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HIE Privacy and Security Program Information Notice (ONC-HIE-PIN-003)

HIE Privacy and Security Program Information Notice (ONC-HIE-PIN-003)

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Published by Brian Ahier

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Published by: Brian Ahier on Mar 23, 2012
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Program Information Notice
Document Number:
ONC-HIE-PIN-003
Date:
March 22, 2012
Document Title:
Privacy and Security Framework Requirements and Guidance for the StateHealth Information Exchange Cooperative Agreement Program
To
: State Health Information Exchange Cooperative Agreement Program Award Recipients As stated in the State Health Information Exchange Cooperative Agreement Program FundingOpportunity Announcement (FOA), the Office of the National Coordinator for Health InformationTechnology (ONC) may offer program guidance to provide assistance and direction to statesand State Designated Entities (SDEs) that receive awards under the program. This ProgramInformation Notice (PIN) provides additional direction to states and SDEs receiving fundingunder the State Health Information Exchange Cooperative Agreement Program on privacy andsecurity frameworks required as part of grantee strategic and operational plan (SOP) updates.The National Quality Strategy sets three aims for improving health care in our country: better care, affordable care, and healthy people and communities. Information that is accurate, up todate, and available when and where a patient seeks care is the lifeblood of health careimprovement and crucial to reaching these goals.The stage is set for the nation to make rapidprogress on health information exchange (HIE) this year supporting achievement of the three-part aim.This PIN guidance provides a common set of privacy and security rules of the road to assureprovider and public trust and enable rapid progress in health information exchange to supportpatient care. It addresses concerns from State leaders and other stakeholders that healthinformation exchange efforts have been hampered and slowed by the lack of consistentapproaches to core privacy and security issues and responds to requests for clear nationalguidance.The guidance in this PIN builds from the privacy and security and governance recommendationsof the Health IT Policy Committee as well as the
Nationwide Privacy and Security Framework for Electronic Exchange of Individually Identifiable Health Information
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But the guidance will also be of great utility to state policy leaders and other stakeholdersworking diligently to establish common privacy and security policies and practices for communities, regions and states to enable provider and public trust and support rapid progressin health information exchange. This PIN can serve as a framework and offer specific directionand guidance to these efforts.If you have any questions or require further assistance, please contact your Project Officer.Sincerely,Farzad MostashariNational Coordinator for Health Information Technology
 
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PURPOSE
This PIN provides direction to states and SDEs receiving funding under the State HealthInformation Exchange Cooperative Agreement Program on approaches to ensuring private andsecure health information exchange of individually identifiable health information (IIHI) and onrequirements for privacy and security frameworks submitted as part of 2012 annual updates tograntee SOPs.
APPLICABILITY
This guidance is applicable to all ONC State Health Information Exchange Cooperative Agreement Program recipients (hereafter referred to as “recipients”), whether the recipient is astate government or a state designated entity (SDE).Please note that the terms “shall” and “should” are used in very specific ways in this document.“Shall” represents a mandatory action while “should” reflects a recommended course of actionwithin the State HIE Program.The requirements and guidance discussed in this PIN are not intended to and do not supercedeany applicable provisions of Federal or State law, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations.
REQUIREMENTS FOR SUBMISSION
 As part of their 2012 annual SOP updates, recipients shall submit their privacy and securityframeworks consisting of all relevant statewide policies and practices adopted by recipients, andany operational policies and practices for health information exchange services beingimplemented by the recipient or funded in whole or in part with federal cooperative agreementfunds. Please refer to Appendix A to determine which domains and specific guidance areapplicable to the specific HIE architectural approach the recipient is taking and must beaddressed. Recipients may use the template in Appendix A as a guide and tool for completingthe privacy and security framework for 2012 SOP updates.
DISCUSSION
Recipients shall use this PIN guidance to do the following:
Determine which domains and relevant guidance need to be addressed based on thearchitectural approach the recipient is taking (see Appendix A).
Review existing privacy and security policies and practices to identify where therecipient’s approach aligns with the specific guidance provided for each domain (see“State Health Information Exchange Cooperative Agreement Program Guidance onPrivacy and Security Frameworks”), and where gaps exist.
Where privacy and security policies and practices align with the specific guidanceprovided for each domain, include these policies and practices as part of the 2012annual SOP update.
Where there are gaps in recipient privacy and security policies and practices, i.e., adomain is not addressed or policies are not in alignment with the specific guidance

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