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SC Data Oversight Council

II. Release of Restricted Data

The following data elements are classified as restricted data elements. They can either directly, in combination with or indirectly, when linked with other databases, identify a patient, health care facility, health care professional or health care insurer. Access to these data elements may be gained by special request and approval by the DOC for health care facility, professional or insurer identifiable data.

A. Geographic Information Data

A Geographic information system is a computer system capable of storing, retrieving, querying, manipulating and mapping geographic data. Geo-coding compares database records with a known master address list and then locates these events to points on a map. The advent of internet map server technology allows users to view geographic data online and download public spatial datasets providing broad accessibility to information. The principal types of mapping techniques are:

  • Point location
  • Point frequency distribution
  • Choropleth mapping
  • Surface density modeling
  • Spatial aggregation to other geographic units

Point location means the mapping of information showing the exact point, address, for an event. The other types of mapping techniques aggregate the data so that the maps do not identify a single event.

The RFA has the ability to geo-code all encounter-level databases at the patient, facility and/or health care provider level. The release of health care facility, health care provider and/or private insurer point-level data requires that approval of the DOC through the data release process. Nothing in the section is to be construed as to restrict the release of data back to the originating health care provider, facility and/or insurer. The DOC considers the release of point location data at the patient-level to be equivalent to releasing patient identifiable data. Consequently, the release of point-level data for patients requires that an entity have statutory authority for these data.

In the case of requests for zip code level information the DOC grants permission to the RFA to satisfy requests that RFA deems non-confidential by a properly qualified statistician using accepted analytic techniques concluding the risk is substantially limited to identify the subject of the information in accordance with the HIPAA Privacy Regulations [45 CFR § 164.514(b)] without requiring an application for release of restricted data.

 

A. Restricted Data

1.     Inpatient Hospitalization Restricted Data Elements

  • Admission date

  • Discharge date

  • Admission Hour

  • Discharge Hour

  • Patient birth date

  • Patient age in years

  • Medical record number

  • Patient number, facility assigned

  • Unique patient number, RFA assigned

  • Procedure dates

  • Encrypted Carrier codes – health care insurer

  • Patient zip code (digits 1-5)

  • Health care professional identifier

  • Unique Health care professional number, RFA assigned

  • Health care facility identifier

  • Unique Health care facility number, RFA assigned

2.     Emergency Department Visits and Facilities Reporting Observation Services Restricted Data Elements

  • Admission date

  • Admission Hour

  • Discharge Hour

  • Patient birth date

  • Patient age in years

  • Medical record number

  • Patient number: facility assigned

  • Unique patient number, RFA assigned

  • Procedure dates

  • Encrypted Carrier codes – health care insurer

  • Patient zip code (digits 1-5)

  • Health care professional identifier

  • Unique health care professional number, RFA assigned

  • Health care facility identifier

  • Unique health care facility number, RFA assigned

 

3.     Free Standing and Hospital Based Ambulatory Surgery, Imaging and Other Services/Equipment Requiring a Certificate of Need Restricted Data Elements

  • Admission date

  • Patient birth date

  • Patient age in years

  • Medical record number

  • Unique patient number, RFA assigned

  • Encrypted Carrier codes

  • Patient zip code (digits 1-5)

  • Health care professional identifier

  • Unique health care professional number, RFA assigned

  • Health care facility identifier

  • Unique health care facility number, RFA assigned

4.     Home Health Restricted Data Elements

  • Admission date(s)

  • Discharge date(s)

  • Services dates by discipline

  • Patient start of care date

  • Service coverage period

  • Patient birth date

  • Patient age in years

  • Medical record number

  • Unique patient number: RFA assigned

  • Patient zip code (digits 1-5)

  • Health care professional identifier

  • Unique health care professional number, RFA assigned

  • Health care facility identifier

  • Unique health care facility number, RFA assigned

 

B. Application for Encounter Data containing Restricted Data

Persons requesting access to restricted data must complete a data application for restricted data and Confidentiality Contract. The DOC, in accordance with The Principles and Protocol for the Release of Health Care Data, will review this application. If approved, persons receiving restricted data elements, including the principal investigator, chief executive officer, and the data processing manager to sign and submit confidentiality contracts to the Revenue and Fiscal Affairs Office. Researchers submitting requests for restricted data files must furnish, along with an application, a copy of their organizations IRB (Internal Review Board) approval. The Application for Use of Restricted Data Files is located in Appendix F.

C. Reports

Historically, the RFA has released two types of health care facility-specific reports; first, reports shared with the health care facility supplying the data and secondly, reports released to the general public.

The first type of facility-specific reports included zip code market share, quarterly and year-to-date trends, patient origin and out-migration market share. The DOC endorses the policy that entities supplying data to the RFA should have access to their data. This policy attempts to balance the need for confidentiality of the patient and the appropriate confidentiality of health care providers, insurers and facilities with regards to competitive health care information against the open release of data.

Because of the sensitivity of competitive information such as financial information and market share data, the DOC will release market share or financial reports, which identify providers, professionals or carriers, only as listed under the Report Approved for Release by the DOC.

1. Reports Approved for Release by the DOC

The following is a listing of the DOC approved reports for Inpatient Hospitalization, Emergency Department Visits and Ambulatory Surgery Encounters

  • Summary Statistics, By Hospital
    • Inpatient Hospital Discharge Data
  • Patient Origin Report By Facility
    •  Inpatient Hospital Discharge Data
    •  Emergency Department Data
    • Ambulatory Surgery Data
  • Number And Percent Of Persons Treated Outside Their County Of Residence
    • Inpatient Hospital Discharge Data
    • Emergency Department Data
    • Ambulatory Surgery Data
  • Summary Injuries Reports by County of Treatment

No report will be released if it cannot meet appropriate levels of accuracy as determined by the RFA. A third party may not reproduce reports without inclusion comments from affected health care professional and/or facility.

