Advocacy Activities

• As proposed HIPAA rules have been released, the Academy has submitted formal comments written by the Task Force on Medical Informatics (TFOMI). TFOMI will write the AAP comments on additional Notices of Proposed Rule Making as appropriate when they are released.

• Becky Levin-Goodman, and Todd Askew have spoken with various organizations to try to reach consensus on an approach to adolescent confidentiality issues. In September 2000, TFOMI Vice Chair Ed Gotlieb, MD, Committee on Adolescence Chair David Kaplan, MD, Becky, and Todd spoke with officials from the Department of Health and Human Services (HHS) by conference call about the AAP position on adolescent confidentiality and consent issues.

• TFOMI wrote the AAP letter of response to the first final HIPAA rule on transactions and code sets for submission to HHS on October 13, 2000.

• TFOMI will gather feedback on pediatricians’ experiences using the standard transactions and will contact HHS and Designated Standards Maintenance Organizations (DSMOs) to advocate for needed changes to the transactions.

• Becky worked with a coalition of provider associations, provider organizations, and HCFA representatives to review the implementation guides and code sets for the standard transactions and submit change requests to the DSMOs.

• TFOMI worked with the Practice Action Group and a number of other committees to put together an AAP response to the final privacy rule, which was submitted to HHS on February 14, 2001. HHS opened up the final privacy rule for a 30-day comment period, and the Academy submitted comments, in particular urging HHS not to modify the provisions of the rule ensuring adolescent confidentiality. On April 12, 2001, HHS Secretary Tommy Thompson issued a statement indicating that the privacy rule would become effective on April 14, 2001, but that the rule could be modified to allow parents access to their children’s medical records including information about mental health, substance abuse, and abortion. The Academy issued a press release and wrote Thompson a letter objecting to any potential changes in this regard. TFOMI is working with the Committee on Adolescence and other AAP entities to develop the message to deliver to HHS about the importance of protecting adolescent confidentiality, and the Academy isworking to collaborate with other medical societies on this effort.

• As additional final rules are released, TFOMI will respond to those as appropriate.

• The Academy submitted written testimony to the Workgroup on Electronic Data Interchange (WEDI) for its February 19-20, 2001 hearings on HIPAA implementation, concentrating on the issues of adolescent confidentiality and the burden of HIPAA Administrative Simplification for small physician practices.

Education/Compliance Activities

• The Section on Computers and Other Technologies has included information and updates on HIPAA in its Pediatric Office of the Future workshops at the Annual Meeting (and previously at the Spring Session) for several years.

• TFOMI members and staff have written a number of AAP News articles providing updates on HIPAA, beginning in November 1997. Articles will continue to be published to keep AAP members informed about HIPAA administrative simplification rules and how they affect pediatric practice.

• A Web site was begun on the Members Only Channel to provide pediatricians with basic information on HIPAA.

• A consultant will be hired to assist TFOMI in the development of compliance materials for the Web site. Some materials will likely be developed in cooperation with other office-based specialty societies and will be customized to meet pediatric-specific needs.

• TFOMI will be updating the online component of the manual Evaluating Practice Management Software for Pediatrics on a regular basis, and they will address information systems needs to achieve HIPAA compliance.

Some of the above activities may be undertaken in part through outside organizations such as the WEDI Strategic National Implementation Process (SNIP). SNIP is trying to coordinate a health care industry-wide approach to HIPAA education, implementation, and advocacy.