Personal Health Records and Personal Health Record Systems
Personal Health Records and Personal Health Record Systems
Personal Health Records and Personal Health Record Systems
U.S. Department of
Health and Human Services
National Institutes of Health
National Cancer Institute
Washington, D.C.
February 2006
Contents
Acknowledgements
Executive Summary
Background
Privacy
Recommendations 3-7
Security Requirements
Recommendations 8-9
Interoperability
Recommendations 10-14
This report was developed by the Workgroup on the National Health Information Infrastructure (NHII) of the National
Committee on Vital and Health Statistics (NCVHS), the statutory public advisory body on health information policy to
the Secretary of Health and Human Services. All the members of the full National Committee, and particularly those
who serve on the Subcommittee on Standards and Security and the Subcommittee on Privacy and Confidentiality,
contributed to the final report. It is based on a letter report that was approved by the full Committee in September
2005 and sent to the Secretary. The letter report is available on the NCVHS Web site (http://ncvhs.hhs.gov/050909lt.
htm). It has been slightly modified (but not substantively changed) to serve the wider audience interested in personal
health records and systems. The Workgroup is grateful to the many experts and organizations whose invaluable
suggestions contributed to the findings and shaped the recommendations.
Development of this report was coordinated and supported by the National Cancer Institute’s Center
for Bioinformatics, which provides the lead staff for the Workgroup. Workgroup staff and staff from
the National Center for Health Statistics, which serves as Executive Secretary to NCVHS, provided
invaluable assistance.
President Bush and Secretary Leavitt have put forward a vision that, in the Secretary’s words, “would create a
personal health record that patients, doctors and other health care providers could securely access through the
Internet no matter where a patient is seeking medical care.” The National Health Information Infrastructure
Workgroup of the National Committee on Vital and Health Statistics (NCVHS) held six hearings on personal health
records (PHRs) and PHR systems in 2002-2005. On the basis of those hearings, the Workgroup developed a letter
report with twenty recommendations that it sent to the Secretary in September 2005. Citing the role PHR systems
could play in improving health and healthcare and furthering the broad health information technology agenda, the
letter report urges the Secretary to exercise leadership and give priority to developing PHRs and PHR systems, con-
sistent with the Committee’s recommendations. The present report is a slightly expanded version of the letter report
sent to the Secretary. Although substantively unchanged, it adds clarifying information for a broader audience.
Currently, PHRs and their associated health The Committee concluded that while this variety
management tools are heterogeneous and evolving. reflects the current stage of innovation, it makes
There is no uniform definition of “personal health collaboration and policy-making difficult. The Com-
record” in industry or government. The following mittee recommended development of a descriptive
attributes can vary: framework to facilitate nuanced discussion and
n the scope or nature of the information/ policy-making in this area, and proposed the attri-
contents butes listed above as a starting point (see page 11).
n the source of the information
n the features and functions offered Although the consumer/patient is the primary ben-
n the custodian of the record eficiary and user of PHRs, other stakeholders stand
n the storage location of the contents to benefit from their use, as well. The table below
n the technical approach summarizes potential benefits from the perspective of
n the party who authorizes access to various roles. (These perceived benefits may not align
the information with any specific PHR or PHR system, and the same
users may play different roles at different times.)
NCVHS is the statutory public advisory Committee on health information policy to the Secretary of Health and Human Services.
http://www.ncvhs.hhs.gov/050909lt.htm
President Bush and Secretary Leavitt have put forward a vision that, in the Secretary’s words, “would create
a personal health record that patients, doctors and other health care providers could securely access through the
Internet no matter where a patient is seeking medical care.” Responding to this vision, the National Committee on
Vital and Health Statistics (NCVHS) submitted a letter report on Personal Health Record (PHR) systems in September,
2005. The letter report describes initial findings from national hearings covering the many types of systems referred
to as “Personal Health Records,” suggests areas for further exploration, and offers twenty recommendations. It urges
the Secretary to exercise leadership and to give this area the priority it deserves, in view of the role PHR systems could
play in improving health and healthcare and furthering the broad health information technology agenda. The present
report is a slightly expanded version of the letter report sent to the Secretary. Although substantively unchanged,
it adds clarifying information for a broader audience.
