Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. C. How the Health Plan Community Can Use this Report to Advance the Privacy-Sensitive Collection of Minimum Necessary Information

01/17/2003

The gulf between the APA’s minimum necessary guidelines and typical MCO information requests is clearly wide.  Although the MCO representatives we spoke with do not believe the information set out in the APA guidelines will allow them to manage care effectively, the health plan trade associations had not focused on articulating a response to the guidelines at the time of our study.  It may be that these organizations do not believe they need to attend to this issue.  If they view the patients’ general consent as a sound legal basis for MCOs to continue requesting information as they now do, then the trade associations may see little reason to be concerned with providers’ views of what is minimally necessary.  However, these organizations may not have focused on this issue simply because of other priorities.  In that case, the information in this report on the large gap between the APA’s guidelines and current MCO practice may draw their attention to the issue.  Also, given the public backlash toward managed care in recent years, the managed care industry could benefit from better conveying the value of care management to the public by explaining in more specific terms why the personal health information they collect benefits consumers.

Also, the report could help health plans review their information-collection routines.  More specifically, they can use the report to identify what information is collected under several privacy-sensitive approaches, what information is especially controversial with providers and why, and whether the items they collect are similar to or different from most of the other organizations whose forms and protocols we were able to obtain.

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