Statement Re: Administrative Simplification section of H3103

[JWRCLUM@aol.com]

  This section should be opposed because:
  
  1.  it creates the framework for a national medical data collection and data
  transfer system, beginning with claims and billing data and proceeding to the
  entire medical record.  The system will include data processing
  clearinghouses, which may also serve as repositories for data.
  
  2.  it requires the Secretary of HHS to assign a unique I.D. to every
  patient, health provider, health plan, and employer, thereby establishing a
  vast national numbering system.
  
  3.  it gives new powers and duties to the National Committee on Vital and
  Health Statistics, authorizing extensive new statistical studies, including
  "health status" studies.  These studies no doubt will make use of the large
  stores of individually identified medical information which will now be
  easily obtainable (especially by this committee; see what follows).
  
  4.  it will be advising the Secretary of HHS on privacy regulations, a
  responsibility in conflict with its duties of data collection and analysis.
   The committee, which will be composed largely of statisticians,
  epidemiologists, health services researchers and experts on computerized
  medical information systems, is ill suited for protecting the patient's right
  to privacy and medical record confidentiality.
  
  THE ADMINISTRATIVE SIMPLIFICATION SECTION CANNOT BE FIXED.   IT MUST BE
  REMOVED FROM THE BILL.
  
  ACLU of Massachusetts
  Privacy Committee