Jan 10, 2022

Is This A Good Idea Or Just Too Intrusive?

This is a Request for Information (RFI). This RFI is for informational and planning purposes only and shall not be construed as a solicitation or as an obligation or commitment by the Government.  ...

The Social Security Administration (SSA) is conducting market research to identify potential vendors capable of providing record locator services to help identify interactions between a disability claimant and the healthcare system (e.g., physician visits, hospitalizations). ...

During the application process [for Social Security disability benefits], claimants may spend a great deal of time gathering information and trying to remember dates of medical treatment and provider details.  The process relies solely on claimant recall for the names and addresses of medical providers and dates of treatment.  As such, the body of medical evidence assembled for evaluation may be incomplete and omit information that could be critical in making an accurate determination of disability. ...

Technical Requirements:

  • The service shall support the ability to accurately identify a patient based on key demographic information supplied by SSA, such as patient name, date of birth, gender, address, and Social Security number.
  • The service shall support the ability to provide an encounter/treatment history within a specified timeframe for an identified patient, which consists of a list of treating facilities/providers, including address information, Medical Record Number (MRN), date of encounter, and conditions that were treated or evaluated.
  • The service shall support the ability to provide a list of active medications within a specified timeframe for an identified patient, including the prescription date along with the prescribing doctor, facility, and address.
  • The service shall support the ability to identify the electronic address of a specific patient’s electronic medical record based on key demographic information supplied by SSA.  ...
  • The service shall support the ability to notify SSA when specific patients, identified by key demographic information supplied by SSA, have had medical encounters, and provide information about the treating provider or facility, the date of the encounter, and the electronic location of where the associated electronic medical record could be found.

      I really want for Social Security to have a complete medical record on my clients. I try hard to figure out who they've seen and to help complete the record set that Social Security has. Contrary to what some would think, the problem isn't claimants trying to conceal medical sources they've seen. I don't think that's what this RFI is even about. The problem is that medical histories get complicated and claimants forget. Still, this RFI seems a bit creepy to me. Do we really want the government to have the power to troll across all medical records to find every last bit of records on an individual? To be able to construct a list of prescribed medications at any given moment? Would you want the government having this kind of power to gather your medical records?

15 comments:

Anonymous said...

As long as the claimant still must give their consent, I don't see the harm.

Anonymous said...

I am well- (or over-) educated and likely of at least average intelligence with no known mental impairments. I had cause to seek treatment in an urgent care clinic last week. I could not tell you the name of the ARNP who treated me. I think as long as the claimant retains control over the process, preferably beyond a simple blanket 827 release, many would benefit from this data mining.

Anonymous said...

DDS literally kicks a claim back to the FO if they don't give their consent. You're applying for a disability benefit, not a job. Finding further information of medical treatment is a boon to an applicant, not a curse.

The only fears this would raise is in the minds of those who have an overly simplistic view of Uncle Sam having one massive database that every single government employee can call up instantly on demand.

Now if it became a prerequisite for federal job applications or clearance investigations, yeah. Time to raise the alarm.

Anonymous said...

I agree with the first post. As long as convent is given, there shouldn’t be an issue. Seems like it could help a lot of the more needy people filing whose record keeping generally hurts them more than helps them.

Anonymous said...

Using a record location service like Surescripts, payer claims data, or even HIEs would be helpful to identify where and when a patient had an encounter using not only a claimant's consent but their further approval of those findings. Not every encounter is related to disability. I see that self-pay would be a shortcoming here as not part of the some of the directory services. This could help in producing a more complete and accurate list of treating sources. This could be used during an online application to help the patient select from a list (add info not found), with a claims representative (when the FOs open) to complete the application faster. Help to identify additional sources and encounters when filing an appeal. I could even see why authorized representatives using a service with a patient's consent to understand a more complete picture of the claimant.

Anonymous said...

Social Security seems to be pursuing two threads from their recent proposals. They are after software that will cull through huge volumes of medical records and pull out the relevant bits. They are also trying to get software that will go through all online available sources, with permission of course, to obtain all medical records.

I have begun to see medical records identified at HIT showing up in files. The files from those sources are huge. i.e hospital records of over a thousand pages.

