There are a number of important topics related to HIPAA that are not addressed in our evaluation proposal. We do not propose efforts that we believe are duplicative of efforts that are underway. Thus, for example, we exclude evaluations of the generic small group insurance market reforms as discussed above.
A second example relates to efforts to inform consumers of their rights under HIPAA. This is an important implementation issue, however there is an extant project at Georgetown University to study consumer information and HIPAA. We believe HCFA(now known as CMS) needs to focus resources on questions that are not being addressed already.
Similarly, we do not propose developing and monitoring indicator measures when we are aware of other efforts that are underway. For example, Deborah Chollet and her colleagues have recently undertaken considerable effort to measure the structure of the group and individual insurance markets in selected states. While the effects of HIPAA on this structure are of interest, the development of reliable measures of structure entails considerable investment and we do not believe HCFA(now known as CMS) should devote resources to duplicate the ongoing work of Chollet and others.
Our evaluation proposal also is limited to the implementation and effects of Title I of HIPAA. We do not address other titles of the act which provide for specific tax incentives, programs to prevent health care fraud and abuse, a demonstration of Medical Savings Accounts, specific benefit mandates, and administrative simplification because these issues are beyond the scope of this contract.