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Financial Services Act of 1999



>
>    EFFector       Vol. 12, No. 2       Sep. 22, 1999

>
>

> NOTE: We apologize to those of you who will not get this alert in
>    time. Some will, some will not, depending on mail queue processing
>    speeds, Net lag and intermediary server delays, etc. We've issued this
>    as fast as possible after gathering the necessary info.
>
>                 Electronic Frontier Foundation ACTION ALERT:
>
>                    H.R. 10 "Confidentiality" Legislation
>                         Undermines Medical Privacy!
>
>              (Issued: Sept. 22, 1999; deadline: Sept. 23, 1999)
>
>    ACTION ALERT: Proposed law (US House bill H.R. 10, the "Financial
>    Services Act of 1999") would allow insurance institutions to share
>    your sensitive and personally identifiable medical information without
>    your knowledge or consent, to a wide variety of agencies and financial
>    and research entities. H.R. 10 would actually reduce existing medical
>    privacy protections!
>
>    WHY YOU SHOULD CARE: The language in the provision misleadingly named
>    H.R. 10's "Subtitle E: Confidentiality" (and known colloquially as
>    "the Ganske Amendment") is riddled with loopholes that make your
>    private medical information available to law enforcement (with no
>    requirements for a warrant, only a subpoena), to vaguely defined
>    "research" projects, and to virtually all affiliates of insurance
>    companies, even banks, credit agencies, and debt collectors. (See text
>    and analysis at end for more detail.)
>                     ___________________________________
>

[....]

>      FULL TEXT: The text of the relevant section of the bill reads:
>
>    Subtitle E--Confidentiality
>
>    SEC. 351. CONFIDENTIALITY OF HEALTH AND MEDICAL INFORMATION.
>    (a) IN GENERAL- A company which underwrites or sells annuities
>    contracts or contracts insuring, guaranteeing, or indemnifying
>    against loss, harm, damage, illness, disability, or death (other
>    than credit-related insurance) and any subsidiary or affiliate
>    thereof shall maintain a practice of protecting the
>    confidentiality of individually identifiable customer health and
>    medical and genetic information and may disclose such information
>    only--
>
>        (1) with the consent, or at the direction, of the customer;
>        (2) for insurance underwriting and reinsuring policies, account
>        administration, reporting, investigating, or preventing fraud or
>        material misrepresentation, processing premium payments,
>        processing insurance claims, administering insurance benefits
>        (including utilization review activities), providing information
>        to the customer's physician or other health care provider,
>        participating in research projects, enabling the purchase,
>        transfer, merger, or sale of any insurance-related business, or as
>        otherwise required or specifically permitted by Federal or State
>        law; or
>        (3) in connection with--
>
>         (A) the authorization, settlement, billing, processing, clearing,
>         transferring, reconciling, or collection of amounts charged,
>         debited, or otherwise paid using a debit, credit, or other payment
>         card or account number, or by other payment means;
>         (B) the transfer of receivables, accounts, or interest therein;
>         (C) the audit of the debit, credit, or other payment information;
>         (D) compliance with Federal, State, or local law;
>         (E) compliance with a properly authorized civil, criminal, or
>         regulatory investigation by Federal, State, or local authorities
>         as governed by the requirements of this section; or
>         (F) fraud protection, risk control, resolving customer disputes or
>         inquiries, communicating with the person to whom the information
>         relates, or reporting to consumer reporting agencies.
>
>    (b) STATE ACTIONS FOR VIOLATIONS- In addition to such other remedies
>    as are provided under State law, if the chief law enforcement officer
>    of a State, State insurance regulator, or an official or agency
>    designated by a State, has reason to believe that any person has
>    violated or is violating this title, the State may bring an action to
>    enjoin such violation in any appropriate United States district court
>    or in any other court of competent jurisdiction.
>
>    (c) EFFECTIVE DATE; SUNSET-
>        (1) EFFECTIVE DATE- Except as provided in paragraph (2),
>        subsection (a) shall take effect on February 1, 2000.
>        (2) SUNSET- Subsection (a) shall not take effect if, or shall
>        cease to be effective on and after the date on which, legislation
>        is enacted that satisfies the requirements in section 264(c)(1) of
>        the Health Insurance Portability and Accountability Act of 1996
>        (Public Law 104-191; 110 Stat. 2033).
>
>    (d) CONSULTATION- While subsection (a) is in effect, State insurance
>    regulatory authorities, through the National Association of Insurance
>    Commissioners, shall consult with the Secretary of Health and Human
>    Services in connection with the administration of such subsection.
>
>    [end excerpt]
>                     ___________________________________
>
>    ANALYSIS: Section (a) states that in general the confidentiality of
>    medical and genetic information shall be protected. Exceptions follow.
>
>    Subsection (a)(2) will allow medical information to be given out by
>    insurers to virtually any affiliated or assisting entities and also
>    provides for personally identifiable medical data to be used for
>    "research projects" without the consent of the person to whom this
>    intensely revealing information pertains.
>
>    Subsubsections (a)(3)(A), (C) and (F) will allow private medical
>    information to be given out by insurers to credit bureaus, banks, debt
>    settlement entities.
>
>    Subsubsection (a)(3)(E) will allow private medical information to be
>    given out to law enforcement. No provisions are present that would
>    require a warrant before the information is disclosed. A simple
>    administrative subpoena or other display of supposed "authorization"
>    would be sufficient to obtain medical information held by insurance
>    companies.
>
>      _________________________________________________________________
>