In its 2001 report, Information for Health: A Strategy wellness and healthcare decision making. It includes
for Building the National Health Information a personal health record that is created and con-
Infrastructure, NCVHS identified three primary areas trolled by the individual or family, plus information
or dimensions that comprise a national health infor- and tools such as health status reports, self-care
mation infrastructure (NHII): information to support trackers and directories of healthcare and public
the needs of patient care, population health, and per- health service providers.
sonal health. The healthcare provider (patient care)
area promotes quality patient care by providing ac- In this vision of the NHII, the three primary areas are
cess to more complete and accurate patient data on equally important, and the goal for the infrastruc-
the spot, around the clock. It includes provider notes, ture as a whole is to promote optimum information
clinical orders, decision-support programs, electronic exchange among them. The heart of the vision is
prescribing programs, and practice guidelines. The sharing information and knowledge as appropri-
second area, population health, makes it possible for ate so it is available to people when they need it
public health officials and other data users at local, to make the best possible health decisions. Ready
State, and national levels to identify and track health access to relevant, reliable information and secure
threats, assess population health, and create and modes of communication will enable consumers,
monitor programs and services. This area includes patients, healthcare and public health professionals,
information on both the health of the population and public agencies, and others to address personal and
influences on it. Finally, the personal health area of community health concerns far more effectively.
the NHII supports individuals in managing their own
Source: National Committee on Vital and Health Statistics, Information for Health:
a Strategy for Building the National Health Information Infrastructure, Washington, D.C., 2001.
3 See Lansky, D., Kanaan, S., Lemieux, J. April 15, 2005. Identifying Appropriate Federal Roles in the Development of Electronic Personal Health
Records. Results of a Key Informant Process. Submitted to the Office of Disease Prevention and Health Promotion, OPHS, U.S. Department of
Health and Human Services; and Connecting for Health, July 2004. Connecting Americans to their Healthcare. Final Report. Working Group
on Policies for Electronic Information Sharing Between Doctors and Patients. Markle Foundation and Robert Wood Johnson Foundation.
http://www.connectingforhealth.org/resources/wg_eis_final_report_0704.pdf
Personal health records are broadly considered as means by which an individual’s personal health information
can be collected, stored, and used for diverse health management purposes. However, NCVHS found that there
is no uniform definition of “personal health record” in industry or government, and the concept continues to evolve.
In some concepts, the PHR includes the patient’s interface to a healthcare provider’s electronic health record (EHR).
In others, PHRs are any consumer/patient-managed health record. This lack of consensus makes collaboration,
coordination and policymaking difficult. It is quite
possible now for people to talk about PHRs without There is no uniform definition
realizing that their respective notions of them may of “personal health record”
be quite different. Recognizing the variety of attri- in industry or government,
butes and possibilities and being very specific about and the concept continues to
what is being discussed would enable those engaged evolve. This lack of consensus
in collaboration and policymaking to conduct more makes collaboration, coordination
nuanced discussions of PHRs and to collaborate and policymaking difficult.
more effectively.
The first step in this direction is to catalog the its process and recommends a way HHS could
variety of types of PHRs and PHR systems in promote greater clarity.
existence and the varied uses of the terminology.
This section summarizes the different perspectives The term “record” in “personal health record” may
of PHRs that the Workgroup observed throughout itself be limiting, as it suggests a singular static
repository of personal data. The Committee found
The Committee proposes adopting that a critical success factor for PHRs is the provi-
sion of software tools that help consumers and
the term “personal health record”
patients participate in the management of their own
to refer to the health or medical health conditions. A “personal health record system”
record that includes clinical data, provides these additional software tools. The Com-
and the term “personal health mittee proposes adopting the term “personal health
record” to refer to the collection of information
record systems” to refer to the about an individual’s health and health care, stored
multi-function tools that include in electronic format. The term “personal health re-
PHRs among a battery of functions. cord system” refers to the addition of computerized
tools that help an individual understand and manage
14 Personal Health Records and Personal Health Record Systems
the information contained in a PHR. These terms are analogous called for, to highlight the benefits and risks of various types
to the terms “electronic health record” and “electronic health of PHRs, aimed not only at consumers and patients but also
record systems” that have been adopted by the standards at healthcare providers and other stakeholders.
