SB 1331, An Act Concerning The Exclusion Of Patient Health Information And Opt-In And Opt-Out Procedures Relating To The State-Wide Health Information Exchange

TESTIMONY OF THE CONNECTICUT HOSPITAL ASSOCIATION
SUBMITTED TO THE PUBLIC HEALTH COMMITTEE

Wednesday, February 26, 2025

The Connecticut Hospital Association (CHA) appreciates this opportunity to submit testimony concerning SB 1331, An Act Concerning The Exclusion Of Patient Health InformationAnd Opt-In And Opt-Out Procedures Relating To The State-Wide Health Information Exchange. CHA has concerns about the bill as written.

Connecticut hospitals and health systems care for patients, strengthen the state’s economy, and support vulnerable communities across the state. Every day, they work to improve healthcare access, affordability, and health equity. Even as they face ongoing challenges, hospitals provide world-class care to everyone who walks through their doors, regardless of their ability to pay. Hospitals also support an exemplary workforce as the largest collective employer in the state, contribute significantly to the state’s economy, and invest in their communities addressing social drivers of health.

SB 1331 seeks an additional study of certain aspects of patient and provider participation in the State-wide Health Information Exchange (State-wide HIE). While CHA appreciates the desire to bring clarity to the State-wide HIE’s operations and governance, we do not believe that more study is needed.

Last session, the legislature passed PA 24-19, An Act Concerning The Health And Safety Of Connecticut Residents. Several sections of that law provided greater operational and regulatory clarity for the State-wide HIE. Section 23 of the PA 24-19 established a working group (Working Group), led by the Office of Health Strategy (OHS), which was tasked with making recommendations to OHS “regarding the parameters of the regulations to be adopted by, and any policies and procedures to be implemented by” OHS for oversight and operations of the State-wide HIE, including but not limited to “any statutory changes that may be necessary to address any concerns raised by the working group.”

CHA had the privilege of serving as an appointed member of the Working Group. Based on the framework set forth in PA 24-19 that sought both agency and legislative recommendations, Working Group members were expressly invited to submit their individual recommendations to OHS. Within that structure, CHA provided 11 recommendations: seven designed to assist OHS as it works toward promulgating regulations (and any policies necessary to address operations pending final adoption of regulations) and four legislative recommendations. CHA’s 11 recommendations were incorporated as an attachment to the report that OHS filed to fulfill its obligations under PA 24-19, subsection 23(c). Our recommendations can be found here.

We believe that agency and legislative action consistent with those recommendations would obviate the need for additional study and allow the State-wide HIE to move ahead with universal or near universal provider support.

Thank you for your consideration of our position. For additional information, contact CHA Government Relations at (203) 294-7301.