June 25, 2003
The Honorable Tommy G. Thompson
Secretary of Health and Human Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
Dear Secretary Thompson:
As part of its responsibilities under the Health Insurance Portability and Accountability Act (HIPAA), the National Committee on Vital and Health Statistics (NCVHS) has written you letters with recommendations about substantive provisions of, and implementation strategies regarding, the HIPAA Privacy Rule.
The NCVHS believes that now is an especially opportune time to develop methodologies and collect baseline data for analyzing the effects of the Privacy Rule. We recommend that the Department initiates a program to measure the effects of the Privacy Rule. An ongoing program will help to refine rulemaking, implementation, and enforcement strategies for the Privacy Rule.
Among other things, it would be valuable to study the effects of the Privacy Rule on such crucial matters as clinical care, public health reporting, research, and the research enterprise. It could also assess the degree to which the Privacy Rule has affected the level of privacy and confidentiality for protected health information, in both objective and subjective terms.
The NCVHS would be pleased to assist the Department in developing strategies for this program. We appreciate the opportunity to provide this recommendation.
John R. Lumpkin, M.D., M.P.H.
Chair, National Committee on Vital and Health Statistics
Cc: HHS Data Council Co-Chairs