NATIONAL HEALTH INFORMATION NETWORK, WITH EMPHASIS ON SECURITY AND PRIVACY ISSUES

Approved by the
IEEE-USA Board of Directors
17 June 2005

IEEE-USA advocates transitioning from our current state of disconnected health information systems to a National Health Information Network (NHIN) that would make use of leading-edge networking technologies, such as web services, mobile communications, and multimedia communications to provide secure and reliable transport of healthcare information. To that end, IEEE-USA makes the following recommendations to the Department of Health and Human Services, the Office of the National Coordinator for Health Information Technology, legislators, administrators and healthcare regulators:

1. Transition to the desired National Health Information Network should be accomplished by building upon existing systems by increasing the reliability, availability and security of these networks. To the extent feasible, the NHIN should support appropriate authorization for access to the distributed nature of health information where it currently resides. It should not rely upon developing and maintaining new, government-controlled, centralized databases or personal health information repositories.
2. Economic policies covering provider expense for transition to the National Health Information Network and adopting an Electronic Health Record should be favorably designed to facilitate provider conversion.
3. Development of the National Health Information Network should not compromise the security and privacy of personally identifiable health information, as currently defined in the HIPAA Privacy and Security Final Rules.
4. Use of the National Health Information Network should adhere to the guidelines on use of genetic information cited in IEEE-USA’s position statement on "Non-discrimination in Employment Based on Genetic and Other Health Information," August 2002.
5. The National Health Information Network should implement the capability to provide public warnings about bioterrorism, epidemic disease, safety and efficacy of vaccines, etc.
6. The National Health Information Network should encourage patient access to medical records and establish “cradle to grave” longitudinal medical records.
7. The standard of such “cradle to grave” records should not be restricted to data pertinent to acute care settings, and should include key data fields from long-term care’s Minimum Data Set to make such records useful throughout the different care settings, including long-term care.
8. The National Health Information Network should develop and implement metrics to document the costs, benefits and unintended favorable and adverse impacts of sharing healthcare information and electronic health records.
9. The NHIN should support federal and state government public health surveillance activities - relative to reportable diseases, health conditions, injuries and risk factors. It should enable these respective public health authorities to secure necessary statistical data by providing a direct means by which they could trace the reports back to individual health providers, and an indirect means by which individual patients could be contacted, if needed, for epidemiologic investigation.
10. The National Health Information Network should be supportive of quality control efforts at institutional, state and national levels by having a means by which quality control staff at all three levels can obtain appropriate authorization to access current statistical data for comparison with like facilities, baselines and benchmarks.
11. The NHIN should have a provision so that appropriately authorized persons in academic and governmental settings can access detailed statistical data for research purposes.
12. The NHIN should support individually specifiable privacy preferences for all healthcare consumers. It should include provisions so that patients could indicate their willingness or unwillingness to be solicited as subjects of medical research by authorized investigators from academic and governmental agencies.

Development of a National Health Information Network would require a joint effort by federal, state and local governments and the private sector. Working jointly would increase interoperability, reduce risk, and ensure that a competitive market existed for products intended for producing healthcare services in a networked environment. However, creating a NHIN also creates new requirements for reliability, availability and maintaining healthcare information privacy and security.

This statement was developed by IEEE-USA's Medical Technology Policy Committee and represents the considered judgment of a group of U.S. IEEE members with expertise in the subject field. IEEE-USA is an organizational unit of the IEEE. It was created in 1973 to advance the public good and promote the careers and public-policy interests of the more than 220,000 technology professionals who are U.S. members of the IEEE. The IEEE is the world's largest technical professional society. For more information, go to http://www.ieeeusa.org.

BACKGROUND

In April 2004, the President signed Executive Order 13335, Incentives for the Use of Health Information Technology and Establishing the Position of the National Health Information Technology Coordinator, which is designed to promote the development of a nationwide interoperable health information technology infrastructure. In addition to improving health care quality, the Executive Order envisions that this infrastructure will result in a more effective marketplace, greater competition, and increased choice through wider availability of accurate information on health care costs, quality and outcomes. See: http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2004/pdf/04-10024.pdf

To implement the Executive Order, the Department of Health and Human Services has established the Office of the National Coordinator for Health Information Technology. In turn, ONCHIT has established a Framework for Strategic Action. One of its goals is to help personalize healthcare. Consumer-centric information helps individuals have choice, control and the ability to manage their own wellness, and it assists with their personal health care decisions.

