Possible Changes to HIPAA – What’s this RFI All About (A Summary)

January 14, 2019

Over the past month, I’ve been tweeting and blogging about possible HIPAA changes that may be in store after the OCR (Office for Civil Rights – HIPAA enforcers) published a Request for Information (RFI). With the deadline for comments about a month away (February 12, 2019), I thought I’d distill the information into a bit of a summary – a sort of tl;dr version of my last 5 posts.

I’d encourage anyone interested in your healthcare privacy rights to read over the information here. I’ve suggested questions at the end of each section for you to consider and will follow up in my next post with how you can submit comments on the RFI.

What is this RFI?

This is NOT a chance to comment on everything we don’t like about HIPAA. While we all know there are many places where HIPAA can be improved, this RFI is about 5 specific areas of HIPAA. The OCR has proposed very specific questions in each area for people to answer and those are what they want feedback on (those questions can be found here).

The 5 areas include:

  • Sharing information between doctors
  • Sharing substance use and mental health information with friends and family
  • Accounting of Disclosures
  • Notice of Privacy Practices
  • HIPAA “burdens” that prevent policy goals around Value-Based Care

There’s a lot here and you certainly don’t have to address every part of the RFI. You can pick and choose what is most important to you.

The rules they are interested in are primarily part of the HIPAA Privacy Rule found at 45 CFR 164, Subpart E (for the nerds who would like to catch up on the current language). In each of my previous posts I’ve taken these areas one by one and answered the questions in detail. I’ve given background on why they matter, examples of how they work now, and concerns as to why and how potential changes will harm patients.

To be clear: Changes suggested in each part will hurt patients.

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Possible HIPAA Changes Could Compromise Privacy of Substance Use and Mental Health Information (RFI Part 2)

December 19, 2018

Trauma Informed Care Principles

June 25, 2018

Current events are bringing awareness to trauma and its lasting effects on the mind and body.  But few are talking about the implications this has for trauma survivors in seeking care and the lack of trauma informed care in medicine.

Trauma Informed Care: when every part of a service is assessed and potentially modified to include an understanding of the emotional issues, expectations, and special needs that a trauma survivor may have in a healthcare setting.[1],[2]

Trauma informed care needs to be a central aspect of these discussions as trauma lasts a lifetime but few health care providers are well trained in the trauma-informed care approaches. This means that many with a history of trauma – which can include medical trauma, domestic violence, childhood abuse, sexual assault, and more – can face retraumitization when seeking care. Unfortunately, this population often needs more care as trauma brings chronic physical and psychological illnesses or to address injuries caused by trauma (even long after the traumatic incident).

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Healthcare Does Not Have a Problem With Silos

August 3, 2017

Healthcare does not have a problem with silos.

In fact, there are no silos in healthcare; there are only boundaries.

If we truly want to change healthcare, we need to break boundaries.

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Housing is a Human Right

July 30, 2017

A year ago, through the kindness of a friend, I finally got a home.  I moved into a one-bedroom apartment with my cats in a quiet neighborhood after a year of homelessness.  And in this year, I have been able to heal and find myself again.

We talk about social determinants of health, but I think few people really understand how impactful they truly are, particularly housing.

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Rights

January 29, 2017

This blog has never been wonderfully defined.  It is “Health as a Human Right” because I knew when I started writing that human rights, especially the right to health is a passion of mine.  I wasn’t sure exactly where I wanted it to go and started by talking about current events or issues in healthcare and policy.  It has over the years come to include more of my personal experiences fighting physical and mental health illnesses.  And now I’m expanding the scope once again, to include all rights.

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Forming Nebular Health Tech in Austin

March 22, 2013

I want to repost this post from the new Nebular Health Tech group founded today in Austin, TX.  As you can tell from this blog, Health IT is incredibly important to me as a human rights advocate, an ePatient, a lawyer, and an activist.

Here is the story about forming Nebular Health Tech in Austin:

While other posts may be more innovation news oriented (guest posts welcome!), I wanted to start with a post about the formation of Nebular Health Tech – what this group is about, who we are, what we’ll do, how we can make a difference in health and healthcare.

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