Guest post by Lucy Doyle, Ph.D., vice president, data protection, information security and risk management, McKesson, and Karen Smith, J.D.,CHC, senior director, privacy and data protection, McKesson.
Today there are opportunities and initiatives to use big data to improve patient care, reduce costs and optimize performance, but there are challenges that must be met. Providers still have disparate systems, non-standard data, interoperability issues and legacy data silos, as well as the implementation of newer technologies. High data quality is critical, especially since the information may be used to support healthcare operations and patient care. The integration of privacy and security controls to support safe data handling practices is paramount.
Meeting these challenges will require continued implementation of data standards, processes, and policies across the industry. Data protection and accurate applications of de-identification methods are needed.
Empowering Data Through Proper De-Identification
Healthcare privacy and security professionals field requests to use patient data for a variety of use cases, including research, marketing, outcomes analysis and analytics for industry stakeholders. The HIPAA Privacy Rule established standards to protect individuals’ individually identifiable health information by requiring safeguards to shield the information and by setting limits and conditions on the uses and disclosures that may be made. It also provided two methods to de-identify data, providing a means to free valuable de-identified patient level information for a variety of important uses.
Depending on the methodology used and how it is applied, de-identification enables quality data that is highly useable, making it a valuable asset to the organization. One of the HIPAA- approved methods to de-identify data is the Safe Harbor Method. This method requires removal of 18 specified identifiers, protected health information, related to the individual or their relatives, employers or household members. The 18th element requires removal of any other unique characteristic or code that could lead to identifying an individual who is the subject of the information. To determine that the Safe Harbor criteria has been met, while appearing to be fairly straightforward and to be done properly, the process requires a thorough understanding of how to address certain components, which can be quite complex.
The second de-identification method is the expert method. This involves using a highly skilled specialist who utilizes statistical and scientific principles and methods to determine the risk of re-identification in rendering information not individually identifiable.
We need to encourage and support educational initiatives within our industry so more individuals become proficient in these complex techniques. At McKesson, we are educating our business units so employees can better understand and embrace de-identification and the value it can provide. This training gives them a basic understanding of how to identify and manage risks as well as how to ensure they are getting quality content.
Embracing Social Media and New and Improved Technologies
One of the challenges we face today in de-identifying data is adapting our mindset and methodologies to incorporate new emerging technologies and the adoption of social media. It is crucial to understand how the released data could potentially be exposed by being combined with other available data. New standards are needed.
While de-identifying data can be challenging and complex, the task is made easier when we remember and adhere to our core directive to safeguard data. With this in mind incorporating new technologies is part of an ongoing process of review.
When done properly, de-identification enables high quality, usable data, particularly when the expert method is used. De-identification should not be viewed as an obstacle to data usage, but rather as a powerful enabler that opens the door to a wealth of valuable information.