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September 8, 2005 Seventh Annual Report to Congress on the Implementation Of the Administrative Simplification Provisions of the Health Insurance Portability and Accountability Act of 1996
September 8, 2005 Seventh Annual…
The Honorable Dennis J. Hastert
H-209, The Capitol
Dear Mr. Speaker:
I am pleased to transmit our Seventh Annual Report to Congress on the Implementation of the Administrative Simplification Provisions of the Health Insurance Portability and Accountability Act (HIPAA). In compliance with Section 263, Subtitle F of Public Law 104-191, the report was developed by the National Committee on Vital and Health Statistics (NCVHS), the public advisory committee to the U.S. Department of Health and Human Services on health data, privacy, and health information policy, and covers the period January 2004 through April 2005.
The Administrative Simplification provisions of HIPAA require the Secretary of Health and Human Services (HHS) to adopt a variety of standards to support electronic interchange for administrative and financial healthcare transactions, including standards for security and privacy to protect individually identifiable health information. In addition, the statute gives expanded responsibilities to the National Committee on Vital and Health Statistics for advising the Secretary on health information privacy and on the adoption of health data standards. The Committee is further directed to submit an annual report to Congress on the status of implementation of the Administrative Simplification effort.
As described in our report, significant progress occurred on several HIPAA Administrative Simplification standards during the past year. NCVHS applauds these accomplishments and reaffirms the importance of the HIPAA administrative simplification initiative for improving the efficiency and effectiveness of the healthcare system in the U.S. However, the full economic benefits of Administrative Simplification will only be realized when all of the standards are in place, and implementation activities and resource planning in the industry will be more effective when the entire suite of standards is finalized. Accordingly, we encourage the Secretary of HHS to expedite the publication of the remaining rules without delay, and urge Congress to provide sufficient resources and support to assure successful implementation of this important initiative.
We hope that you will find this seventh annual report informative and look forward to continued progress on these important issues for the nation's health system. If you or your staff would like a briefing presentation on any of our past or anticipated activities, please let me know.
We are committed to improvements in health information systems that will enhance the quality of healthcare, lower costs, and facilitate access to care in the U.S.
Simon P. Cohn, M.D., M.P.H., Chairman,
Richard Cheney
The Honorable Chuck Grassley
The Honorable Mike Enzi
The Honorable Bill Thomas
The Honorable Joe Barton
The Honorable John A. Boehner
Administrative Simplification in Healthcare: January 2004 – April 2005
Seventh Annual Report to Congress on the Implementation
Background About HIPAA Administrative Simplification
Progress Since Last Report to Congress
This report describes the status of implementation of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA.)
The major purpose of the HIPAA provisions is to improve the efficiency and effectiveness of the nation's healthcare system, specifically Medicare and Medicaid programs and, in general, the overall healthcare system by encouraging the electronic transmission of health information through the use of standards. The HIPAA standards are required to be used by health plans, clearinghouses, and healthcare providers who transmit or maintain electronic health information.
Through the HIPAA statute Congress expanded the responsibilities of the National Committee on Vital and Health Statistics (NCVHS), which include advising the Secretary of Health and Human Services on the adoption of standards, monitoring their implementation, and reporting annually on progress. This report is the seventh annual report on implementation and covers the period January 2004 through April 2005.
To improve the effectiveness and efficiency of the nation's healthcare system, the Health Insurance Portability and Accountability Act (HIPAA) of 1996 includes a series of "administrative simplification" provisions requiring HHS to adopt national standards for electronic healthcare transactions. By ensuring consistency throughout the industry, the national standards will make it easier for health care organizations to process transactions electronically. The law also requires the adoption of privacy and security standards in order to protect individually identifiable health information. HIPAA requires that "covered entities" e.g. health plans, healthcare clearinghouses, and those healthcare providers conducting electronic financial and administrative transactions (such as eligibility, referral authorizations, and claims) comply with each set of standards. Other businesses may choose to comply with the standards, but the law does not mandate that they do so.
In general, the law requires covered entities to comply with each set of standards within two years following adoption, except for small health plans, which have three years to come into compliance. For the electronic transactions and code sets rule only, Congress in 2001 enacted legislation (Administrative Simplification Compliance Act [ASCA]; Pub. L. No. 107-105) extending the initial deadline one year to Oct. 16, 2003 for all covered entities, including small health plans. The compliance dates for the health information privacy rule were April 14, 2003 for large health plans, healthcare clearinghouses and participating healthcare providers and April 14, 2004 for small health plans.
The newest regulations under HIPAA's Administrative Simplification provisions that took effect during this report's timeframe (along with the privacy rule for small health plans stated previously) include the employer identifier standard on July 30, 2004 and the security standard on April 20, 2005. All covered entities were required to comply with each of these standards with the exception of the small health plans, which must do so one year later respectively.
The next HIPAA regulation with scheduled compliance dates is the national provider identifier (NPI) standard slated for May 23, 2007 (most covered entities) and May 23, 2008 (small health plans). Other HIPAA regulations in various stages of development or publication include enforcement, claims attachment, and the national health plan identifier standards. Although HIPAA included a requirement for a unique personal healthcare identifier, HHS and Congress have put the development of such a standard on hold indefinitely.
Eighteen months after the compliance date for the transactions and code sets rule, progress continues with the implementation of the HIPAA standards. The Centers for Medicare and Medicaid Services (CMS) report that as of the end of April 2005 the proportion of HIPAA-compliant claims coming into Medicare reached ninety-nine percent. In addition over eighty percent of receivers of the remittent advice transactions are able to use the HIPAA standard.
Current healthcare industry enforcement for HIPAA compliance is managed by CMS for the non-privacy standards (transactions and code sets, security, etc.) and by the Office for Civil Rights (OCR) for the privacy standards. Both CMS and OCR have employed proactive strategies involving extensive multi-faceted outreach campaigns to educate the public about HIPAA Administrative Simplification requirements. These strategies include informative web sites, frequently asked questions, conferences, toll free hotlines and targeted technical assistance materials.
To strengthen HIPAA enforcement and to ensure uniform rules for the imposition of civil monetary penalties for HIPAA violations, two notices were posted in the Federal Register. The first notice was posted on March 25, 2005 entitled: Procedures for Non-Privacy Administrative Simplification Complaints Under the Health Insurance Portability and Accountability Act of 1996. The second, a Notice of Proposed Rule Making (NPRM), was posted on April 18, 2005 entitled: HIPAA Administrative Simplification: the Enforcement Rule.
Seventy-eight percent of the 334 complaints received by CMS involved private sector entities. CMS has determined that most complaints filed are resolved by the involved parties before the need to issue a corrective action plan.
By the end of April 2005 (two years after the initial compliance date) the number of privacy complaints to OCR totaled 12,542 with sixty-five percent closed. Two hundred cases have been referred by OCR to the Department of Justice (DoJ).
The compliance date for the employer identifier was July 30, 2004 (small health plans July 30, 2005). No complaints have been received by CMS regarding the employer identifier.
The compliance date for the security rule was April 20, 2005 (small health plans April 20, 2006). CMS was prepared for security complaint submission on that date. CMS and OCR also developed procedures to investigate "dual" complaints, those that involve violations of both the privacy and security rule. A small number of complaints were received during the first several weeks after the compliance date.
CMS is preparing the system to issue the National Provider Identifier (NPI) for use in the HIPAA standard electronic healthcare transactions. The NPI will replace current provider identifiers used in today's HIPAA standard transactions thus eliminating the use of multiple identification numbers by each provider. The earliest application for an NPI is through a web-based process, which started May 23, 2005. The paper applications for NPI enumeration will begin July 1, 2005. The system began issuing NPIs on May 23.
The proposed rule on standards for claims attachments was signed by the Secretary of HHS and sent to the Office of Management and Budget (OMB) in May 2005. Publication is expected this fall.
The proposed rule on a National Health Plan ID is being developed within HHS.
Private Sector Input About HIPAA Administrative Simplification
The Committee has continued to serve as the Department's primary liaison with the private sector to obtain the views, perspectives, and concerns of the interested and affected parties, as well as their input and advice, on health data standards and privacy. During 2004 and through April 2005, the focus of NCVHS public hearings and committee deliberations about HIPAA Administrative Simplification was on implementation issues, industry readiness and obstacles in achieving successful implementation.
In March 2004 the Committee recommended to HHS the continued use of the National Council for Prescription Drug Programs (NCPDP) Telecommunication Standard Version 5.1 for billing supplies consumed or used during the administration of a drug therapy or commonly dispensed through a retail pharmacy channel. A clarification to this standard was prompted by a request by the Designated Standards Maintenance Organization (DSMO). When the use of the National Drug Code (NDC) designated standard code set within the NCPDP standard is not possible, the Committee recommended the continued use of the Universal Product Code (UPC) and the Health Related Item Code (HRI) be allowed.
