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Agenor Ramadan

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Aug 5, 2024, 4:44:58 AM8/5/24
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So the vision for the Public Health Information Network is indeed to transform public health by coordinating its functions and its organizations, and to enable real time data flow, at least close to real time data flow, to support computer assisted analysis and decision support, to facilitate professional collaboration, and use information technology to fully achieve the rapid dissemination of information to both public health as well as the clinical care community and the public.


The vision for the Public Health Information Network is a broad one, as I indicated cross multiple functions. It includes the areas of detection and monitoring, this is inclusive of activities early on in bioterrorism detection, in the areas of syndromic surveillance and early indicators of possible outbreaks. It includes the more routine surveillance and reporting operations of the National Electronic Disease Surveillance System, as well as the analysis of these data and the conversion of these data information at all levels of public health to make good decision.


The Public Health Information Network includes information resources and knowledge management, the ability to focus these information and present them in ways that support decision making, as well as alerting and communication and including the broad communities that I identified before, and the large and still developing information systems needs of response, having identified an outbreak, having identified an attack, the coordination and management of prophylaxis, vaccination, and other response activities is an area that still needs attention and been relatively under attended to in information systems development.


We are then funding through these specifications. And last year over a billion dollars went out in a cooperative agreements, some through CDC, some through HRSA, and both of them had what were then called the IT functions and specifications, which identified the technical and data standards for this network attached to them, and the requirement exists that if these monies are used to support information technology that those information technology activities need to be done with those standards.


And then the final step on this, which we have just really started to pursue, is that of supporting conformance testing to ensure that the standards are indeed implemented and to be able to have methods for the evaluation of the implementation of the specifications to assure interoperability.


The types of things that this needs in terms of ongoing needs for Public Health Information Network indeed include additional work on standards identification and specification. With the number of activities that are going on at the national level we are eager to tag onto industry standards that are identified and do work in this public health domain for internal specification development that gets us to that level of specificity to do the work of this activity. We are also working on foundational elements for public health partners that support integrated interoperable systems. Since much of the funding for information technology that has historically gone into public health has been focused around disease categories or around specific initiatives there is a need to implement shared functions or components in public health participants around directors of individuals, around data exchange, around standardized data stores and the like. I mentioned the need to develop transitional software components, those needs are ongoing. And the need to support conformance testing and integration assurance.


The three broad thrusts for achieving the Public Health Information Network can be described in these categories. One, a technical systems architecture for how systems need to be constructed to be interoperable. Two, a sub-component of that, which relates to implementing a live network for the exchange of very specific data. And three, work on a shared data model and vocabularies for public health participants.


The area of security to ensure that these data are well protected and that practices for continuity of operations are ensured. And increasingly, the left side of the slide, areas around standards for content delivery around the identification of content, the tagging of content, information architecture, metadata about content that facilitates its delivery in a timely fashion to those who need it.


A large part of that obviously is speaking to the messages and the common vocabulary for the exchange of this information, and in this regard we have in public health have identified an industry based data model, vocabulary and messages that are derivative of industry standards in this regard, heavily relying on the clinical standards development activities and HL7 activities around the reference information model, as well as the identification of technical standards to ensure that that full stack of interchange is achievable among these different partners. Obviously we are also very interested in interchanging with the clinical care community, and are excited about the opportunities that the National Committee on Vital and Health Statistics is enabling in this regard, and the work of the Consolidated Health Informatics activities to work on industry standards and work on messages that can allow us to interface public health with the clinical care community.


Where do we stand in regard to achieving these goals? I mentioned previously that there was a great influx of funding for public health preparedness and response, over a billion dollars, $800 some odd million of that coming through a CDC cooperative agreement. At that time the IT functions and specifications that were derivative of some of the initiatives I indicated in my first slide, the work that had been done on the Health Alert Network, the work that had been done with public health partners on the National Electronic Disease Surveillance System, these IT functions and specifications have been attached to those monies and funding was done through them. Since then the CDC Information Council, which includes membership both CDC, ASTHO, and NACCHO, public health partner organizations, has approved the naming of those IT functions and specification as version one of the Public Health Information Network standards and specifications. We have as part of that activity also conducted an external review of those IT functions and specifications by the Garten(?) Group, that review is just finishing up, and the work of that review will be presented at the Public Health Information Network conference which is coming up in the early part of next month.


We are also concerned just from the process standpoint, we fully understand that none of us have been able to take the time to do the things the way we want to since September 11th, definitely all of our lives have been fast tracked in public health, and similarly the development and adoption of the PHIN standards have been fast tracked. But realistically there has been minimal state involvement in the identification and the selection of those standards and we believe is going to cause some problems for us down the road.


At the same time, and as all of you know oh so much better than I, there is a better technical capability to access health data, as technology improves the ability to access it and the ability to use that data at the individual level becomes better and better. And there is an increased need, in my view, for public health authorities to exchange data with other parties, and by other parties I mean both in the public sector and also in the private sector, and I will elaborate on that in a few moments. And in the context of all of that there is a heightened sensitivity to privacy of health information, not only under federal law but also under state law as well.


Licensure and certification. This is one that I would emphasize because sometimes it gets overlooked as one thinks about the public health system. Public health is responsible in many cases for licensure and certification of health facilities. In order to appropriately do that one needs to have access to individual health information, health information with respect to residence and patients in order to assure that care is properly being delivered, and that licensure and certification standards are being met. Early detection and intervention, vital records, and generally preventing or controlling disease, injury, or disability, all of these are public health functions and all of these require access to individual health information.


And let me just quickly talk about some of the aspects of the privacy rule that do allow for that flexibility. Covered entities are allowed to continue to report information into the public health system without individual authorization under a variety of different accommodations within the privacy rule. First, to the extent that it is mandated by state law, and there are some special bells and whistles in connection with certain types of reporting, but as a general proposition I think it is fair to say that if state law mandates that that information be reported into the public health system then it can be so and it can be so consistent with the HIPAA privacy rule without the need for individual authorization.


Health oversight activities. If state law allows access or reporting of individual health information to a health oversight body, which in many instances will include the public health system, then that reporting can occur consistent with the HIPAA privacy rule without the need for individual authorization.


Moving to health oversight, I would point that health oversight contains that same allowance when it talks about what constitutes a health oversight agency. It specifically indicates that a health oversight agency may not only be a governmental entity but also may be a third party with whom that governmental entity enters into an appropriate arrangement. And health oversight is broadly defined to include audits, investigations, inspections, and licensure of disciplinary actions.

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