Health Breach Notification Rulemaking #541358-00103

Submission Number:
Stephen Lieber
Healthcare Information and Management Systems Society
Initiative Name:
Health Breach Notification Rulemaking
June 1, 2009 The Honorable Jon Leibowitz Federal Trade Commission 600 Pennsylvania, Avenue, N.W. Washington, D.C. 20580 Dear Chairman Leibowitz, On behalf of the Board of Directors and members of the Healthcare Information and Management Systems Society (HIMSS), I am pleased to submit written comments (attached) on the Federal Trade Commission’s request for information, entitled, “Health Breach Notification Rulemaking, Project No. R911002.” HIMSS is the healthcare industry’s membership organization exclusively focused on providing leadership for the optimal use of healthcare information technology and management systems for the betterment of healthcare. HIMSS represents more than 22,000 individual, 350 corporate members, and 46 chapters nationwide. HIMSS seeks to shape healthcare public policy and industry practices through its educational, professional development, and advocacy initiatives designed to promote information and management systems’ contribution to quality patient care. As in past responses HIMSS has leveraged the subject matter expertise of our members to ensure that our response reflects the broadest level of industry experience. For the response on the guidance document, members of our Personal Health Records and Privacy and Security Steering Committees played important roles in encouraging comments from their industry colleagues. These cross-industry viewpoints ensure that HIMSS fulfills its requirement to offer a coordinated voice to the national discussion on these important healthcare issues. With respect to notification to the FTC, the American Recovery and Reinvestment Act creates many challenges and opportunities for the federal government and the healthcare community. We appreciate your effort to engage healthcare stakeholders in reviewing the guidance document, and look forward to future dialogue with HHS on this important issue. Our staff points of contact are Mr. Thomas M. Leary ( ), Sr. Director for Federal Affairs, and Ms. Mary Griskewicz ( ), Sr. Director for Ambulatory Information Systems. Sincerely, H. Stephen Lieber, CAE HIMSS President/CEO