Keep in mind that NCVHS was tasked by Congress to provide status on the implementaion of HIPAA. I think this sounds more like a status report on HIPAA rather than any other reason. David Sweigert, M.S., CISSP State IT Security Policy Officer Office of Statewide IT Policy State of Ohio http://www.ohio.gov/itp "Giesecke, Steve" <SteveGiesecke@SierraS To: "'Grant, Peter'" <[EMAIL PROTECTED]>, ystems.com> "'[EMAIL PROTECTED]'" <[EMAIL PROTECTED]> cc: 06/26/2002 12:28 PM Subject: RE: OCR's Report to NCVHS Regarding the Status of the Privacy Rul e Thanks for the update. I'm curious why the Office of Civil Rights (OCR) would be reporting on the status of, as well as be "working diligently on issuing," the Privacy Rule modifications when they are presumably in an enforcement role with respect to the rule. I would have thought that HHS wouldn't turn over the modification/publishing responsibilities until the changes were final..... Anyone have a clarifying perspective on the OCR's role in the Privacy Rule modifications? Does the explanation below represent an expansion of OCR's preexisting role with respect to the rules? Thanks, Steve Giesecke, MBA, FACHE Sierra Systems -----Original Message----- From: Grant, Peter [mailto:[EMAIL PROTECTED]] Sent: Wednesday, June 26, 2002 7:34 AM To: '[EMAIL PROTECTED]' Subject: OCR's Report to NCVHS Regarding the Status of the Privacy Rule The National Committee for Vital Health Statistics (NCVHS) is currently meeting. You can hear this meeting live vie audio streaming at http://www.va.gov/audiohhs.htm, OCR is reporting regarding the status of the privacy rule NPRM. As I understand it, OCR just reported that: 1. There have been over 11,000 comments, 9,000 of which address the issue of consent. 2. OCR is working diligently to issue the final rule with the full support of the Secretary of HHS, OMB and the White House. 3. The goal is to publish the rule so that the privacy rule that goes into effect on April 14, 2003 reflects the December 2000 rule as it may be changed by any final rule changes arising from this NPRM process. The problem that it appears that OCR wishes to avoid it a situation where the December 2000 rule goes into effect on April 14, 2003 for a period of only several months, and then the amended rule goes into effect, creating an awkward interim period for enforcement and compliance. 4. There then took place a brief and somewhat inconclusive discussion of the date by which the privacy rule must be published in order to achieve this goal. I will not attempt to characterize this discussion. Presumably this will be a matter for substantial list serve discussion. Two final thoughts: 1. I do not here desire to speak for the government, but rather to share only generally the nature of the NCVHS discussion. 2. The ability to listen in to NCVHS live via streaming audio at http://www.va.gov/audiohhs.htm is great, but not perfect. The broadcast just crashed. I hope that it will be up shortly. Peter N. Grant, JD, Ph.D. Partner and Co chair, Health Law Group Davis Wright Tremaine Co chair, National HIPAA Summit Instructor, Schools of Public Health Harvard University and University of California at Berkeley [EMAIL PROTECTED] 206-628-7668 The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited. The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited. The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited.