In general areas of HIPAA implementation, the leadership from the Workgroup for Electronic Data Interchange (WEDI) testified to the Subcommittee on Standards and Security in May 2004. WEDI reported on the healthcare industry's progress from the perspective of the private sector and expressed two general concerns: the importance of pilot testing the standards before their adoption and validating of costs and benefits prior to issuing final rules.
Progress of the DSMO activities was reported to the Subcommittee on Standards and Security by the 2004 DSMO Chair in February 2005. The final HIPAA rule established the new organization under Section 162.910 with the HHS Secretary designating the members to be comprised of three standard data content committees (DCC) and three standard development organizations (SDO). The role of the DSMO is to maintain the standards adopted by the Secretary and to establish criteria for the processes to be used in such maintenance.
The most recent testimony to the Subcommittee on Standards and Security about the healthcare industry's experience with implementing the HIPAA standards was heard April 2005. The hearing provided a forum to report implementation issues with standards for financial and administrative transactions and the national provider identifier (NPI). Testimony included reports of financial results such as early and general perspectives on the industry's return on investment (ROI) after implementing HIPAA and specific recommendations about NPI pre-implementation. Testimony was received from health plans, physician and provider groups, WEDI, health information technology vendors and clearinghouses.
The NCVHS Subcommittee on Privacy and Confidentiality has held many hearings about HIPAA standards since the implementation of the HIPAA Privacy Rule (April 14, 2003-2004). Reported to HHS in March 2004 was feedback from the public and private sectors about the privacy regulation's impact on public health and research, healthcare providers, health plans, and consumers. In general, witnesses reported less anxiety and confusion since passage of the initial compliance date and identified the need to continue expanding outreach and to provide more public education activities so that the rule can be implemented effectively.
An additional series of privacy hearings were held in February and July 2004 and focused on the impact of the rule specific to the areas of banking, schools, law enforcement, fundraising, marketing and media access. A critical issue of whether other privacy laws adequately protect health information held by financial institutions exempt from HIPAA under Section 1179 warranted several recommendations (see full report).
The effect of the privacy rule on schools pertained to the control of health information disclosures by covered entities (such as family physicians) to schools in situations where the information is needed in the school setting. While covered entities under the privacy rule may disclose protected health information (PHI) to public health authorities for public health activities, there is no provision permitting covered entities to disclose PHI to schools for purposes such as for tracking immunizations. Based on the oral and written testimony presented at the hearing, NCVHS made several recommendations (see full report).
Based on limited oral and written testimony about the effect of the privacy rule on law enforcement, the Committee framed its recommendations in the context of drug diversion activities. NCVHS recommended that HHS work with the U.S. Department of Justice's Drug Enforcement Administration (DEA) to educate providers that communicating information about drug diversion or complying with State reporting requirements are permissible under the HIPAA Privacy Rule.
The Subcommittee heard from witnesses who had previously testified about the impact of the privacy rule on marketing. Based on the testimony several areas of concern were highlighted for HHS to explore (see full report).
In addition, testimony was heard about the effect of the privacy rule on fundraising. The witnesses had predicted in previous hearings that prohibiting disclosure of patient service department information would adversely affect the fundraising activities of many nonprofit health care institutions. The witnesses' testimony expressed that their experience with the privacy rule had confirmed their fears about the likely consequences of the Rule. Based on this testimony, NCHVS made several recommendations (see full report).
The most recent HIPAA recommendations to the Secretary in March 2005 by the Committee reflected testimony heard by the Subcommittee on Privacy and Confidentiality on the impact of the Security Rule.
In November 2004 witnesses from the Veterans Health Administration (VHA), the Food and Drug Administration (FDA), and various manufacturers of FDA regulated software and medical devices voiced concerns about the challenges with bringing medical devices into compliance with the Security Rule as well as providing effective security. Based on the testimony NCVHS made several recommendations (see full report).
In addition to a focus on administrative simplification in healthcare, HIPAA directed the NCVHS to study issues regarding electronic exchange of patient medical record information (PMRI). The Committee's 2000 report and subsequent recommendations in 2002 and 2003 served as the foundation for standards to be adopted through the
Consolidated Health Informatics (CHI) Initiative, one of the federal E-Government initiatives established by OMB. The CHI goal is to adopt uniform standards to promote interoperability of clinical information in the federal healthcare enterprise. Recently the CHI activities became part of the Federal Health Architecture (FHA), which is operated by the Office of the National Coordinator for Health Information Technology (ONCHIT).
The NCVHS Workgroup on the National Health Information Infrastructure (NHII) heard testimony about PMRI standards in July 2004 at the second Secretarial HIT Summit and NHII 04 Conference. The Committee made recommendations on September 8, which identified areas where more work is needed to advance the ONCHIT Framework for Strategic Action. Previous NCVHS recommendations are currently being implemented through the FHA activities, which include the adoption of CHI standards. Although these standards apply only to federal healthcare agencies and programs, NCVHS believes that the federal adoption will profoundly impact the private industry by providing the impetus to accelerate the convergence and voluntary adoption of standards in a broader context.
The NCVHS also made significant recommendations concerning standards for electronic prescribing for use in the new Medicare drug benefit, as required by the Medicare Prescription Drug, Improvement and Modernization Act of 2003. Together with HIPAA standards, the e-prescribing standards will help promote interoperability in the nation's health data infrastructure as well as improve the quality, safety and cost effectiveness of patient care.
The Public Health Data Standards Consortium has continued to be a key organization in the implementation of administrative simplification in the public health and health services research arenas.
The NCVHS reaffirms the importance of the HIPAA administrative simplification initiative and urges the Secretary to expedite the publication of the remaining rules. A high level of adoption for the healthcare claims transaction standard has been achieved, although this same level has not occurred for standards in eligibility, enrollment, health claim remittance, healthcare claim status and the coordination of benefits. This low level of adoption has delayed the achievement of efficiencies and industry cost savings with the full economic benefits of Administrative Simplification to be realized only when the entire suite of standards are implemented. In addition, the delays in promulgation of the regulations for provider and health plan identifiers have slowed the realization of expected benefits by the healthcare industry. Congressional support is needed for additional resources to enable the Department to accelerate the promulgation of the remaining HIPAA standards as well as to provide appropriate levels of industry education, which includes efforts to educate the healthcare industry about the Privacy Rule.
This report describes the status of implementation of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA.) The Administrative Simplification provisions (title II, subtitle F of Pub. L. No. 104-191, adding a new title XI, part C, to the Social Security Act (42 U.S.C. 1320d et seq.)) require the Secretary of Health and Human Services (HHS) to adopt standards for the electronic transmission of administrative and financial healthcare transactions, including data elements and code sets for those transactions; for unique health identifiers for health care providers, health plans, employers, and individuals for use in the healthcare system; and for security standards to protect individually identifiable health information. The law also requires standards to protect the privacy of health information.
Congress gave the National Committee on Vital and Health Statistics (NCVHS) the roles of advising the Secretary of Health and Human Services on the adoption of standards, monitoring their implementation, and reporting annually on progress. This report is the seventh of those annual reports on implementation and covers the period January 2004 through April 2005. Previous NCVHS reports to congress about the progress of the implementation of administrative simplification may be found at the committee's web site, http://ncvhs.hhs.gov/.
The Committee has monitored the process of standards adoption and the issuance of proposed standards, as carried out by the Government and its advisory bodies. In addition, now that most of the standards have become finalized and attention turns to their implementation, the NCVHS is identifying and advising on implementation issues.
II. Background About HIPAA Administrative Simplification
To improve the efficiency and effectiveness of the healthcare system, the Health Insurance Portability and Accountability Act (HIPAA) of 1996 included a series of "administrative simplification" provisions that required the Department of Health and Human Services (HHS) to adopt national standards for electronic healthcare transactions. By ensuring consistency throughout the industry, these national standards will make it easier for health plans, healthcare clearinghouses, doctors, hospitals and other healthcare providers to process claims and other transactions electronically. The law also requires the adoption of privacy and security standards in order to protect individually identifiable health information. HIPAA administrative simplification regulations include:
Electronic healthcare transactions and code sets (final rule issued August 17, 2000);
Health information privacy (final rule issued December 28, 2000 and modified August 14, 2002);
Unique identifier for employers (final rule issued May 31, 2002);
Security requirements (final rule issued February 20, 2003);
Unique identifier for providers (final rule issued January 23, 2004);
Enforcement procedures (interim final procedural rule issued April 17, 2003, a proposed rule for policy and procedures for investigations, imposition of civil monetary penalties, and hearings issued April 18, 2005 entitled: HIPAA Administrative Simplification: the Enforcement Rule, and a Notice on March 25, 2005 entitled: Procedures for Non-Privacy Administrative Simplification Complaints Under the Health Insurance Portability and Accountability Act of 1996);
Unique identifier for health plans (proposed rule in development); and
Claims Attachment (proposed rule in development).