Benefits of a National Health Information Network could include the following:

• Reducing the number of medical errors -- The fast and ubiquitous access to patient records and other medical information provided by the NHIN could reduce the number of medical errors due to inadequate information regarding a patient's history, prescribed medication and current condition.
• Restraining the rising cost of providing healthcare -- Using an electronic network for transmitting healthcare-related information could reduce the overall cost of providing healthcare by eliminating much of the current paper-based processing of patient records and healthcare insurance claims.
• Providing Fast Access to Healthcare Information in Emergency Situations-- Implementing an NHIN could enable the sharing of confidential medical record information with enough speed and accuracy to be of value to a physician examining an emergency patient at a remote site.
• Coordination of Federal Health Information Systems-- Using an NHIN could expand access to healthcare information for healthcare providers and consumers. The National Health Information Network must interoperate with existing health information systems to make sharing of public health information, and healthcare delivery, reimbursement and oversight efficient and cost-effective.
• Use of Telehealth Systems to provide access to healthcare services in remote, rural or otherwise underserved areas-- An NHIN could make use of information technology to expand services to underserved areas.
• Accelerate Standardization of Medical Information and Adoption of Electronic Health Records (EHR). Standardized Medical Information transmitted across the NHIN will increase the efficiency of healthcare providers. It should enhance patient ownership and control of personal health information, especially as individuals transition between care settings. In addition, standardized medical information should facilitate quality assurance and clinical research programs.

In 2000, the Institute of Medicine estimated that 44,000 to 98,000 people die each year from medical errors in hospitals. See To Err is Human: Building a Safer Health System. Institute of Medicine, National Academies Press, 2000 at http://www.nap.edu/openbook/0309068371/html/.

Medical errors have been found in one of every five doses given in typical hospitals and skilled nursing facilities, and seven percent of those errors were potentially life-threatening. See Barker, K.N., Flynn, E.A., Pepper, G.A., et al., "Medication Errors Observed in 36 Healthcare Facilities," Archives of Internal Medicine, 2002:162 (1897-1903).

Healthcare costs have risen more than ten percent in each of the past three years. See the 2003 Kaiser Employer Health Benefits 2003 Annual Survey at http://www.kff.org/insurance/ehbs2003-1-set.cfm.

Many diagnostic tests are repeated needlessly because medical history and results of earlier tests are not available. See Health Information Management Systems Society, "EHR and the Return on Investment" at http://www.himss.org/content/files/EHR-ROI.pdf.

The Center for Information Technology Leadership projects annual savings of approximately $44 billion with the nation-wide adoption of computerized order-entry systems that incorporate decision support systems. See http://www.citl.org/research/ACPOE.htm.

Veterans Administration hospitals have demonstrated the effectiveness of online Emergency Health Records in reducing medical errors and decreasing cost of care. Annual cost of care per eligible veteran has decreased by nearly half, according to a presentation given to the President's Information Technology Advisory Council by Anthony Principi, Secretary, and Jonathan Perlin, Deputy Undersecretary for Health, Department of Veterans Affairs, November 2003.

The administrative simplification subtitle of HIPAA and its final security rule specify safeguards for health plans, healthcare clearinghouses, and healthcare providers to assure the security of electronic protected health information (PHI).  See http://www.cms.hhs.gov/hipaa/hipaa2/regulations/security/default.asp.

Koppel et al published a paper entitled “Role of Computerized Physician Order Entry Systems in Facilitating Medication Errors (JAMA 2005; 293:1197-1203; March 9, 2005). This paper documented the creation of new medication errors through implementing computer-based information systems. It stands as a warning that, as we encourage use of such systems, we must be vigilant in reducing and eventually eliminating such adverse consequences.

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Last Update: 22 June 2005
Staff Contact: Deborah Rudolph