I have no real problem with the SSA getting records including records people likely forgot about or son't know how to get themselves. Reports from specialists that consulted in hospitals for example that the person doesn't even know. But once they get those records, the size of the files will increase considerably. ALJs are compiling now about the size of files. I can't even imagine what they will think if "everything" gets included. Think every source being like the VA.

If the SSA can manage to find a way to pull out what is relevant, then more power to them. I just have a lot of doubts as to how this will all come together back in the real world.

Anonymous said...

this is an insurance program with a trust fund. SSA should be doing all it can to ensure beneficiaries are proper. More information is better.

Anonymous said...

12:28, you would only need to provide the info about the Urgent Care Clinic, not a particular provider within that clinic.

randomname said...

The government in the UK has all their people's records doesn't seem to be a problem.

Anonymous said...

@1:41 Large records can be problematic. the analysis part of MEGAHIT uses business rules to quickly identify information within a HIT record and point an examiner to it that could support a disability claim. IMAGEN takes this a seat further by extracting text from scanned documents, run the text through a Natural Language Processing (NLP) engine identifying clinical concepts, sections within the record and timeframes. This information is passed onto a Machine Learning (ML) process that identifies matching patterns that support a disability claim. These tools are rolling out to widespread production. This helps examiners rapidly identify information that supports a disability claim.

Anonymous said...

I can imagine a company like Palantir, with a decade's experience at NSA and DOD trolling datastores looking for terrorists and whatever else, seeing this kind of thing as relatively simple, with the kind and quality of the databases to be mined being the limiting factor.

There is consent and then there is "consent". HIPAA protected records, wondering just how one can get value from just metatdata? Because trolling for records beyond metatdata would likely be HIPAA violation due to possible exposure of not related data (i.e. family member who is on DIB applicant's health insurance) and similar name issues etc.

On the one hand, if your claim lives and dies by the existence of accurate information, SSA would be helping all applicants by getting better data and getting accurate decisions. On the other hand, you may view that responsibility as the responsibility of the applicant, not the agency and let them sink or swim (i.e., today's situation in essence).

I'd love to see this go into a pilot stage, but would want HHS involved in setting boundaries on all the odds and ends related to HIPAA protected data that will be uncovered, and how to treat the unrelated data and disposal etc.

Anonymous said...

We just unfolded a giant telescope in space and sent it a million miles away from Earth to peer into the deep vastness of the Universe using technology that is over two decades old. I think there is a place for modern tech in SSA if we can get the people out of the way that cant work their smart phones and TV.

Tim said...

Call me a cynic if you want to...I don't view ANYTHING SSA does as a way to "help" the claimant. Could it? In some cases, yes. But, I really doubt that is WHY they are doing this. Much more likely (in SSA's Braintrust) a way to find records that can allow them to deny someone.

Anonymous said...

So where are all the neigh sayers when Health IT and interoperability was started a decade ago. Sharing of your medical record electronically has been going on for a while. Yes, under HIPAA, mostly for treatment, payment and operational purposes but SSA has been using the patient's authorization (SSA-827) in this automated manner. The HIT volume is still relatively low (13-14%) compared to mail, fax, and ERE, but growing. What holds it back for the moment is the need for a complete medical record including restricted info. Doctors are asking for the same rich information nowadays. The use of a record location service only assists in completing the application faster, identifying a more complete list of treating sources reducing discovery and follow-ups and locating both electronic\paper medical records. Tools like these have been in use across the federal government (CMS, CDC, DoD, VA, IHS, SSA as a few examples) for a while.

Anonymous said...

@9:18 SSA use of Health and Interoperability has benefited the claimant by getting medical records sooner, identifying supporting clinical information and alerting examiners to this information. When this occurs, the agency has seen determinations drop from 90-110 days (initial claims) to 24-48 hours. This is to help get benefits to those that deserve them sooner. Better use of your and my tax dollars. We need more of these type of capabilities to better serve those in their time of need. I really hope that SSA executives put more funding into these efforts rather than limiting the budget as they have been for years.

Technologies such as Health IT are still growing. This do not happen overnight. Electronic banking, cell phones and the internet did not happen overnight, but took decades to become widely adopted.