Organizations covered by HIPAA Administrative Simplification
In HIPAA, Congress required health plans, healthcare clearinghouses, and those health care providers who conduct certain financial and administrative transactions electronically (such as eligibility, referral authorizations, and claims) to comply with each set of standards. The Medicare Prescription Drug, Improvement and Modernization Act of 2003 (MMA) created a fourth type of covered entity, Medicare discount drug card sponsors. Other businesses may voluntarily comply with the standards, but the law does not require them to do so.
Compliance Schedule
In general, the law requires covered entities to come into compliance with each set of standards within two years following the effective date of the regulation, except for small health plans, which have three years to come into compliance. For the electronic transactions and code sets rule only, Congress in 2001 enacted legislation (Administrative Simplification Compliance Act; Pub. L. No. 107-105) extending the deadline to October 16, 2003 for all covered entities, including small health plans. The legislative extension did not affect the compliance dates for the privacy rule or all subsequent rules that have since followed.
HIPAA Transaction and Code Set Standards
Under HIPAA, HHS must adopt recognized industry standards when appropriate (and as advised by NCVHS). HHS recognized the need for the ongoing maintenance of the HIPAA transaction and code set standards, and especially the need for the industry to collect, review and recommend changes to the standards. The final regulation for transactions and code sets established a set of industry organizations called Designated Standards Maintenance Organizations (DSMOs) to receive and process requests for modifications to standards or for adopting new standards. The DSMO members include three standard data content committees and three standards development organizations.
HIPAA Privacy Standards
In December 2000, HHS issued a final rule to protect the confidentiality of individually identifiable health information. The rule limits the use and disclosure of certain individually identifiable health information; gives patients the right to access their medical records; restricts most disclosure of health information to the minimum needed for the intended purpose; and establishes safeguards and restrictions regarding the use and disclosure of records for certain public responsibilities, such as public health, research and law enforcement. Improper uses or disclosures under the rule may be subject to criminal or civil sanctions prescribed in HIPAA.
After reopening the final rule for public comment, HHS Secretary Tommy G. Thompson allowed it to take effect as scheduled. In March 2002, HHS proposed specific changes to the privacy rule to ensure that it protects privacy without interfering with access to care or quality of care. After considering public comments, HHS issued a final set of modifications in August 2002. Most covered entities were required to comply with the privacy rule by April 14, 2003 with small health plans required by April 14, 2004 to come into compliance, as required under the law.
Employer Identifier
In May 2002, HHS issued a final rule to standardize the identifying numbers assigned to employers in the healthcare industry by using the existing Employer Identification Number (EIN), which is assigned and maintained by the Internal Revenue Service. Businesses that pay wages to employees already have an EIN. Currently, health plans and providers may use different ID numbers for a single employer in their transactions, increasing the time and cost for routine activities such as health plan enrollments and premium payments. Most covered entities were required to comply with the EIN standard by July 30, 2004. (Small health plans have an additional year to comply.)
Security Standards
In February 2003, HHS adopted final regulations for security standards to protect electronic health information systems from improper access or alteration. Under the security standards, covered entities must protect the confidentiality, integrity, and availability of electronic protected health information. The rule requires covered entities to implement administrative, physical and technical safeguards to protect electronic protected health information in their care. The standards use many of the same terms and definitions as the privacy rule to make it easier for covered entities to comply. The rule does not address the use of electronic signatures. Most covered entities were required to comply with the security standards by April 21, 2005, while small health plans will have an additional year to come into compliance.
HHS issued a final rule January 23, 2004 adopting the National Provider Identifier (NPI) as the standard provider identifier to be used in electronic transactions. Most covered entities are required to comply with the requirements of this rule by May 23, 2007, while small health plans have an additional year.
HHS issued two notices regarding enforcement of the HIPAA requirements. In March 2005 the Centers for Medicare and Medicaid Services (CMS) explained its procedures for processing HIPAA Administrative Simplification complaints and in April 2005 the Office for Civil Rights (OCR) proposed new provisions of civil money penalties on covered entities that violate the HIPAA regulations, as well as changes to procedural requirements for penalties issued as an interim final rule in April 2003.
National Health Plan Identifier
HHS is working to propose standards that would create a unique identifier for health plans, making it easier for healthcare providers to conduct transactions with different health plans.
Unique Personal Identifier
Although HIPAA included a requirement for a unique personal healthcare identifier, HHS and Congress have put the development of such a standard on hold indefinitely. In 1998, HHS delayed any work on this standard until after comprehensive privacy protections were in place. Since 1999, Congress has adopted appropriations language to prevent appropriated funds from being used to promulgate such a standard. HHS has no plans to develop such an identifier.
Other HIPAA Administrative Simplification Regulations
A proposed rule adopting a standard for claims attachments was signed by the Secretary and forwarded to the Office of Management and Budget (OMB) in May 2005. Publication is expected this fall.
Federal Government Web Sites for HIPAA Administrative Simplification
In addition to the NCVHS web site, https://ncvhs.hhs.gov/, two other web sites containing HIPAA administrative simplification regulations, frequently asked questions, and other helpful materials are: the HHS Office for Civil Rights, http://www.hhs.gov/ocr/; and, the HHS Centers for Medicare and Medicaid Services.
III. Progress Since Last Report to Congress
Eighteen months after the compliance date for the transactions and code sets rule, progress continues with the implementation of these HIPAA standards. CMS reported to the NCVHS Full Committee in June and September 2004 that the proportion of HIPAA-compliant claims coming into Medicare increased from eighty-six to ninety-seven percent respectively. As of May 2005, the proportion has risen above ninety-nine percent. In addition, over eighty percent of receivers of remittance advice transactions are able to use the HIPAA standard.
Current healthcare industry enforcement for HIPAA compliance is managed by CMS for the non-privacy standards (transactions and code sets, security, etc.) and by the Office for Civil Rights (OCR) for the privacy standards. By May 2005, CMS had received 334 complaints of which seventy-eight percent involved private sector entities as opposed to governmental organizations qualifying as covered. The majority of complaints fell into three categories: compliant transactions rejected, non-compliant transactions sent, and excessive telecommunication fees by trading partner. One hundred-fifty two of the complaints have been closed. CMS monitors all corrective action plans and has determined that most complaints filed are resolved by the involved parties before reaching the point of issuing a corrective action plan.
OCR reports that through the end of April 2005 (two years after the initial privacy rule compliance date) the number of privacy complaints totaled 12,542 of which sixty-five percent were closed. The majority of the complaints deal with health information uses, disclosures and safeguards. Access to information continues to garner a number of complaints followed by complaints of the minimum necessary standards and violations of the authorization standards and notice. Most complaints are filed against provider groups such as private physician practices, general hospitals, pharmacies and outpatient clinics, and group health plans. OCR has made 200 referrals to the Department of Justice (DoJ).
To strengthen HIPAA enforcement two notices were recently posted in the Federal Register. The first notice was posted on March 25, 2005 entitled: Procedures for Non-Privacy Administrative Simplification Complaints Under the Health Insurance Portability and Accountability Act of 1996. It details the procedures for filing a complaint with the Department on non-compliance with the non-privacy HIPAA provisions.
The second notice, a Notice of Proposed Rule Making (NPRM), strengthening enforcement and ensuring uniform rules for the imposition of civil monetary penalties for HIPAA violations was posted on April 18, 2005 entitled: HIPAA Administrative Simplification: the Enforcement Rule. This proposed rule contains new provisions for the imposition by the Secretary of civil money penalties on covered entities violating the regulations, as well as proposing changes to and responding to comment on the procedural requirements for penalties issued as an interim final rule on April 17, 2003. For example, it proposes to amend the existing rules relating to the investigation of non-compliance to make them apply to all of the HIPAA Administrative Simplification rules, rather than exclusively to the privacy standards. It would also amend the existing rules relating to the process for imposition of civil money penalties. Among other matters, the proposed rule would clarify and elaborate upon the investigation process, bases for liability, determination of the penalty amount, grounds for waiver, conduct of the hearing, and the appeal process.
The second round of modifications to the transactions code sets is under development, expected to be published sometime early in 2006.
The compliance date for security rule was April 20, 2005 (small health plans April 20, 2006). CMS was prepared for security complaint submission on that date. CMS and OCR also developed procedures to investigate "dual" complaints, those that involve violations of both the privacy and security rule. A small number of complaints were received during the first several weeks after the compliance date.
