National Committee on Vital & Health Statistics

September 16, 1998

Health Care Financing Administration
Department of Health and Human Services
Attention: HCFA-0049-P
P.O. Box 26585
Baltimore, MD 21207-0519

To Whom It May Concern:

The National Committee on Vital and Health Statistics (NCVHS) is pleased to submit the following comments on the Notice of Proposed Rule Making (NPRM) labeled HCFA-0049-P.

In hearings conducted by the National Committee last August, we learned that poor security practices are commonplace in the handling of paper-based health information and the move toward electronic storage and transmission only heightens concerns. Health care organizations have been slow to adopt strong security practices largely due to the absence of strong management and organizational incentives. This proposal for Security and Electronic Signature Standards is a positive step toward changing these incentives with its requirements that all health care entities must safeguard the integrity, confidentiality, and availability of their electronic data.

We are pleased that these proposed rules incorporate all of the NCVHS recommendations made to the Secretary last year. The technology-neutral standard that will promote interoperability among information systems, the accommodation of different sizes of health care entities, and the consideration of the cost of implementation are of particular importance.

Although strong national privacy legislation or regulation is still needed to ensure privacy of individuals’ health information, broad application of these standards for the security of health information will help a great deal. We commend your efforts.


Don E. Detmer, M.D.