development organization HL7, which is leading the standards
activity in this area. The PHR and the PHR system are intended Initial framework of PHR
for use by consumers, patients or their informal caregivers, and PHR systems attributes
in contrast with EHR systems that are intended for use by
healthcare providers. n Scope and nature of content
Some PHR systems just have consumer
Despite the heterogeneity of PHRs and PHR systems at pres- health information, personal health
ent, NCVHS concluded that it is not possible, or even desir- journals, or information about
able, to attempt a unitary definition at this time. However, the benefits and/or providers, but no
Committee believes it is possible as well as useful to charac- clinical data about the individual.
terize them by their attributes: specifically, the scope or nature Some PHR systems have clinical informa-
of their information/contents, the source of their information, tion. Of these, some are disease specific,
the features and functions they offer, the custodian of the some include subsets of information
record, the storage location of the content, the technical ap- such as lab reports, and some are
proach to security, and the party who authorizes access to the comprehensive.
information.
n Source of information
Data in PHR systems may come from the
NCVHS believes that establishing consumer, patient, caregiver, healthcare
a framework for characterizing and provider, payer, or all of these.
describing the attributes of PHRs and Some PHR systems are populated with
PHR systems would be extremely helpful data by EHRs.
in promoting a better understanding and n Features and functions
appropriate use of any given PHR PHR systems offer a wide variety of
features, including the ability to
system. A consensus framework would
view personal health data, exchange
also provide a foundation for public secure messages with providers, schedule
education efforts. appointments, renew prescriptions, and
enter personal health data; decision support
(such as medication interaction alerts or
NCVHS believes that establishing a framework for char-
reminders about needed preventive
acterizing and describing the attributes of PHRs and PHR
services); the ability to transfer data to or
systems would be extremely helpful in promoting a better
from an electronic health record;
understanding and appropriate use of any given PHR system.
and the ability to track and manage
Some of the approaches to each of the attributes, as heard
health plan benefits and services.
by the Committee, are listed below in a framework that the
Committee offers as a starting point for such an effort. The n Custodian of the record
consensus-building process around such a framework should The physical record may be operated by a
take into consideration the work that standards development number of parties, including the consumer
organizations are doing to define the functional attributes of or patient, an independent third party, a
PHR systems. A consensus framework would also provide a healthcare provider, an insurance
foundation for public education efforts, which many speakers company, or an employer.
Personal Health Records and Personal Health Record Systems 15
n Data storage Recommendation 2:
Data may be stored in a variety of locations,
including an Internet-accessible database, Education.
a provider’s EHR, the consumer/patient’s HHS and others should use the agreed-upon framework
home computer, a portable device such as as a basis for education efforts highlighting the benefits and
a smart card or thumb drive, or a privately risks of various types of PHRs, aimed not only at consumers
maintained database. and patients but also at healthcare providers (e.g., physicians
n Technical approaches and nurses) and other stakeholders.
Current PHRs and PHR systems are
generally not interoperable (with the
exception of the PHRs that are “views”
into the EHR, and they vary in how
they handle security, authentication,
and other technical issues.
n Party controlling access to the data
While consumers or patients always have
access to their own data, they do not
always determine who else may access it.
For example, PHRs that are “views” into
a provider’s EHR follow the access rules
set up by the provider. In some cases,
consumers do have exclusive control.
Recommendations on Evolving
Terminology and Functions:
1. Consensus Framework
2. Education
Recommendation 1:
Consensus framework.
NCVHS recommends that HHS support the development
of and promote public-private consensus on a framework for
characterizing personal health record systems, building on
this initial framework.
