I have
also analyzed this information and we use the real life database for the testing
and the training. I came to this conclusion because:
it it
part of our operations;
we are
training employees who would have access to the info in their
jobs;
all of
our employees have signed confidentiality agreements and we have a great
privacy/confidentiality policy in place;
the
employees are all reminded about their signed agreements and that on-the-job
training is included;
we can
audit the training system to look for breaches, this is part of the testing;
and
we are
including this scenario in our policy.
I fall
back on that if the employees cannot be trusted during training, they should not
be employees, period.
Andrea,
Admittedly my focus is most likely more narrow than
yours...
LTC
Medicare and Medicaid claim's primarily; the
intermediaries
I
have dealt with so far, do not want blinded data. They want
the
"real thing" so that a full testing through their adjudication
systems may take place.
In
all my years of doing EDI for the LTC market, I have only run
into
one Intermediary that wanted to use blinded data...
and they
supplied the test claim data that you had to
use.
BCY
Brian C. Young
Accu-Med Services Inc.
An OmniCare
Company
Milford, OH 45150
513.831.1207
I agree that this issue also pertains to test data, which is a big
issue for me at the moment. We are also considering scrambling the
data, and I would like to be copied on any additional
suggestions.
We too are
looking at this issue. We are a health plan and currently use live data
for training purposes. The live data is stored in a test region of our
system and is periodically updated. One solution we are
looking at is to scramble the demographic data such as name,
ssn, dependent names, address, etc. before it is loaded to the test
region. Although, this does not meet the true definition of
de-identification, we feel that it may be a reasonable way to safeguard
the PHI. Keep in mind, access to our test region is
tightly controlled by user. Only those users who have a need to
know have access to the test data. Individuals being trained, using
the modified live data, are the same staff that will have access to this
information for the purpose of performing the functions of their
jobs. In addition, the test data is not shared with any outside
entities. I sure would be interested in hearing how others are
addressing this question.
Phyllis Line
HEREIU Welfare
Fund
HIPAA Privacy
Officer
(630)236-5114
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.
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.
|