The RFA will continue to develop health care facility and professional specific reports which do not release financial or market share information. The DOC believes in the use of constituent-based subgroups to make recommendations for the types of reports necessary in the areas of health care policy, planning and outcomes. Before the release of any new, not previously DOC approved, health care facility and/or professional specific reports, the RFA and the DOC will follow the New Report Review Process to ensure the accuracy and validity of the reports. After a report has gone through the New Report Review Process, subsequent releases of the report will be subject to the Previously Approved Report Review Process.

2. The New Report Review Process

New reports, not previously approved by the DOC, will be developed utilizing the most current data available and will be provided to the affected health care facilities and/or professionals for review before release. The affected health care facilities and/or professionals will have 30 days to review these reports and to notify the RFA of any errors in data that would affect the accuracy of the report.

a. Errors in Data Reporting: Upon review of the reports, if health care facilities and/or professionals identify errors in reporting which were not discovered through normal editing procedures and which would change significantly the analytic results, as determined by the DOC, health care facilities and/or professionals will have 3 months to resubmit a corrected data tape. Health care facilities and/or professionals unable to correct their data may submit comments for inclusion in the report. In extraordinary cases, the health care facilities and/or professionals may request an extension from the DOC. The RFA will provide revised reports to health care facilities and/or professionals for an additional 14 days to review the revision of the report and submit comments for inclusion in the release. Health care facilities and/or professionals may request an extension from the DOC.

b. Errors in Report Format or Methodology: Upon review of the report, if the health care facilities and/or professionals identify errors or enhancements in format or methodology which the DOC determines to substantially alter the results the RFA will make the necessary modifications within 30 days and provide health care facilities and/or professionals a 14 day review period to submit comments for inclusion in the release. After making the necessary adjustments, the RFA will provide the reports including the health care facilities’ and/or professionals’ comments to the DOC for approval and release. Subsequent releases of these reports will be subject to the Previously Approved Report Review Process.

3. Previously Approved Report Review Process

Previously approved reports will utilize the most current data available and be reviewed by the affected health care facilities and/or professionals. The affected health care facilities and/or professionals will have 14 working days (from date of receipt of the report) to review these reports and to submit comments for inclusion in the release. After making the necessary adjustments, the RFA will release the reports including the health care facilities’ and/or professionals’ comments.

D. Special Requests

A special request is the release of restricted data elements in a manner that would allow the identification of patients and/or health care facilities and/or professionals. If the special request requires the RFA to aggregate the data by a restricted data element but not release the restricted data element, the request will be handled as a release of unrestricted data, so long as the confidentiality of patients and the appropriate confidentiality for health care professions, insurers and facilities will not be compromised. The release of the patient-level data with health care professional, facilities and/or private insurer’s identifiers will be made to researchers and government entities only.

All applicants for special requests will submit to the RFA the required documentation including, but not limited to the following: a list of the requested data elements, time frame for the requested data elements, a study protocol, intended uses of the data, policies for the protection of the restricted data elements, a Confidentiality Contract signed by the principal investigator and a detailed listing of individuals who will have access to the data. Data requests may include multiple years of prospective data, for the same research protocol, so that an application need not be filed for each year. It is the policy and practice of the RFA to provide technical assistance to applicants to assist in the application process.

Health care professional, private insurer and facility identifiable data elements approved for the applicant’s use by the DOC may not be released in any product, publication or communication without the written approval of the DOC and review and comment by the affected health care facilities and/or professionals (as specified in Section 44-6-170, as amended, Code of Laws of South Carolina, 1976). All third party reproductions of the reports must include comments from the affected health care facilities and/or professionals.

If the application requests the linking of a RFA database with other database(s), the DOC will approve the manner in which the linkage is done.

E. Health Data Analysis Task Force

The Health Data Analysis Task Force (HDATF), as specified in Section 44-6-170, as amended, Code of Laws of South Carolina, 1976, may be a committee or committees convened to make recommendations concerning types of analyses needed to carry out the goals and objectives of the Data Oversight Council. The task force will be composed of members as deemed appropriate by the subject being considered and may include technical representatives of universities and other private sector and public agencies including, but not limited to, health care providers and insurers. The DOC may request the RFA to convene the HDATF for study and review of specific data issues.

The Chair of a HDATF will be appointed by and serve at the pleasure of the Chair of the DOC and RFA. The HDATF will meet as needed. A quorum for the HDATF will be a majority of its members.

F. Follow-back Studies

For entities not having statutory authority to access patient identifiable data, patient contact for follow-back studies, using patient identifiable data, must be conducted through the health care facility and/or professional and requires the informed consent of the patient or the patient's representative. The purpose of these studies shall not be disclosed to anyone, when trying to locate patients, other than the entity originally providing the RFA with the data, the patient or the patient’s representative. No undue burden shall be placed upon health care facilities and/or professionals to comply with follow-back studies. For on-going data activities, the data users with assistance from the RFA in conjunction with the South Carolina Health Information Management Association shall develop an informed consent form for use by the appropriate facilities.

For entities having statutory authority to access patient identifiable data with confidentiality requirements comparable to the RFA, follow-back studies using patient identifiable data will be requested to be conducted in accordance and with the approval of an Internal Review Board or Privacy Board.