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Looking at health information technology (HIT) through the "donut hole"! |
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January 29, 2008 - In my capacity as a volunteer data entry operator, I received an email forwarded by the Director of the Senior Outreach Program from the Nutrition Specialist mandating that effective March 1, 2008, the Social Assistance Management System (SAMS) be used to track client information from the new "Nutrition Screening Form" that all programs had been required to implement by January 1, 2008. Data entry instructions were located at: http://dhfsbadr.org/docs/sams/nutritioncheck/. That Website appeared to me to be an official site of Department of Health and Family Services (DHFS) Bureau of Aging and Developmental Resources (BADR), but as I was to find out, was actually a site privately owned by the SAMS' system administrator. The intended use of the tracking system was to show nutrition "outcomes" at both the local and state levels. January 31, 2008 - I sent an email to the Nutrition Specialist and SAMS system administrator telling of the visceral reaction I experienced that the SAMS' tracking process violated my rights to privacy. I attached a DHFS form that followed proper protocol as to specifying the law underlying the form and the consequences that would follow if the form was not completed. February 18, 2008 - While working as a volunteer data entry operator, I
inadvertently gained access and control of the Web programs and host computers
at Harmony Inc.’s data centers. Security
holes had already been identified by the current systems administrator and–as I
recently found–by a systems installer, as recorded in his service order notes,
dated 3/24/2004. In a list of the top
ten security flaws in Web programs, the security hole I inadvertently found is described
as, “Broken access control – in which
restrictions on authorized users are not enforced.” Cyber thieves are well aware of semantic
technologies and crawl the Web looking for such vulnerabilities.
The following letters and documents will form the basis for
a case study (which I hope to complete by January 2010) concerning the failure
of the federal Administration on Aging (AoA) to take the lead in defining a
minimum data set (MDS) and in setting security requirements for Older American
Act Programs. AoA’s failure has resulted
in Letter to: Rea Holmes, Executive Assistant, DHFS and Tonya Harmon, CEO, Harmony Inc. BADR's Privacy Statement - 071508 Attachments: 1-ScreenShotsRemoteAccess.pdf 2-HolmesHarmonLetters.pdf 3-FairfaxCountyAudit2006.pdf 4-OpenRecordsRequest.pdf 5-Nutrition Committee Minutes.pdf 6-BADR’s Contract for the Social Assistance Management System (SAMS).pdf 7-Minutes of DHFS Data Stewardship Council.pdf 8-Report to HIPAA Metadata Registry Coalition.pdf 9- Comments to Area Agency on Aging Board - Legislative Committee – 11/12/2008 10-Comments to Health and Human Needs Committee – 11/18/2008 Attachment: HHN111808 Minutes of 11/18/2008 Meeting 11-Comments to HHN, HSB, LTS and AAA Boards – 12/02/2008 Attachment: Combined Boards 120208 12-Comments to Area Agency on Aging Board - Legislative Committee – 12/17/2008 Following are reference documents: Privacy Assessment Requested by Governor Doyle Letter from Governor Doyle to Secretary Michael Morgan - April 15, 2008 State of Wisconsin Privacy Assessment - April 14, 2008 By: Metavante Milwaukee, WI Privacy Laws in Legislative Reference Bureau Brief - July 2008
State Aging Information Systems Management Study – December 2006 NAPIS State Reporting Tool Training Manual
Wisconsin Site Visit
Report – August 2007 See page 13 for
impressions of http://www.hhs.gov/healthit/resources/reports.html Enhancing Protections for Uses of Health Data – A Stewardship Framework -Summary for Policy Makers- April 2008 Secretary Leavitt Announces New Principles Draft Model Personal Health Record (PHR) Privacy Notice & Facts-At-A-Glance
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Last modified: 01/01/11 |