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May 20, 2009
Public Policy Priority Health Data Privacy
Statement Type Regulatory Comment

AMIA comments on the “Guidance Specifying the Technologies and Methodologies That Render Protected Health Information Unusable, Unreadable, or Indecipherable to Unauthorized Individuals for Purposes of the Breach Notification Requirements under the American Recovery and Reinvestment Act of 2009. AMIA promulgates several concerns that include the exclusion of the limited data set (LDS), whom the liability falls in breach reporting, and to better define “breach” that apply to applicable groups.