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Responsible management of Public Health Data
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Betty Jung
Send letter to journal:
bcj17{at}columbia.edu Betty Jung
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RE: Informational Privacy and the Public’s Health: The Model State Public Health Privacy Act (L.O. Gostin, J.G. Hodge, Jr., R.O Valdiserri) in September, 2001 issue of AJPH. Gostin, Hodge & Valdiserri’s "The Model State Public Health Privacy Act" is a much needed step in helping to define how Public Health will address issues of health information privacy. This issue is the crux of the HIPAA compliance the health care sector is currently grappling with. While privacy of health information has always been a concern to individuals, compromising this privacy has been greatly enhanced by advances in information technology. This is not fully addressed in this model. First, disclosure point #5 regarding "appropriate public or private agencies performing health oversight function…" needs more clarification. Of all governmental agencies, Public Health usually do not have the resources it needs to perform the functions necessary to achieve its mission. The lack of resources gets worse at the state level, and almost pitiful at the local level. Public Health has been always extremely creative through coalition building and community partnerships to provide the services necessary for ensuring the Public’s health. However, it will need legal support to justify the need to dedicate intra-agency resources to manage the growing burden of data in its possession. Current strategies proposed by the information technology sector and state governments to warehouse and/or farm out data management to the private sector for efficient data management and to save money may not be the most appropriate solutions to handling sensitive health data. I would like to see: 1. All health data Public Health is responsible for to remain within the purview and jurisdiction of Public Health agencies; 2. Those at the health data collection level be primarily responsible for: a. Informing the patients they collect data from that such data will be shared with public health authorities, should the need arise (i.e., health care providers, laboratories, etc.), b. Ensuring the accuracy of the health data that are submitted to public health agencies. Second, while it is reasonable to expect public health practitioners to ensure the accuracy of the data they collect (i.e., environmental sampling, community surveys, etc.), it would be a logistical nightmare to expect public health practitioners to correct errors in the health data they manage (i.e., mandatory disease reports). This distinction needs to be made. Finally, should the sentence in Figure 1, under "Protected Health Information" read "Any information that relates to an individual’s physical or mental health status, condition, or, treatment, and which (a) reveals the identity…." rather than "identify??? Thank you for your time. Betty C. Jung, RN, MPH
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