I would like to see regulations that will protect patient confidentiality interests in this situation. In addition, I am concerned about the potential for violation of confidentiality through the sale of identifiable health information. As an ophthalmologist, organizations have offered to sell me lists of names and addresses of likely candidates for refractive surgery, cataract extraction, and laser surgery for diabetic retinopathy. A regulation prohibiting and providing prosecution for the sale of such information seems to be required. I am also concerned by the potential of health care information to be used to discriminate against individuals, without their knowledge or consent, when they apply for health care, life and other insurance, and in education and employment.
Regulations preventing such use are essential.
Another concern is that access log requirements might be written that would make the delivery of health care by teams unworkable. Team members often look at the paper health care record together. Having Federal regulations that establish reasonable minimum standards for health care information protection would be an enormous aid to health care delivery organizations. If we had such regulations, we would not have to spend resources to determine what protection is required and then justify the resources necessary to develop and implement it. We do not need to justify the resources that are required to implement Federal standards.