If a doctor is participating in a quality measurement initiative and is only submitting “Aggregate Patient Information” to the quality measure unit, does the doctor need to take CONSENT from the patient that the patients information will be used in “Aggregate Data Collection”?
PatientPrivacyRights.Org (Deborah Peel, MD) says:
There should be no “secondary uses” or any uses of our personal health information without contemporaneous, informed consent.
Technically, HIPAA does not require consent for aggregate information sharing. Also, quality measurement is part of treatment/payment/operations, so it is exempt anyway. However, beyond HIPAA is the perception of the patient and community that their data is being shared.
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