The privacy considerations of PHR systems are complex, yet addressing them adequately is essential if PHR
systems are to become widely accepted and used. Consumers want to be able to control access to their
personal health information. As noted above, all PHR systems are based on consumers having access to
their health information, and some are based on consumers having exclusive control of the information in
their PHR. Some presenters raised the issue of consum-
ers’ ownership of their personal health information. All PHR systems are based on
Some identified a difference between legal control consumers having access to
and ownership of the institutional medical record, their health information, and
on one hand, and consumer control and ownership some are based on consumers
of personal information and of a PHR, on the other.
having exclusive control of the
NCVHS observed that although the issues of health
information in their PHR. It will
record ownership and access control are not new,
be important to clarify the
they take on added dimensions with the emergence
respective rights, obligations,
of PHR systems. Moreover, while ownership per
and potential liabilities of
se may not be as relevant as control, it will nev-
ertheless be important to clarify the respective
consumers, patients, providers,
rights, obligations, and potential liabilities of con-
and other stakeholders
sumers, patients, providers, and other stakeholders in PHR systems.
in PHR systems.
While HIPAA compels covered entities to provide notice of Education about privacy. In any public education program
their privacy practices to consumers, not all PHR vendors are about PHR systems, HHS and other parties should inform
“covered entities” as defined under HIPAA. The Committee consumers about the importance of understanding the pri-
is unaware of any requirement that compels PHR vendors vacy policies and practices of PHR system vendors, including
not covered by HIPAA to provide to consumers the terms and the enumeration of potential secondary uses and disclosures
conditions governing the privacy of their personal data. While of personally identifiable health information.
the Committee does not suggest that HIPAA or a HIPAA-like (See Recommendation 2.)
framework is necessarily the most appropriate for
safeguarding privacy in PHR systems, it does believe that Recommendation 4:
privacy measures at least equal to those in HIPAA should
apply to all PHR systems, whether or not they are managed Best practices. HHS should identify and promote best
by covered entities. The Committee also believes that it is practices with respect to privacy policies and practices for
vital for PHR systems vendors to provide clearly stated, PHR systems, and models for plain language wording of
easily understood, up-front privacy notices to consumers of notices describing these policies and practices. These best
their privacy policies and practices, and that these notices practices and models should also address translations into
should be translated into other languages. other languages.
Recommendation 7:
NCVHS noted that security is a critical component of a PHR system, especially if it is accessible via the Internet.
Appropriate security measures must be employed to minimize the risk that an unauthorized person could gain
access to an individual’s information contained within a PHR. Survey and focus group research presented to the
Workgroup indicates that widespread adoption of PHRs is not likely to happen until consumers are confident that
they have adequate security protections. This confidence seems to depend on having the ability to control access
to personal information and to audit who has seen it. As noted, the Committee found that PHR systems may exist
in a variety of forms. Some of these may be within the exclusive control of the individual, such as a smart-card or
thumb-drive based system. The large majority are currently Internet-based, such as those sponsored by healthcare
providers, health insurers, or commercial ventures. New technical approaches may be needed to promote and
achieve personal control over the creation, management, and exchange of personal health information contained
within PHRs. The HIPAA Security Rule, as noted, has limited application. However, there is broad validity to its
observation that specific security requirements will vary
over time based both on threats, available security tech- Security is a critical component
nologies and requirements inherent to a particular PHR. of a PHR system, especially if it is
As noted above, the HIPAA Security Rule only applies to accessible via the Internet.
covered entities.
Recommendation 8:
As observed at the beginning of this report, the greatest opportunities for improving health and health care lie
in enabling information exchange between the three dimensions (areas) of the national health information infra-
structure. Consumers, providers, and those responsible
for population health use much of the same informa- The greatest opportunities for
tion, but they do so for different purposes: respectively,
improving health and health care
to manage personal and family health, to care for
lie in enabling information
patients, and to protect and promote the health of
exchange between the three
the community and the nation. The overlapping areas
dimensions (areas) of the national
shown in the diagram on page 12 illustrate the types
health information infrastructure.
of information that will be shared and the need for
interoperability. Interoperability is the term used to
The full potential of PHR systems
describe the technical capacity for this exchange
will not be realized until they are
of data between different information systems. capable of widespread exchange
The full potential of PHR systems will not be realized of information with EHRs and
until they are capable of widespread exchange of other sources of personal and
information with EHRs and other sources of personal other health data.
and other health data.
