CDT Comments to HHS Accounting of Disclosures NPRM

CDT has repeatedly called for a comprehensive framework of privacy and security protections for health data that address the full complement of fair information practices (FIPs).

FIPs, which provided the foundation for the HIPAA Privacy and Security Rules, are fundamental to privacy law both domestically and internationally. The Office of the National Coordinator for Health Information Technology (ONC) also adopted FIPs through the Nationwide Privacy and Security Framework for Electronic Exchange of Individually Identifiable Health Information.

Openness and transparency about personal information access, use and disclosure is a fundamental tenet of FIPs. Transparency supports accountability, consumer choice and trust while providing a deterrent to unauthorized access. A recent survey by the Markle Foundation indicates that both doctors and the public strongly support letting patients see who has accessed their records, and requirements to account for disclosures provide a vehicle for greater transparency into how an individualʼs information is actually accessed, used and disclosed.


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