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AHIMA Day on the Hill

On March 26, we had the opportunity to lobby our Congressional leaders in Washington, D.C. for some important initiatives.

We had two asks of Congress: Patient Matching and Modernizing HIPAA.

We requested that congress omit the 1999 language in the fiscal year 2020 appropriations legislation (government budget) to empower HHS to work with industry to advance a nationwide patient matching strategy. AHIMA has been asking for this language to be removed since 2001!

The modernizing HIPAA request has three components, aligning HIPAA and Certified Health IT on the Designated Record Set, extend HIPAA individual right of access to Non-Covered Entities, and encourage note sharing in real-time via MIPS.
  1. Inconsistencies in concepts and terminologies have hampered individuals’ right of access, and the broad definition of the DRS has made it difficult to operationalize in practice. AMIA and AHIMA recommend that policymakers take concerted action to align HIPAA’s right of access with Health IT certification, so individuals can view, download, or transmit this information electronically to a third party and access the information via application programming interfaces (APIs).

    Specifically, we recommend lawmakers revise the definition of the DRS and require certified Health IT to provide the amended DRS to patients electronically while maintaining computability. Further, regulators should develop guidance and request regular feedback from stakeholders on continued barriers to delivering this right under HIPAA. This revision would provide greater clarity and predictability of what constitutes the DRS to both providers and patients.
  2. There is no standard definition for HIPAA NCEs, and there exists wide discrepancies in how such entities produce, manage, and share personal health data.

    AMIA and AHIMA recommend that lawmakers develop or direct HHS to define HIPAA NCEs in law and at minimum extend HIPAA’s right of access to such NCEs. The goal of such a policy is to create a uniform data access policy for individuals using technology developed by an entity that produces and/or manages their individually identifiable health information, regardless of commercial or legal status. 

    Congress can draw from important work developed by HHS to distill a standard definition for HIPAA NCEs.2,6 In addition, ONC has developed a model privacy notice designed to help health technology developers provide clear notice to consumers about what happens to their digital health data when the consumer uses a developer’s product.

    As the lines between consumer and medical information systems continue to blur, Congress must ensure that rights endowed by HIPAA to patients inside the hospital and within the physician’s office also apply beyond the clinical setting.
  3. The Medicare and Medicaid Promoting Interoperability Programs and the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program both require eligible hospitals, critical access hospitals (CAH), and eligible clinicians to offer patients access to their health information via a portal or application programming interfaces (APIs). However, additional opportunities exist to meaningfully enhance patient access to their health information through such efforts as OpenNotes. One compelling avenue to incentivize such note sharing would be through the MIPS Improvement Activity Performance Category, which provides clinicians an opportunity to engage in a range of activities meant to improve the safety, efficiency, and effectiveness of patient care. Additionally, innovative payment models developed by the Centers for Medicare and Medicaid Services’ Innovation Center, including the Comprehensive Primary Care (CPC) and CPC Plus initiatives, could incentivize note sharing as part of their payment requirements.
AHIMA and AMIA recommend Congress, using its oversight authority, promote efforts such as OpenNotes through Medicare and Medicaid payment programs, including the Promoting Interoperability Programs, the MIPS Improvement Activity Performance Category, and other innovative payment models, so that the practice of note sharing benefits patients nationwide.

PHIMA Scholarship Raffle

The PHIMA Fund Raising Committee is accepting donations for the Annual Conference Raffle. If you have a new item or gift certificate to donate, please contact Linda McLinden (, Lisa Hershey ( or Lesia Peck ( Some suggestions include jewelry, handbags, office accessories, scarves, tech items, wine accessories, gift certificates. All monies raised through the Raffle support the PHIMA Student Scholarship fund.

IG Corner

AHIMA initiatives supported by IG – Patient Engagement
  • Apps – monitoring blood pressure, heart rate, respiratory rate
  • Telemedicine

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