NRPM: Standards for Privacy of Individually Identifiable Health Information. iv. Disclosure to the Department of Veterans Affairs.


Upon completion of an individual's military service, the DOD routinely transfers that person's entire military service record, including protected health information, to the Department of Veterans Affairs so the file can be retrieved quickly if the individual or his/her dependents apply for veterans benefits. This practice was initiated in an effort to expedite veterans benefits eligibility determinations by ensuring timely access to complete, accurate information on the veteran's military service. Under the proposed rule, the transfer of these files would require individual authorization if protected health information is included. While this change could increase the time necessary for benefits processing in some cases, we believe the privacy interests outweigh the related administrative challenges. We invite comment on whether our assessment of costs and benefits is accurate. We also invite comment on alternative methods for ensuring privacy while expediting benefits processing.