Dear Senator Leahy:
The American Health Information Management Association (AHIMA) and the American Medical Informatics Association (AMIA) support your most recent privacy amendment draft for S. 1693, the "Wired for Health Care Quality Act." Your amendment proposes constructive mechanisms that enable the forward movement of health information technology legislation by addressing privacy and confidentiality issues that have troubled Congress and other policymakers for years.
As we express our support for your amendment, we also want to note a concern that our organizations share with regard to the following provision in your legislative language:
- Definition of the Personal Health Record (PHR): AMIA and AHIMA are concerned that your definition of the PHR is limited to "…an entity that is not a covered entity under HIPAA." We believe that the definition of a PHR needs to be standardized across the industry. A standardized definition leads to standard rights and responsibilities and reduces the confusion for consumers interacting with PHRs. AHIMA and AMIA therefore recommend deleting the language that states "…that is not a covered entity under HIPAA." We do not believe this would impact HIPAA’s coverage of PHRs offered by covered entities. AHIMA has been very actively promoting consumer use of PHRs through a public education campaign and for further information, you can visit www.myphr.com.