CMS is now preparing the system to issue the National Provider Identifier (NPI) for use in the HIPAA standard electronic healthcare transactions. With national standard identifiers healthcare providers will be able to submit HIPAA transactions (eligibility inquiries and responses, claim status inquiries and responses, remittance advices and referral authorizations) to any health plan in the United States. Healthcare providers who transmit electronic health information are required to obtain NPIs, even if they use business associates such as billing agencies, to prepare the transactions. The NPI will replace current provider identifiers used today in HIPAA standard transactions and will eliminate the need for and use of multiple identification numbers by each provider.
The earliest application for an NPI is through a web-based process, which started May 23, 2005. The paper applications for NPI enumeration will begin July 1, 2005. The system began issuing NPIs on May 23, 2005. Healthcare providers are being advised not to begin using the NPI on or before the compliance dates (May 23, 2007 for most covered entities and May 23, 2008 for small health plans) so that health plans may issue their instructions on accepting the NPI transactions.
The proposed rule on standards for claims attachments was signed by the Secretary of HHS and sent to OMB in May 2005. Publication is expected this fall. CMS has funded a pilot test of electronic claims attachment standards developed by HL7 and X12. The pilot is taking place in New York State, involving Empire Medicare Services, and hospitals and physician providers. Results of the pilot test are expected in the fall.
The proposed rule on a National Health Plan Identifier is being developed within HHS with publication expected late in 2005 or early in 2006.
Transactions and Code Sets
In November 2003, the NCVHS recommended that the Department initiate the regulatory process for the concurrent adoption of ICD-10-CM and ICD-10-PCS as HIPAA standards for national implementation as replacements for current uses of ICD-9-CM, Vol. 1, 2 and 3. This recommendation is still under review by the Department.
The NCVHS Quality Workgroup completed a report on Measuring Health Care Quality in May 2004; the report included a number of candidate recommendations for enhancing the data included in the HIPAA claim standard for quality measurement. In November 2004, the NCVHS recommended to the Department that the next version of the Uniform Bill for Hospitals (UB-04) and the ANSI ASC X12N 837I HIPAA Implementation Guide be revised to facilitate reporting of a diagnosis indicator to flag diagnoses that were present on admission in secondary diagnosis fields for all inpatient claims transactions. The National Uniform Billing Committee is developing coding guidelines for implementing this recommendation.
In addition to a focus on administrative simplification in healthcare, HIPAA directed the NCVHS to study issues regarding electronic exchange of patient medical record information (PMRI). The Committee's 2000 report and subsequent recommendations in 2002 and 2003 served as the foundation for standards to be adopted through the Consolidated Health Informatics (CHI) Initiative, one of the federal E-Government initiatives established by OMB. The CHI goal is to adopt uniform standards to promote interoperability of clinical information in the federal healthcare enterprise. Recently the CHI activities became part of the Federal Health Architecture (FHA), which is operated by the Office of the National Coordinator for Health Information Technology (ONCHIT) and lead by Dr. David J. Brailer. Nearly all federal agencies involved in the healthcare industry participate in the FHA. The general partner group has 15 federal departments or agencies participating in the FHA Partner Council with approximately 350 people participating in FHAs e-community.
The NCVHS Workgroup on the National Health Information Infrastructure (NHII) heard testimony about PMRI standards on July 23, 2004 at the second Secretarial HIT Summit and NHII 04 Conference. As a result of testimony from each of the conference break out groups, the Committee made recommendations to HHS on September 8, 2004 (https://ncvhs.hhs.gov/rrp/september-8-2004-letter-to-the-secretary-on-the-health-it-nhii-summit/), which identified areas where more work is needed to advance the ONCHIT Framework for Strategic Action. Previous recommendations included naming a core set of PMRI standards for adoption, a policy of guidance and incentives for encouraging use of the standards, suggestions for mapping among the various terminology standards, and areas for further research. Further suggested was naming the National Library of Medicine (NLM) as the central coordinating body for the PMRI terminology standards. Many of these recommendations are currently being implemented through the FHA activities. NCVHS believes that the federal adoption of the CHI standards will profoundly impact the private industry by providing the impetus to accelerate the convergence and voluntary adoption of standards in a broader context.
HHS Outreach Activities
Within HHS, the Secretary has assigned responsibility for implementation and enforcement of the HIPAA regulations to two organizations: the Office for Civil Rights (OCR) is responsible for the privacy rule and the Centers for Medicare and Medicaid Services (CMS) is responsible for the rest of the administrative simplification standards.
In addition, the NCVHS has a prominent role in monitoring the implementation of HIPAA's administrative simplification standards. Both CMS and OCR have employed extensive multi-faceted outreach strategies to educate the public about HIPAA Administrative Simplification requirements. Elements of the strategy include informative web sites, frequently asked questions, teleconferences, toll free hotlines and targeted technical assistance materials.
The Committee has continued to serve as the Department's primary liaison with the private sector to obtain the views, perspectives, and concerns of the interested and affected parties, as well as their input and advice, on health data standards and privacy. During 2004 and through April 2005, the focus of NCVHS public hearings and committee deliberations about HIPAA Administrative Simplification was on implementation issues, industry readiness, obstacles in achieving successful implementation, and issues relating to implementation of the privacy rule.
The March 31, 2004 NCVHS hearing resulted from a request by the Designated Standards Maintenance Organization (DSMO) membership for the Committee to address implementation issues related to the standard for electronic billing of supplies, issues which were initially raised in 2001. The Committee recommended the continued use of the National Council for Prescription Drug Programs (NCPDP) Telecommunication Standard Version 5.1 for billing supplies consumed or used during the administration of a drug therapy or commonly dispensed through a retail pharmacy channel. When the use of the National Drug Code (NDC) designated standard code set within the NCPDP standard is not possible, the Committee recommended the continued use of the Universal Product Code (UPC) and the Health Related Item Code (HRI) be allowed.
In general areas of HIPAA implementation, the leadership from the Workgroup for Electronic Data Interchange (WEDI) testified to the Subcommittee on Standards and Security on May 26, 2004. WEDI reported on the healthcare industry's progress focusing on private sector issues. Their recommendations were consolidated into issues needing immediate, ongoing and strategic or longer-term attention. WEDI emphasized the need for (1) a continued focus on full compliance while maintaining contingency plans with timelines to "move beyond"; (2) a renewed effort to identify and promote benefits of other transactions and moving toward them (i.e., contingency plans and data content standardization); (3) a requirement for the use of a standard acknowledgement transaction along with more clarity on reporting; and (4) a comprehensive review of coordination of benefits issues, especially the need for a health plan identifier. Other suggestions included developing standardized test data; expediting changes to the standards; addressing standard data content issues more timely; restructuring to a coordinated and annual code set maintenance schedule; and specifying code values on instructions. Strategic issues focus on the need to consider ways of drawing healthcare providers into the standards development process, boosting overall participation in the Standard Development Organizations (SDO), and balancing the DSMO representation. Two general concerns expressed were the importance of pilot testing the standards in order to identify changes needed before their adoption and the validating of costs and benefits prior to final rules.
Progress of the DSMO activities was reported to the Subcommittee on Standards and Security by the 2004 DSMO Chair on February 2, 2005. The role of the DSMO is to maintain the standards adopted by the Secretary and to establish criteria for the processes to be used in such maintenance. The DSMO Chair reported the DSMO process improvements, which covered a period of 16 months and reflected the receipt of 35 change requests for the transaction standards. The monthly volume dropped from eleven to four over this period with twelve requests considered ones that would significantly impact the use of standard and the remainder being simple clarifications. The DSMO did not receive any requests for appeals as opposed to one appeal during the previous annual DSMO report. A significantly lower number of change requests was noted since the last DSMO reporting period (a drop of 63 percent). The reason for this decline was unclear with speculation by the DSMO membership cited as being due to the maturity of the healthcare industry's implementation of the current HIPAA transaction standards and that the requests were being submitted directly to each standards group (DCCs and SDOs) rather than through the DSMO change request system.
The most recent testimony to the Subcommittee on Standards and Security about the healthcare industry's experience with implementing the HIPAA standards was heard on April 6, 2005. The hearing provided a forum to report implementation issues with standards for financial and administrative transactions and the national provider identifier (NPI). Testimony included reports of financial results such as early and general perspectives on the industry's return on investment (ROI) after implementing HIPAA and specific recommendations about NPI pre-implementation.