Recommendation 10:
The Committee heard testimony that the Federal government can offer vision and strategic leadership for PHR develop-
ment and dissemination across its many roles in the health sector—that is, its roles as policy maker, healthcare provider,
payer, employer, and sponsor of research and public education. The Committee notes that a number of documents
already exist that can help identify specific opportunities, including the report cited on page 12 of this Report. Several
Federal agencies are already pursuing the use of or interaction with PHR systems to support their own missions (e.g.,
CDC and CMS, DoD and VA). Development of harmonized definitions for PHR systems and EHR systems will help coordi-
nate these efforts with other Federal agencies, thereby
preventing unwanted duplication and confusion among
The Federal government can offer
users and promoting needed interoperability. NCVHS
vision and strategic leadership for
believes that HHS can model its role on the one it plays
PHR development and dissemination
with respect to EHR adoption. That is, it can encourage
and actively participate in a public/private partnership
across its many roles in the health
that facilitates standards-based approaches in a harmo- sector. NCVHS believes that HHS
nized legal and regulatory environment across geopoliti- can encourage and actively participate
cal boundaries. The Committee heard that the Federal in a public/private partnership
Employee Health Benefits Plan could provide a vehicle that facilitates standards-based
for encouraging PHR system use and assessment. An approaches in a harmonized legal
additional federal role is to provide for experimentation and regulatory environment across
and research to facilitate the evolution of PHR systems, geopolitical boundaries.
as described below.
Recommendations
on the Federal Role:
15. Assess Federal roles
16. Considerations for
underserved populations
Recommendation 15:
Recommendation 16:
The hearings identified numerous issues regarding PHR systems that require further research and evaluation—for
example, who uses them and how, interactions with health services, and impacts. NCVHS found that much of the
currently available information about PHR systems is based on expert opinion and focus groups. It concludes that a
variety of research, evaluation, and pilot studies are necessary to answer key questions and allow comparison of PHR
system types and approaches. Findings from rigorous research and evaluation studies will increase the evidence base
for the effective implementation and use of PHR systems. At least some of the needed research may be conducted as
an extension of current and planned research into EHR systems. The Committee estimates that the amount of funding
required for PHR systems research would be a mod-
The Committee identified broad areas for est percentage of ongoing and future health IT and
research and evaluation for PHR systems. EHR research efforts.
These areas include consumer, health
services, and technical research and the The Committee identified broad areas for research
and evaluation for PHR systems. These areas include
development of metrics to assess the consumer, health services, and technical research and
implementation and impact of PHR the development of metrics to assess the implemen-
systems on multiple dimensions of tation and impact of PHR systems on multiple dimen-
sions of health and healthcare.
health and healthcare.
Consumer research should identify who is adopting PHR Health services research should address issues
systems; how individuals use the systems; barriers to adop- related to PHR systems’ impact on workflow,
tion and successful use; and access, pricing and usability particularly its effects on efficiency and utilization.
issues, among other things. Identification of these factors While there are presumptive positive relationships
can inform decisions about the functions and drivers for between PHR systems and patient safety, healthcare
PHR systems adoption. When overlaid with the different quality, costs, and individual and population health,
types of PHR systems that the Committee has identified, the the actual impact is unknown. Some areas for fur-
health care and technology industries can design successful ther research with respect to patient management
products that will match consumers’ needs and preferences, include whether and how PHR systems change the
and the Federal government can more easily identify the best way individuals relate to healthcare providers and
purposes for any Federally-sponsored or Federally-promoted the healthcare system; whether PHR systems lead
PHR system. to better self-management of chronic conditions;
Recommendation 17:
The National Committee will continue to gather information on this dynamic field. In particular, it plans to release
additional recommendations on privacy, confidentiality and the NHIN. In addition, it will provide a forum for exploring
the following issues that arose from the initial hearings:
n The role of CMS
n Ownership and control of data within PHR systems
n The ability of PHR systems to obtain data from external sources such as provider systems, claims
clearinghouses, health plans and similar sources
n Non-repudiation (authenticating the integrity of the contents and exchange of information)
n Potential liability for providers associated with the use of incomplete or inaccurate data within a PHR
n Privacy policy practices, including notice