I will need to bring this up with the steering committee

Russ Waitman


On Oct 21, 2014, at 10:44 AM, Dan Connolly 
<dconno...@kumc.edu<mailto:dconno...@kumc.edu>> wrote:

I haven't read the whole thing, but I just noticed this (emphasis mine):
3.3 Comments on Protected Health Information (PHI)



The CDM will contain some of the 18 elements that define PHI under HIPAA, 
including encounter dates and date of birth. However, these dates will remain 
under the control of the institutions that already maintain PHI. To maximize 
analytic flexibility and allow for all types of analyses, complete and exact 
dates should be included in the CDM. Distributed analytic programs will use the 
date fields for analysis, but will generate results that contain the minimum 
necessary information to address the question. The results returned to the 
requester will typically be aggregated and not include any PHI. Queries that 
generate results sets with PHI (eg, a person-level analysis under an IRB, with 
all necessary data agreements in place) will be clearly flagged as such and 
will only be distributed with the appropriate approvals clearly documented. As 
with all distributed queries, sites should review all results before release.

Two options I can see:

  *   add original-date restoration to our CDM building plans and scripts 
(#145<https://informatics.gpcnetwork.org/trac/Project/ticket/145>)
  *   re-iterate that this wasn't in the GPC proposal nor our approach to  
de-identify/re-identify patient data 
(#73<https://informatics.gpcnetwork.org/trac/Project/ticket/73>) and suggest 
that they change the CDM spec


--
Dan

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