A Survey of Law and Policy Governing Immunization Information Systems
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Transcript of A Survey of Law and Policy Governing Immunization Information Systems
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Daniel W. Martin, MSPHPublic Health Analyst
Presented to the Public Health Informatics ConferenceAtlanta, April 30, 2014
A Survey of Law and Policy A Survey of Law and Policy Governing Immunization Governing Immunization
Information SystemsInformation Systems
National Center for Immunization & Respiratory Diseases
Immunization Information Systems Support Branch
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What are Immunization Information Systems?
Confidential public health systems that:Collect & consolidate vaccine information from multiple providers & provide records/decision support to providers
So patients aren’t over- or under-immunized So all providers have a clear picture of a specific patient’s needs So providers know how well they’re serving their clientele, or where they need to
improveGenerate reminder/recall notifications
So patients aren’t lost to follow-up So more people are fully vaccinated
Assess vaccination coverage To ensure the population is properly protected To identify pockets of need
Manage Vaccine Inventory Dose-level accounting and eligibility Vaccine ordering and reporting
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Study Objective
To obtain information relating to legislation, regulations, rules, and policies (collectively referred to as “laws”) that enable, support, or constrain the ability of an IIS to receive or disclose immunization information for both children and adults and to assess trends with regard to these laws.
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Participants
Immunization Programs in:49 states (no IIS in New Hampshire)4 municipalities
New York City Philadelphia San Antonio, TX Washington, DC
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Methods
Westlaw search of state statutes Online survey
Feb-March 2012 Follow-up telephone interviews
Initial interviews March-Apr 2012 Validation of reclassified responses Feb 2013
Historic data for trend assessment: Horlick et al., conducted in 2000 *
* Horlick GA, Beeler SF, Linkins RW. A review of state legislation related to immunization registries. Am J Prev Med. 2001;20(3):208-213.
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Legal Basis for IIS Operation
Laws specifically authorizing an IIS Laws addressing the sharing of
immunization information From one provider to another With or through public health Does not actually describe an IIS
Laws addressing sharing of health information Public health may be referenced, but not specifically
immunization-centric General public health authority
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Legal Basis for IIS Operation, 2012
Chicago
Houston
New York
Washington
San Antonio
Philadelphia
Authorization Type (children's data)
Law specifically authorizing IIS
Law addressing sharing of immunization information
Law addressing sharing of health information
Authorization derived from general public health authority
No IIS
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Whose Immunizations?
51/53 IIS are permitted to collect immunization data on clients of all ages Connecticut & Rhode Island are only exceptions
Mandate to report varies Consent requirements vary 46/53 obtain birth reports from Vital
Records or birthing hospital
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Chicago
Houston
New York
Washington
San Antonio
Philadelphia
Mandate
Mandate has no age restrictions
Childhood/adolescent/young adult
Young childhood
No Mandate
No IIS
IIS Reporting Mandate
Washington
Mandate
No Mandate
Mandate
2000
2012
•Mandates differ as to who must report
•Also differ as to whose data are reportable
•Enforcement variable
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IIS Consent Requirements (pediatric)
2000
2012
•Trend toward opt-out
•How opt-out or non-consent are handled is variable
•A few states more restrictive for adult records
Chicago
Houston
New York
Washington
San Antonio
Philadelphia
Consent to include children's data
Mandatory, with no right to opt out
Mandatory, with right to opt out
Implicit consent with Opt Out
Explicit consent
No IISWashington
Consent
Implicit consent with no right to opt out
Implicit consent with opt out
Explicit consent
Consent not yet addressed
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Interaction with Health Information Exchanges (HIEs)
Nearly everyone (50/53) are considering exchanging immunization data through an HIE
Only 36/53 currently have authority to do so Consent laws may present barriers to exchange
If HIE is considered a 3rd party If HIE and IIS consent differ (e.g. opt-in HIE and opt-out IIS) Between jurisdictions (states or cities) with different consent
laws
More work is needed to examine policy implications of data exchange between systems
or jurisdictions
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Conclusions
Increases in IIS authorization and reporting mandates are positive trends
Shift from opt-in to opt-out may help with IIS participation rates
Standardization of policies (where possible) should facilitate information exchange
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Limitations …
The data in this report were gathered in 2012. The legal landscape is shifting rapidly and the data presented here may not represent the most current state of IIS policy.
All data are based upon self-reports by immunization programs
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Acknowledgements/Disclaimer
Study co-authors: Elaine Lowery, JD, MSPH * Bill Brand, MPH * Rebecca Gold, JD ** Gail Horlick, MSW, JD **
* Public Health Informatics Institute, Decatur, GA** CDC
Managers and staff of IIS and Immunization Programs
Data gathering and analysis were conducted by the Public Health Informatics Institute, Decatur, Georgia, under cooperative agreement no. HM08-080502CONT12 from the Centers for Disease Control and Prevention.
The findings and conclusions in this report are those of the authors and do notnecessarily represent the views of the Centers for Disease Control and Prevention.
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Peer-reviewed paper: Journal of Public Health Management & Practice http://journals.lww.com/jphmp/Abstract/publishahead/Immuniz
ation_Information_Systems___A_Decade_of.99861.aspx
Line-listed data is linked from this article
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For more information please contact Centers for Disease Control and PreventionImmunization Information Systems Support Branch
Dan Martin, Public Health [email protected] (404) 639-0476
Gary Urquhart, Branch [email protected] (404) 639-8277
Thank you!
National Center for Immunization & Respiratory Diseases
Immunization Information Systems Support Branch