Blue Cross Blue Shield (BCBS) of Arkansas reported that the cost to implement HIPAA has been greater then originally estimated with the benefits lower then originally projected. Their comparison is based on the 1993 WEDI cost-benefit study, which projected a $29 billion dollar savings over ten years. Arkansas BCBS acknowledged that a greater positive impact will be achieved once providers engage in the full suite of HIPAA transactions, which was also identified within the WEDI report. One area that added to higher implementation costs resulted from the need to run concurrent pre-HIPAA and HIPAA-compliant systems during the extended HIPAA compliance period for standard transactions and code sets. Further testimony from physician and provider groups, WEDI, and health information technology (HIT) vendors and clearinghouses generally supported the correlation between improved ROI and the full or improved implementation of HIPAA transactions.
The American Hospital Association expressed concerns about implementing the NPI standard suggesting an incremental approach and the need for a central authority to effectively respond to questions and concerns about the NPI. It was suggested that the central authority be the source for clear and authoritative responses about general NPI issues and questions, subpart guidance in relationship to federal programs, bulk enumeration procedures, and enumeration progress reports.
The NCVHS Subcommittee on Privacy and Confidentiality has held many hearings about HIPAA standards since the implementation of the HIPAA Privacy Rule (April 14, 2003-2004). The initial hearings held in November 2003 and reported to HHS in March 2004 provided feedback from the public and private sectors about the privacy regulation's impact on public health and research, healthcare providers, health plans, and consumers. In general, witnesses reported less anxiety and confusion since passage of the initial compliance date and identified the need to continue expanding outreach and to provide more public education activities so that the rule can be implemented effectively.
An additional series of privacy hearings were held in February and July 2004 and focused on the impact of the rule specific to the areas of banking, schools, law enforcement, fundraising, marketing and media access. One critical issue addressed was whether other privacy laws adequately protect health information held by financial institutions exempt from HIPAA under Section 1179. After witness testimony, NCVHS recommended the following:
HHS should clarify the nature of the Section 1179 exception for financial institutions when engaged in processing health care transactions. Specifically, clarification is needed from HHS about whether the exception applies to consumer-initiated transactions (e.g., credit card or check payments), covered entity-initiated payment transactions, or both.
Until HHS clarifies the Section 1179 exception, HHS should recommend to health care providers and payers that they use business associate agreements with financial institutions.
Regardless of the technical status of financial institutions under the law and the regulation, HHS should consider whether encryption should be required for Protected Health Information (PHI) moving through the Automated Clearing House (ACH), to ensure that it is available only to final recipients.
The effect of the privacy rule on schools addressed during the February 2004 hearings pertained to the control of health information disclosures by covered entities (such as family physicians) to schools in situations where the information is needed in the school setting. While covered entities under the privacy rule may disclose PHI to public health authorities for public health activities, there is no provision permitting covered entities to disclose PHI to schools for purposes such as for tracking immunizations. Based on the oral and written testimony presented at the hearing, NCVHS recommended the following:
HHS should continue to work with the U.S. Department of Education to clarify how the privacy rule and Family Educational Rights and Privacy Act of 1974 (FERPA) interact with respect to confidentiality of school health records, and where possible to harmonize these regulations and issue guidance.
HHS should make special efforts to focus its outreach and education activities, in a timely manner, on schools, physicians, and State health departments to clear up any confusion regarding the permissible disclosures of health information in the context of dealing with the health needs of students in the school setting.
HHS should regard disclosure of immunization information to schools as a public health disclosure, thereby permitting providers to disclose this information to appropriate school officials without an authorization.
HHS should clarify that disclosure of health information to school health personnel in the context of dealing with the health needs of students is a disclosure for treatment, and thus possible without an authorization.
Based on limited oral and written testimony presented in the February 2004 hearings about the effect of the privacy rule on law enforcement, the Committee framed its recommendations in the context of drug diversion activities. NCVHS recommended that HHS work with the U.S. Department of Justice's Drug Enforcement Administration (DEA) to educate providers that communicating information about drug diversion or complying with State reporting requirements are permissible under the HIPAA Privacy Rule.
The Committee has addressed marketing in several prior hearings and letters to the Department. For this reason the Subcommittee on Privacy and Confidentiality requested that two previous witnesses (the general counsel of the National Association of Chain Drug Stores [NACDS] and a representative of the Georgetown University Health Privacy Institute) address the privacy rule's marketing provisions during the July 2004 hearings. Based on the testimony, NCVHS highlighted three areas of concern to be explored by HHS as follows:
HHS should explore whether to require the disclosure of the financial and other arrangements when covered entities and commercial entities collaborate to approach individuals with recommendations that they utilize specific health care products and services.
HHS should explore whether to require that covered entities and their business associates take specific measures to prevent the incidental disclosure of PHI in communications promoting products and services.
HHS should explore whether it would be feasible and desirable to permit individuals to opt out of further communications regarding products and services.
Also during the July 2004 NCVHS hearings, the subcommittee heard from witnesses who had previously testified about the impact of the privacy rule on fundraising prior to the rule's compliance date of April 2003. The witnesses had predicted that prohibiting disclosure of patient service department information would adversely affect the fundraising activities of many nonprofit health care institutions. In particular, large general hospitals would be unable to target specialized fundraising efforts to patients who were treated, for example, in their ophthalmology or cardiology departments. By contrast, specialty hospitals, by their very nature, would have this information. The witnesses' testimony in July 2004 expressed that their experience with the privacy rule had confirmed their fears about the likely consequences of the Rule. Based on the oral and written testimony, NCVHS recommended the following:
HHS should allow covered entities and institutionally related foundations to use information related to the patient's department of service for fundraising activities without the requirement to secure a patient's authorization.
Department of service information should apply only to broad designations (e.g. surgery, oncology, but not narrower designations), and the privacy rule should retain the prohibitions on disclosure of information relating to diagnosis and treating physician.
The covered entity's notice of privacy practices should inform patients that their department of service information may be used in fundraising, and patients should be afforded the opportunity to decline to permit their department of service information to be disclosed for fundraising or to opt out of all fundraising contacts.
The most recent HIPAA recommendations to the Secretary by the Committee (March 4, 2005) reflect the testimony heard by the Subcommittee on Privacy and Confidentiality about the impact of the Security Standard for Electronic Protected Health Information (Security Rule). In November 2004 witnesses from the Veterans Health Administration (VHA), the Food and Drug Administration (FDA), and various manufacturers of FDA regulated software and medical devices voiced concerns about the challenges with bringing medical devices into compliance with the Security Rule as well as providing effective security. Based on the oral and written testimony, NCVHS recommended the following:
HHS should provide guidance to covered entities to assist them to bring medical equipment into compliance with the Security Rule and to otherwise take appropriate steps to make medical equipment secure (e.g. protection from viruses that may impact the proper functioning of the medical equipment).
HHS should provide clarification regarding the compliance obligations of covered entities with non-compliant and non-upgradeable legacy medical devices. A range of options should be considered based on the nature of the equipment, its replacement cost and life expectancy, patient safety implications, security problems, and the possibility of protecting the security of PHI through other means.
HHS should develop guidance to assist medical device manufacturers to provide medical device functionality consistent with the Security Rule, as well as address reasonable security risks.
HHS should support industry efforts to have medical device manufacturers self report the capability of their medical devices consistent with the Security Rule.
The Public Health Data Standards Consortium has continued to be a key organization in the implementation of administrative simplification in the public health and health services research arenas. During this time period, the Consortium provided input for the development of the next version (5010) of the American Standards Committee (ASC) X12 837 Health Care Service: Data Reporting Guide. The guide provides a standardized format and data content for reporting health care service data that are compatible with the 837 Health Care Claim transaction set standards identified by HIPAA. The guide provides assistance in developing and executing the electronic transfer of health care systems data for reporting purposes to local, State, and Federal agencies that utilize the data for monitoring utilization rates, assessing patterns of health care quality and access, and other purposes required by legislative and regulatory mandates. The new version of the guide provides additional data capability for pay-for-performance initiatives. The Consortium has also served as a vehicle for educating, discussing and disseminating information related to the guide to State and local healthcare organizations and agencies.
IV. Conclusions
The NCVHS reaffirms the importance of the HIPAA Administrative Simplification
initiative and urges the Secretary to expedite the publication of the remaining rules. A high level of adoption for the healthcare claims transaction standard has been achieved, although this same level has not occurred for standards in eligibility, enrollment, health claim remittance, health claim status and the coordination of benefits. The low level of adoption has delayed the achievement of efficiencies and industry cost savings with the full economic benefits of Administrative Simplification to be realized only when the entire suite of standards are implemented. In addition, the delays in promulgation of the regulations for provider and health plan identifiers have slowed the realization of expected benefits by the healthcare industry. Congressional support is needed for additional resources to enable the Department to accelerate the promulgation of the remaining HIPAA standards as well as to provide appropriate levels of industry education, which includes efforts to educate the healthcare industry about the Privacy Rule.


