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AHIMA’s Position

AHIMA supports the use of policy to promote access to health insurance coverage for all, as well as the continuity, accuracy, timeliness, completeness, accessibility, and security of an individual’s health information regardless of their health coverage status. Health information (HI) professionals have extensive knowledge and expertise to contribute in developing policies around health reform and health information. To recognize the value of health information in any health reform efforts seeking to expand insurance coverage, improve quality, and/or reduce costs, AHIMA believes that, regardless of insurance coverage status, public policy must:

Access to health coverage is critically important for promoting and maintaining health, preventing and managing ongoing health conditions, and reducing fiscal burden on individuals and their families. Policy must consider closing existing coverage gaps to help achieve comprehensive health coverage for every American.

Individuals’ access to their health information is essential to ongoing care coordination and management. While the Health Insurance Portability and Accountability Act (HIPAA) guarantees the right of individuals to access their protected health information (PHI) that is maintained by a covered entity, policy must also ensure that an individual’s access to his or her health information should not be impeded by any change in insurance status, including a change in commercial or government-run insurance plans.

An individual’s health insurance status or plan can change over time. Policy must encourage individuals to have the ability to take their health information, including both clinical and administrative data, with them when they change plans or experience a change in coverage, should they choose to do so.

Policy must promote the accuracy and integrity of an individual’s health information. This includes addressing the challenge of patient identification and working to incorporate social determinants of health data whenever possible.

Individuals’ health information must have the same protections regarding privacy, security, and completeness regardless of insurance coverage.


Healthcare has been in a constant state of reform in the US for the past century. From the creation of Medicare and Medicaid to the implementation of the Health Insurance Portability and Accountability Act (HIPAA), to the enactment of the Patient Protection and Affordable Care Act (ACA), healthcare reform has been a consistent area of attention. The Biden Administration has prioritized protecting and expanding access to quality, affordable health care, and building on the ACA.

One critical area within healthcare reform that has received less attention is ensuring the accuracy, timeliness, availability, completeness, and access individuals have to their health information. While some steps have been taken to address these issues, additional work is needed to maintain the integrity of an individual’s health information as his or her health insurance status may change. As policymakers aim to address this important issue, AHIMA members have the expertise to offer insight.


Key Points

To realize the benefits of comprehensive health coverage, certain barriers must be addressed, including:

Since 2017, the number and share of Americans without health insurance coverage has risen every year. In 2019, approximately 28.9 million Americans under the age of 65 were uninsured.  Barriers to coverage include affordability, ineligibility, and complexity in the enrollment process.

The ONC Cures Act Final Rule encourages the ability of individuals to leverage secure, standards-based application programming interfaces (APIs) to support individuals’ access to their electronic health information. At the same time, the Centers for Medicare and Medicaid Services (CMS), in a separate final rule, requires health plans in Medicare Advantage, Medicaid, the Children’s Health Insurance Program (CHIP), and through the federal Exchanges to share claims data and other health information electronically via API with individuals.

However, not all aspects of the rule have been implemented. Furthermore, beneficiaries under commercial health insurance plans that are not under CMS authority are not required to share encounter and claims data electronically with individuals via a secure, standardized API. Work also remains to support individuals being able to collect all of their information in one place.

Today, lack of widespread operational principles, as well as limitations in processes and technologies, result in inaccurate patient identification.  Accurate patient identification is necessary in strengthening interoperability. Patient matching processes differ between insurers, which increases difficulties for patients to ensure they have access to their accurate and complete patient data.

Successful attempts today that attempt to ensure the accuracy, continuity, and completeness of an individual’s health information as their health insurance status changes is often manual, human-capital intensive, and may involve unstructured data.

Healthcare reform efforts must maintain the ability of health information professionals to be good stewards of health information, which includes the appropriate sharing of health information (while ensuring that only the minimum necessary information is exchanged and limited to the specific transaction in question). Patient health information, whether residing in a clinic or hospital, or with one of the many HIPAA non-covered entities, must be protected.


Want to read the full statement or share it with your colleagues?

January 5, 2021

AHIMA Calls for Biden Administration and Congress to Ensure Health Information is at Forefront of Health Policy

AHIMA calls for the incoming administration to consider the implications of health information as they begin to implement new health policies in 2021.

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