PUBLIC COMMENT‐2022‐24 HS Chronic Disease Reporting
COMMENTOR AND ORGANIZATION
PUBLIC HEARING OR
WRITTEN
RULE NUMBER
COMMENT
DHHS RESPONSE
Jerome Finkel, Senior Vice President and Chief Written
General Comment The Michigan Department of Health and Human Services
There are no additional costs anticipated for compliance with the rules if a healthcare facility is
Primary Health Officer Henry Ford Health
(Department) indicates that the costs for the implementation of these reporting the required information electronically through a health information exchange.
rules will be minimal for healthcare providers. We feel this may be an There should be no changes required of the facility's IT system to comply with the reporting
misestimation of the burden that these reporting requirements will requirements. For businesses that are required to report the required information manually, it
put on providers, particularly as it is not clear the quantity of chronic is estimated that somewhere between 1 and 2 hours of staff time per month will be necessary
disease types that providers may be expected to report once the
board and the Department determine which diseases will be
to gather and report the required information to MDHHS. This estimation may be more or less
depending on the number of patients with a given condition that the site serves. MDHHS staff
reportable. Disease reporting, even if it is through electronic health will work with facilites to ensure data quality and to assist in minimiizng time needed for
reporting, still requires staff time to ensure that information is being reporting and training of new staff.
properly documented and submitted. This staff time also includes
training for employees on new requirements to ensure they are
reporting compliantly. It also requires a build out on the health
information technology (HIT) side, which comes with infrastructure
and staff time costs. Health information technology is not always
simple to reconfigure and interconnect. The costs in staff time and
HIT infrastructure will be more than “minimal,” and these costs will
be ongoing as we will need to make new technology and training
adjustments each time there is a new chronic disease added to the
list.
Jerome Finkel, Senior Vice President and Chief Written
Primary Health Officer Henry Ford Health
General Comment Henry Ford Health also believes that the implementation of this
chronic disease registry—while well intentioned—may create more
concerns around patient privacy. There is a clear reason for providers
to report communicable diseases to their local public health
The proposed rules will improve chronic disease surveillance capacity and the data
collected under this ruleset will inform evidence‐based practices that reduce health
disparities within Michigan. Public health has a duty to address the chronic disease
burden in Michigan, which continues to be the leading cause of death and disability.
While most chronic diseases are not the result of a pathogenic community exposure,
they are determined by community influences and environmental determinants of
health that can exacerbate individual risk factors or behaviors. The availability of
timely and detailed clinical data will benefit public health agencies, local governments,
healthcare providers, and community‐based organizations through improved tailoring
of programs and services provided to the communities they serve.
department, as is required by the Michigan Public Health Code.
Communicable diseases have a clearly identifiable cause (a pathogen)
and as evidenced by the name, the potential to spread to others in
the community. This reasoning is not as clear for chronic diseases,
which can be caused by multiple factors over a patients’ lifetime and
are not likely to spread from person to person. Providers would now
be required to report private information about their patients,
without a clear public health justification. This issue is exacerbated by
the fact that the required reporting information in the proposed rules
exceeds the required information for communicable disease
MDHHS is committed to maintaining patient privacy and is in compliance with HIPAA
regulations. MDHHS staff will only have access to the minimum information necessary
to complete their jobs. The data collected under the proposed rules is protected by
reporting or syndromic surveillance, which do not require a patient’s system security and role defined access. Access to the information will be closely
social security number; medication list; or narrative accounting of the
patient’s symptoms, diagnostic tests, and clinical outcomes. Henry
Ford Health is committed to data security for its patients, and we
want patients to know that their conversations with their healthcare
provider and diagnosis and treatment plans are private. We foresee
difficulty explaining to patients why and how their private
monitored and users of the data will continue to be bound by confidentiality rules.
Collection of social security number under the reporting requirements is specific for
the purpose of accurate patient matching and deduplication. The information
collected under the proposed rules is stored in way that will not allow users to access
or display social security number.
The reporting requirements may exceed those for communicable disease and
syndromic surveillance but this is due to differences in disease monitoring of chronic
conditions. To effectively monitor conditions that persist over time, information on
whether the condition is in control and the severity or progression of disease is
important and necessitates the reporting of prescribed medications or a narrative of
the patient's symptoms.
information was reported to the state for their hypertension, cancer,
or diabetes, when the overriding benefit to public health is not clear.