The elections might be over but work for state legislators is just getting underway — Monday is the first day state senators and state representatives can begin filing bills for the 86th legislative session which begins in January.
Among the bills expected to be filed are a few from local lawmakers, including state Rep. Ryan Guillen, D-Rio Grande City, state Sen. Juan "Chuy" Hinojosa and state Rep. Terry Canales, D-Edinburg.
The bills filed by Guillen are expected to focus on boosting funding for the Teacher Retirement System of Texas, increasing teacher pay, property tax/school finance reform, and school safety.
>> A bill relating to the eligibility for the exemption of ad valorem taxation of the residence homestead of the surviving spouse of certain first responders.
>> A bill regarding the use of hypnotically induced testimony during a criminal trial.
>> A bill that would designate May 18 as School Shooting Victim Remembrance Day.
>> A bill regarding the participation of the medical school at the University of Texas Rio Grande Valley in the Joint Admission Medical Program.
>> Enhancements for the prosecution of assaults on federal officers, such as FBI, ICE and Border Patrol agents. Such enhancements already exist for assaults on police officers, public servants and EMS workers.
>> The registration of 3D printed guns with the Texas Department of Public Safety.
>> Requiring prosecutors to explain why they are seeking a prison sentence of a particular length and how much that will cost taxpayers.
>> Prosecuting only for the amount of marijuana in one's possession and not for the container it is in which is allowed under current state law.
>> A constitutional amendment that would require the automatic resignation of a district judge who becomes a candidate for another office when the judge's remaining, unexpired term exceeds a specified period.
>> Preventing an employee from requiring or using a credit report of a potential employee as a condition of employment.
Canales also plans to file a bill on Monday that closes exceptions to the Texas Public Information Act, a goal he tried to achieve during the last legislative session in 2017.
The proposed bill, similar to the bill he filed for the 2017 session, focuses on transparency when it comes to the use of taxpayer funds that are currently allowed to remain confidential under Boeing Co. v. Paxton, a court ruling that allows public entities to keep such records secret if revealing them would place them in a competitive disadvantage.
As the start of the session moves closer, Canales's office will file additional bills targeting voter registration in high schools, penalties for marijuana, modernization for law enforcement training requirements, improvement in data collection on truancy in schools, and — like Guillen — a bill regarding the Teacher Retirement System of Texas. Canales' bill, specifically, would aim to increase the state's contribution toward the TRS.
Several more bills are likely to be filed Monday from the six other legislators representing the Rio Grande Valley at the state level.
The 86th Legislature begins Tuesday, Jan. 8, 2019.


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Baranow is a unique neighbourhood in that it is almost entirely non-residential in character. Commercial and business/industrial land uses predominate and residential land uses are clustered in two distinct areas, one in the far northern portion of the community and one in the south central area of the community. The community is also distinctive based on the high density of its residential land use.
Further, with the exception of a few remnant single detached houses constructed during the 1960s along the eastern edge of the neighbourhood, 96% of all residential units within Baranow were added in the late 1990s and early 2000s. As of 2009 the neighbourhood was still actively under construction, and remaining developable residential lands are located along the eastern border of the community.
A large shopping Centre is located along 137 AVE between 123 and 127 ST. The neighbourhood does not contain any institutional or recreational land uses but residents can access facilities and amenities in the adjacent Carlisle and Caernarvon neighbourhoods.


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Top PDF Preventing youth homelessness: An assessment of local approaches
Preventing youth homelessness: An assessment of local approaches
interviewees argued that it was often difficult to get different authorities to agree to a "shared mission" with clear outcomes, such as focusing on mental health or substance abuse, and to share resources equally to ensure certain authorities are not overburdened. In a similar fashion to homelessness forums, a successful cross-authority partnership requires buy-in from the various authorities and a clear understanding of its aims based on local need. This can be particularly difficult for two-tier authorities working with other districts and county councils, as the number of relevant partners can grow significantly. Statutory obligations and limited resources can affect the ability of local authorities to work together. If a young person in need of housing does not have a local connection, such as living, working or having family in the area, the local authority may refer the relief and housing duty to another authority where the young person has a connection. According to MHCLG's Homelessness Code of Guidance, however, if that person is at risk of domestic abuse or violence, that person should not be referred. 63 Nonetheless,
Preventing youth homelessness : an international review of evidence
It has been useful to consider the range of youth homelessness interventions at both national and local levels using the typology of prevention. The typology reinforces that, to effectively tackle and end youth homelessness, there is a need to consider structural and systemic issues that reach beyond housing. The international evidence review concludes that to be most effective, youth homelessness prevention should involve all five strands of prevention and sets out the areas of each for which there is evidence of effectiveness. It also concludes that research indicates that youth homelessness prevention requires targeted interventions and approaches that account for the distinct challenges that young people face. Some local authorities in Wales are recognising this in the way that they provide services to young people with housing issues, while others take a much more generic approach, expecting young people to access services and projects that are provided for all age groups.
Opening Doors: Preventing Youth Homelessness Through Housing and Education Collaboration
educate the public on the scope, causes, and costs of homelessness, the Strategic Plan, and the reasons for taking action; (ii) engage state, local, and tribal leaders in a renewed commitment to prevent and end homelessness in their communities; (iii) get states and localities to update and implement plans to end homelessness to reflect local conditions and the comprehensiveness of the Strategic Plan, as well as to develop mechanisms for effective implementation; (iv) involve citizens and businesses in efforts to prevent and end homelessness; (v) test, model, and learn more about interagency collaboration; (vi) seek opportunities to reward communities that are collaborating to make significant progress preventing and ending homelessness; (vii) review budget processes to determine avenues for recognizing savings across partners resulting from interventions to prevent and end homelessness; (viii) seek opportunities for engaging congressional committees collaboratively on issues related to preventing and ending homelessness; (ix) collaborate on and compile research to better understand best practices and gaps in research; (x) coordinate federal technical assistant resources and provide service providers with information on how to access the support they need; (xi) make information on best practices and strategies to finance them more readily available; (xii) make information more readily available on working effectively with various sub-populations; (xiii) attend to the unique needs of rural and tribal communities; (xiv) develop and maintain an inventory of federal emergency response programs to help communities identify what is being funded in their community with federal resources and which resources are available to them; (xv) continue to increase and encourage the use of the HMIS, and develop
All efforts to prevent youth homelessness can be strengthened, supported, enforced, and defended through legislation and social policy. Recent international examples include: the Housing (Wales) Act (2014); England's Homelessness Reduction Act (2017); Ireland's National Homeless Prevention Strategy (2002); and Washington State's Homeless Youth Prevention and Protection Act (2015). The Welsh and subsequent English legislation legally require the local council to immediately assist anyone who is homeless or at risk of homelessness, if they are deemed eligible for assistance. While evidence is still emerging, early evaluations of the Housing (Wales) Act (2014) indicate that this policy intervention is successfully decreasing the number of people who are homeless (including youth), as well as reducing the number of people in temporary accommodations (Mackie, Thomas, and Bibbings, 2017). While the specific effects of this policy on youth have not been examined to date, this evidence holds considerable promise for structural youth homelessness
Youth Inclusion and Support Panels : preventing crime and antisocial behaviour?
The ONSET assessment was designed to help panels and keyworkers decide the key targets for intervention, and the ISP should set out the expectations for the child, the family and the service providers. Although relatively few data were available about ISPs on YISPMIS, we were able to see from the quantitative and qualitative information that a range of interventions were offered. These tended to fall into two distinct categories: direct work with children and indirect work on behalf of children. The former included activities for children, one-to-one support, mentoring, and issues-based sessions/programmes. Structured activities such as sports, art, media and computing were popular. Most activities had developmental and social learning aims as well as providing fun and diversion. Keyworkers regarded them as helping to build self-esteem, improve social skills, offer one-to-one attention and enhance the social inclusion of YISP children. Direct one-to-one work was offered in most pilots by the YISP keyworker. All the keyworkers believed that a one-to-one relationship is crucial to the success or failure of most ISPs. However, differences of approach emerged within and between YISPs regarding what were considered to be appropriate interventions. Many keyworkers made use of programmes for addressing risk factors, which they had bought in (e.g. Teen Talk), downloaded from the internet or designed themselves. Some keyworkers stressed that the 'crime and consequences' work, as it was often termed, was only of value when integrated into an ISP which addressed deeper issues, such as family functioning. Deciding whether, and how, keyworkers should be involved in direct service delivery to children and families was an issue with which many pilots had to grapple. Resource and workload considerations resulted in some keyworkers being unable to devote much time to direct work with YISP children. Furthermore, the professional qualifications and practice skills of keyworkers were variable.
