WPF advises HHS regarding proposed changes to standards for privacy under HIPAA

WPF provided detailed comments to the US Department of Health and Human Services regarding its proposal for changes to HIPAA regarding modifications to the Privacy Rule. Specifically, HHS proposed modifications to standards for the privacy of individually identifiable health information. WPF supports many of the changes proposed in the NPRM. In the NPRM’s overview, HHS stated:

“If individuals believe that their Protected Health Information (PHI) may be disclosed without their knowledge or consent to initiate criminal, civil, or administrative investigations or proceedings against them or others based primarily upon their receipt of lawful reproductive health care, they are likely to be less open, honest, or forthcoming about their symptoms and medical history.”

WPF agrees with this statement regarding the chilling effects that medical mistrust can have on all patients and their health outcomes, particularly for those in vulnerable communities that have been impacted by historic and ongoing health disparities.

Related Documents:

Comments of WPF Regarding HHS NPRM proposing modifications to the Standards for Privacy of Individually Identifiable Health Information (Privacy Rule), RIN Number 0945-AA20 (PDF, 11 pages)
Notice of Proposed Rulemaking (NPRM) amending the HIPAA Privacy Rule to modify the Standards for Privacy of Individually Identifiable Health Information (Privacy Rule) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act). 88 Federal Register 23506 (April 17, 2023) https://www.federalregister.gov/documents/2023/04/17/2023-07517/hipaa-privacy-rule-to-support-reproductive-health-care-privacy

Posted June 28, 2023 in Digital Health Ecosystems, Electronic Health Records, Health Privacy, HIPAA, Patient Privacy

New Report: Risky Analysis: Assessing and Improving AI Governance Tools

We are pleased to announce the publication of a new WPF report, “Risky Analysis: Assessing and Improving AI Governance Tools.” This report sets out a definition of AI governance tools, documents why and how these tools are critically important for trustworthy AI, and where these tools are around the world. The report also documents problems in some AI governance tools themselves, and suggests pathways to improve AI governance tools and create an evaluative environment to measure their effectiveness. AI systems should not be deployed without simultaneously evaluating the potential adverse impacts of such systems and mitigating their risks, and most of the world agrees about the need to take precautions against the threats posed. The specific tools and techniques that exist to evaluate and measure AI systems for their inclusiveness, fairness, explainability, privacy, safety and other trustworthiness issues — called in the report collectively AI governance tools – can improve such issues. While some AI governance tools provide reassurance to the public and to regulators, the tools too often lack meaningful oversight and quality assessments. Incomplete or ineffective AI governance tools can create a false sense of confidence, cause unintended problems, and generally undermine the promise of AI systems. The report contains rich background details, use cases, potential solutions to the problems discussed in the report, and a global index of AI Governance Tools.
National IDs Around the World — Interactive map

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Report: From the Filing Cabinet to the Cloud: Updating the Privacy Act of 1974

This comprehensive report and proposed bill text is focused on the Privacy Act of 1974, an important and early Federal privacy law that applies to the government sector and some contractors. The Privacy Act was written for the 1970s information era -- an era that was characterized by the use of mainframe computers and filing cabinets. Today's digital information era looks much different than the '70s: smart phones are smarter than the old mainframes, and documents are now routinely digitized and stored and perhaps even analyzed in the cloud, among many other changes. The report focuses on why the Privacy Act needs an update that will bring it into this century, and how that could look and work. This work was written by Robert Gellman, and informed by a two-year multi-stakeholder process.

WPF advises HHS regarding proposed changes to standards for privacy under HIPAA

Related Documents:

Comments of WPF Regarding HHS NPRM proposing modifications to the Standards for Privacy of Individually Identifiable Health Information (Privacy Rule), RIN Number 0945-AA20 (PDF, 11 pages)