Promoting Electrotechnology Careers and Public Policy

October 5, 1998

Health Care Financing Administration
Department of Health & Human Services
Hubert H. Humphrey Building, Room 309-G
200 Independence Avenue, S.W.
Washington, D.C. 20201

Attention: HCFA-0049-P

IEEE-USA has reviewed the Department of Health and Human Services' proposed rule on "Security and Electronic Signature Standards" (HCFA-0049-P) and offers the following comments:

1. We are pleased that the proposed security requirements are broad enough to facilitate the use of security technologies from areas outside of health care.

2. We feel it is important to emphasize that policy issues regarding privacy be separated from the technical issues regarding security. We do not foresee any technical barriers to implementation of the HIPAA security requirements, but do anticipate problems until Congress establishes privacy policy. This would put value onto the security mechanisms and assist organizations with determining the level of security in which to invest.

3. The absence of privacy legislation, definitions of wrongful disclosure, and penalty amounts makes determining the proper level of security very difficult.

4. Cost benefit evaluations need to be undertaken to understand the relationship between competing technologies, levels of security and potential threats to be guarded against. These evaluations should illuminate the economic burdens created by compliance in both large and small organizations and the benefits to be gained from security mechanisms. We need to understand how the levels of desired security vary by the size of the organization and the inducements/support available to facilitate adoption.

5. As privacy issues are resolved by Congress and as cost benefit analyses become available, security and electronic signature policy standards must be reviewed and modified.

IEEE is the world's largest technical professional association with 320,000 members worldwide. IEEE-USA promotes the career and technology-policy interests of the nearly 220,000 electrical, electronics and computer engineers who are U.S. members of the IEEE.

If you have any questions or if we may assist in any way, please contact Deborah Rudolph at (202) 785-0017; d.rudolph@ieee.org.

Thank you.

Sincerely,

John R. Reinert, D.M.
President
IEEE-USA

The Institute of Electrical and Electronics Engineers - United States of America
1828 L Street, N.W., Suite 1202, Washington, DC 20036-5104
Office: (202) 785-0017 * Fax: (202) 785-0835 * E-mail: ieeeusa@ieee.org

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Last Update: Oct. 7, 1998

Staff Info Contact: Deborah Rudolph, d.rudolph@ieee.org