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More Than Just A Roof: California State Action Plan to End Youth Homelessness
We know that homelessness takes a serious toll on the lives of youth through increased rates of mental health and substance abuse disorders, unemployment, and lower educational attainment. If California does not act to address this problem, the homeless youth of today will be at greater risk of becoming the chronically homeless adults of tomorrow. Preventing and ending homelessness now is far less costly than paying for the consequences of chronic homelessness later. For these reasons and many more, it is crucial that the State of California pursue strategies, supported by better data collection, to end youth homelessness through prevention, supportive services, and housing. By creating a State Action Plan, we hope to bring together public and private sector partners to exercise leadership and pursue strategies that will prevent and end youth homelessness in California.
Preventing Suicide Through Improved Collaboration for Juvenile Justice Youth
behavioral health disorder (mental health and substance abuse) for which the youth would benefit from an evidence-based treatment intervention (National Council on Disability, 2002). The practice of placing a youth in a juvenile justice setting in order to access these services requires policy and legislative monitoring. Courts need to work closely with public behavioral health, chemical dependency, child welfare, and public education systems to identify accessible interventions that do not require youth to be placed either under the care of the juvenile court or remanded to secure detention in order to access mental health interventions. Court administrators, judges, prosecuting attorneys, and the defense bar need to create facilitated and prioritized access outside of the system for youth needing interventions. Strategies That Relate to Overarching Priority I
This issue of the Notre Dame Journal of Law, Ethics & Public Policy touches on all these categories and the whole range of problems they present.. Professor Kim Hop[r]
Standards checklist for local authorities for providing an effective and safe homelessness mediation service
commissioned Relate to develop a standard model for a service to address relationship breakdown that may lead to homelessness. As a national provider of counselling and mediation services, Relate has a proven track record in helping individuals, couples and families to improve communication, strengthen their relationships and reconcile differences. Relate practitioners are trained to recognise indicators of abuse and violence, and to respond with a model that prioritises the safety of victims and associated children.
'Omic approaches to preventing or managing metastatic breast cancer
DTCs detected [75]. Th e presence of extensive bone metastases has been associated with increased CTC numbers in metastatic breast cancer [76]. A prospective multicenter trial of patients with metastatic breast cancer found that about half of all patients had detectable CTCs using the CellSearch® assay and about 40% were positive using AdnaTest BreastCancer™ [77]. More interestingly, up to half of patients with HER2-negative primary tumors had HER2-positive CTCs. Th is suggests that HER2 status can change during breast cancer progression or relapse and raises the possibility that monitoring of CTCs for such markers could inform targeted treatment of metastasis. Th ere remains, however, a troublingly poor concordance between CTC assay methods. Development of consistent CTC detection methods and standard HER2 (and other biomarker) assessment methods is still needed. Another challenge is that CTCs can lie dormant for years and have been detected in patients with metastasis-free survival over 20 years after primary diagnosis [78]. Th us, simple detection of CTCs alone may not be suffi cient to identify clinically important meta- static disease or determine the correct treatment. Indeed, studies have shown that only a subset of DTCs/CTCs detected are viable and that many are simply terminal or dead tumor cells shed from the primary or metastasis and do not necessarily directly represent metastatic cells (reviewed in [79]).
Homelessness in Liverpool City Region: A Health Needs Assessment.
accommodation that someone might be helped to obtain would include any form of hostel, private rented accommodation, accommodation with friends or relatives, supported lodgings, social housing or low cost home ownership schemes (DfCLG 2013b). Since 2008, local authorities have been required to provide data on the numbers of households for whom casework and positive action took place in order to prevent or relieve homelessness, either by the authority themselves or by a partner organisation (DfCLG 2013b). With a rate of 6.21 per thousand households, levels of prevention and relief in Liverpool City Region were lower than the national average of 8.20 in 2012/13. Within Liverpool City Region, Knowsley (12.09) and Halton (8.62) had levels higher than the national average. Levels in Sefton were lowest, at 2.65 per thousand households (Table 4).
SUPPORTING HEALTHY AND SUCCESSFUL TRANSITIONS TO ADULTHOOD: A PLAN TO PREVENT AND REDUCE YOUTH HOMELESSNESS
5.2 Youth Leadership and Engagement According to the Centre of Excellence for Youth Engagement, youth engagement is meaningful participation and sustained involvement of a young person in an activity, with a focus outside of him or herself. The kind of activity in which the youth is engaged can be almost anything – sports, the arts, music, volunteer work, politics, social activism – and it can occur in almost any kind of setting. Under the Youth Plan, youth will have the opportunity to influence, shape and refine its implementation. They will be key drivers of policy and program improvements, which will be paramount to the Youth Plan's success. Youth have an important role in directing and shaping their own priorities and interests. This role should be facilitated through the Government of Alberta's youth engagement processes to ensure direct linkage to broader public policy initiatives on youth homelessness.
Religious Approaches to Preventing Gender Violence and Sexual Abuse in Nigeria
These religious approaches should be based on traditional moral values, communication and dialogue, love, mutual respect and collegiality spirit to eradicate sexual abuse and gender violence. Any religious leaders or traditions that seek inequality, and promote sexual abuse and gender violence are unforgivable and should be discarded in all ramifications as crime against women. Those who are engaged in education of the Youths and in moulding of public opinions should promote gender equality. This is the only path possible where justice, solidarity, universal brotherhood and sisterhood could be achieved. All religions affirmed the fact that men and women were created equal. Christianity for example, maintains that men and women were created in the image of God to multiply and fill the earth. The book of Genesis 1:27 states thus: "God created man in his image. In the image of God he created him. Male and female, he created them. This identical human nature which appears in the two different forms of male and female indicates that women possess equal human nature perfectly to men before the creator. As a sovereign being, women are not subordinate to man more than they subordinate to them; they are free and independent as the men. Pope John Paul II (1981) asserts that both men and women are human beings to equal degree. The women have full and equal human rights and role both politically, economically, culturally and ecclesial as benefits the human persons. All women and men are individuals worthy of respect and dignity even in terms of sexual rights. Jesus unfailingly respected the human dignity of women and went off his way to help the most vulnerable women.
Victimization and Homelessness: How Collaborative Court Models are Addressing the Needs of Commercially Sexually Exploited Youth
On a large scale, one of the most effective ways to help girls escape involvement within the juvenile justice system is to decriminalize offenses common to girls living in traumatic social contexts, such as prostitution, non-violent school-based offenses, and verbally disruptive behavior. 43 Though many jurisdictions recognize that sexually exploited youth are victims and not criminals and have consequently moved towards decriminalizing prostitution, the majority of states still inflict criminal punishment on survivors of exploitation. 44 Likewise, schools should be held responsible for handling all nonviolent, school-based offenses, such as verbally disruptive behavior, or status offenses, such as truancy. Keeping these offenses within the school district and not involving the delinquency system and its punishment mechanisms could ensure that youth are not punished for typical adolescent behavior.
Preventing Suicide in the North: developing capacity, local knowledge and skills
TABLE OF CONTENTS BACKGROUND i EXECUTIVE SUMMARY POINTS ii SUICIDE CONTEXTS AND EFFECTS 1 AUSTRALIAN SUICIDE STATISTICS Regional Rural and Remote Factors 1 3 QUEENSLAND SUICIDE STATISTIC[r]
Homelessness, Temporary Accommodation and Housing Support Evidence Paper for the Development of the Local Housing Strategy
7.2.5 Data collected internally in 2014/15 as part of the Prevention and Sustainability (PAS) module highlight that around 1,500 people were assessed as having a high level of risk to sustainability and a further 2,227 a medium risk. 1,932 of these cases went on to make a homeless application which therefore suggests that prevention activity is having a limited impact on those seeking assistance. However, it could be that these individuals are presenting in crisis which makes it much less likely that homelessness can be prevented. PREVENT1 statistics published each quarter are being analysed in order to fully understand the reasons why some people go on to make a homeless application and what prevention activity could be completed to avoid the need for a homeless application.
