value-based care. The AAMC noted that many of these issues can be addressed through additional education and guidance. The association also highlighted some opportunities where changes to the rules would be beneficial, including:
- Allowing covered entities to disclose protected health information (PHI) to social service agencies and community-based support programs where necessary to facilitate treatment and coordination of care;
- The expansion of the minimum necessary standard for reasons, such as population-based care management and care coordination, claims management, and review of health care services;
- Aligning 42 CFR Part 2 and HIPAA to address barriers that the privacy rule presents with respect to sharing PHI with family members, caregivers, or others who may be able to support individuals with substance abuse disorders or serious mental illnesses; and
- Reducing burden by eliminating the requirements for acknowledgement of receipt of the Notice of Privacy Practices.