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Elizabeth M. Whitehorn, Director

Data Use Boundaries

HFS is proud to support the many innovative and complex analyses that our partners are completing in support of the planning of their Care Coordination Entities, Managed Care Community Networks and Medicare-Medicaid Alignment Initiative demonstration projects. We look forward to reviewing these analyses in your completed care coordination proposals.

As our data users utilize the extra time before the solicitation's new deadline, we'd like to clarify the data's scope of use. We recognize that our data has many potential purposes, and that data analysis of a wide range of issues may be pertinent to your organizations' goals. However, our Data Use Agreement stipulates that the data you've pulled may only be used for the development of a Care Coordination Innovations Project proposal. Any other uses – such as analyses for public reports, other business arrangements, projects internal to your organization, or mere curiosity – are prohibited. This limitation on use is intended to ensure compliance with HIPAA privacy regulations. Specifics, including grounds for data use termination, are described in the Data Use Agreement (Sections 4c-d and 5a-d). HFS will impel any organization violating the Data Use Agreement to destroy its data, in compliance with Section 4g of the DUA.

We are proud that the large majority of organizations appear to be using data in ways consistent with HIPAA compliance and the best interests of HFS, your organization, and the patients we will serve. We urge all organizations to maintain very high standards with regard to the appropriate use of this limited data set. Please consult us if you have any specific questions as to appropriate data uses.