Bone loss: Therapeutic approaches for preventing bone loss in inflammatory arthritis
Synovial fibroblasts in rheumatoid synovium may also con- tribute significantly to localized bone loss. These cells produce chemokines such as macrophage inflammatory peptide 1, regulated-upon-activation normal T cell expressed and secreted, IL-8, and IL-16, which promote lymphocyte infiltration and support lymphoproliferation via secretion of various colony-stimulating factors [21]. This results in a large pool of RANKL-expressing lymphocytes supporting osteoclastogenesis and local bone loss. Furthermore, syn- ovial fibroblasts may directly contribute to local bone destruction by expressing RANKL on their surface [22,23] and by secreting cathepsins [21]. These cells have not been shown to have any bone-resorbing capacity, and any direct role of these cells in bone resorption is unknown. Inflammatory cytokines play an important role in various inflammatory arthritides and associated bone damage. Ele- vated levels of tumor necrosis factor (TNF)-α have been demonstrated by immunoassays in several inflammatory arthritides [24]. TNF-α promotes expression of adhesion molecules, activation of leukocytes, recruitment of leuko- cytes, and production of proinflammatory cytokines (e.g. IL-1, IL-6, and IL-8) in RA. It promotes osteoclastogenesis by stimulating the osteoblasts/stromal cells and possibly T lymphocytes to produce RANKL and M-CSF. In addition, recent in vitro studies have shown that TNF-α, in the pres- ence of M-CSF, directly induces the formation of multinu- cleated cells containing tartrate-resistant acid phosphatase that are fully capable of resorbing bone [25,26]. This effect is independent of RANKL/RANK inter- action and is potentiated by IL-1. The osteoclast progenitor cells have been shown to express both p55
EU local and regional authorities contributing to the mid-term review of Europe Assessment of the "Youth on the Move" flagship initiative
youth employment prospects in the region, a number of projects carried out under Priority IX of the Human Capital Operational Programme not only facilitate the universal access of children and young people to education but also provide an attractive and high quality educational programme via centres of learning. The schools development programmes carried out under these projects help to improve the core competences and key skills needed to enhance students' employment prospects and to continue with their education or start work. Moreover, the project also gives young people educational and careers guidance, information on the benefits of selecting a given educational path, information on further training and educational opportunities in view of local and regional labour market needs as well as schools careers centres. All these measures should help students to plan and follow their own educational and careers path (including helping graduates adapt to labour market requirements). The projects carried out in the regions aim to increase the educational standards and attractiveness of schools and learning centres that organise vocational training to improve their students' employment prospects. These measures will help popularise vocational training as a career path and tailor vocational training to labour market needs (particularly at local and regional level). This will enable the vocational training system to supply the labour market with a greater number of qualified specialists who have the skills that match employers' current requirements. This action also gets employers involved in the vocational training process in a way that goes beyond hands-on teaching of a trade. For instance, this may involve assessing market demand for graduates with a specific skills set. To improve the quality of vocational training, the projects include a number of measures which aim to increase employer involvement in the organisation of work placements and work experience programmes, thereby providing a concrete prospect of employment.
HOMELESSNESS IN INDIA
The phenomenon of homelessness is stated to be one of the poorest forms of urban poverty and social vulnerability. It is largely upsetting and also an impediment within the course of the development of the country, that a large number of poverty stricken people in urban areas are homeless. In a civilized society and an independent India, a large number of individuals, who do not have proper education, employment opportunities, and other facilities that are required for an efficient living are homeless, i.e. they do not even have proper roofs over their heads and have to live on the streets. In this research paper, the concept of homelessness has been studied, the main areas that are taken into consideration are, causes for homelessness, lifestyle of the homeless individuals, problems and difficult situations experienced by homeless individuals, National Policy and housing for the poor homeless and the homeless girl child. Amongst the homeless individuals, women constitute one of the groups that are affected by homelessness on an extreme basis. The individuals who are homeless, encounter numerous problems, they are deprived of human rights and suffer from the most severe kinds of abuses and violence. There have been individuals, who at one point of time, led a good life, had access to educational and employment opportunities, but the occurrence of natural calamities and disasters have left them in a homeless state. It is evident that the circumstances that have led the individuals and families to homelessness are prevalent worldwide and there are absence of tasks that would integrate these homeless individuals into the mainstream society.
An Assessment of the Effect of Entrepreneurship on Youth
Key of those affecting demand of labour were: poor investment climate to foster job creation and informal employment dominance of labour market while for the supply of labour mismatch between higher education graduates and job availability, outdated pedagogic models, imbalance between higher education graduate quality/quantity. Of all the prescribed policy options implemented by AfDB, there was an evaluation emphasising the integration of youths in the labour market, support for private sector value chain initiatives, minimisation of skills mismatch between demand and youth employability as well as the revamping of educational systems to spur innovation and entrepreneurship amongst youths. Central to this crisis is the need of making youth skill readily absorbable by the labour market. This is crucial especially in a situation where the labour market has been saturated and has a slow rate of labour turnover. All the above may just be ad hoc measures if the entrepreneurial classes or absorption capacity of the economy is not efficiently developed.
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Harnessing technology: local authorities
Combating Housing Benefit fraud: local authorities' discretionary powers
Are local government authorities in Australia reporting on sustainability?
The concept and practice of 'enabling' local housing authorities
Homelessness Code of Guidance for Local Authorities

redpajama_set_name: RedPajamaCommonCrawl


In light of the displacement in the north eastern part of Nigeria, NRC is about to start up an emergency response programme in Nigeria to respond to the humanitarian needs.
In the coming months, the main focus for NRC would be conflict affected populations including IDPs, returnees and the local communities in Borno State. NRC will initially be starting activities in the area of food security, water and sanitation and shelter sectors. NRC is therefore seeking a Logistics Officer for the NRC Field Office in Maiduguri, Nigeria for 2015.
Ensure reporting, documenting and payment of staff benefits, social security, taxes etc.
Advice and support line managers staff in HR processes.
Minimum 3 years' experience from working with administration and human resource management in a humanitarian/recovery context.
Relevant university Degree or other relevant educational background combined with relevant professional experience.
Managing resources to optimize results.
High-level competency in computer skills (Microsoft Office applications).
Fluency in one or more of the national/regional languages.
Interested and qualified candidate can submit their application letter and updated CV to:[email protected] . The title of the position (Logistics Officer Maiduguri) must be indicated in the subject line of your e-mail. Please note that only shortlisted candidates will be contacted.


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text:
A collaborative approach between the Ghanaian Government, civil society and business is essential to getting the Millennium Development Goal sanitation target back on track in order to improve the health and prosperity of women in the country. This call comes in a new report jointly published on World Toilet Day by the United Nations hosted organisation Water Supply and Sanitation Collaborative Council, international charity WaterAid and Unilever. The report is published on the first UN recognised World Toilet Day, which serves as a reminder of the 21.6 million people lacking access to an adequate toilet in Ghana, with devastating consequences in particular for the well-being, health, education and empowerment of women and girls in the country.
A collaborative approach between the Ghanaian Government, civil society and business is essential to getting the Millennium Development Goal sanitation target back on track in order to improve the health and prosperity of women in the country. This call comes in a new report jointly published on World Toilet Day by the United Nations hosted organisation Water Supply and Sanitation Collaborative Council, international charity WaterAid and Unilever. The report is published on the first UN recognised World Toilet Day, which serves as a reminder of the 21.6 million people lacking access to an adequate toilet in Ghana, with devastating consequences in particular for the well-being, health, education and empowerment of women and girls in the country. The report highlights the stark consequences for women and girls of the lack of access to toilets. Over four out of five women in Ghana risk shame, disease, harassment and even attack because they have nowhere safe to go to the toilet and 2.3 million Ghanaian women have no choice but to go to the toilet out in the open. This is the first time the three organisations, representing the worlds of business, UN and NGOs, have come together in this way on sanitation. The report brings together real life case studies of people, alongside research from a variety of organisations and agencies that examine the impact of a lack of sanitation on women and girls. In the report, UN Deputy-Secretary General, Jan Eliasson, and Paul Polman, Unilever Chief Executive Officer, declare: "One person in three lacks access to adequate sanitation. The result is widespread death and diseases – especially among children – and social marginalisation. Women are particularly vulnerable. "Poor sanitation exposes females to the risk of assault, and when schools cannot provide clean, safe, toilets girls' attendance drops. "We simply cannot wait. By acting decisively we can now make a positive impact on global health, education, women's safety, social equality and economic growth for generations to come". The report puts forward a number of recommendations including the following: • Governments (of both developing and donor countries) make strengthening the sanitation sector and bringing the Millennium Development Goal target on sanitation back on track an immediate and urgent political priority. • Governments across the world keep their promises and implement the commitments made at national level, regional level (AfricaSan, SACOSAN) and global level (Sanitation and Water for All). Furthermore, they must significantly increase financial resources to the sector, use these resources wisely and ensure that the most marginalised and vulnerable people are targeted. • The post-2015 development framework to succeed the Millennium Development Goals needs to address water, sanitation and hygiene as priority issues, set ambitious targets to achieve universal access to water, sanitation and hygiene, and gradually reduce and eventually eliminate inequalities in access and use. • Sanitation should be integrated into education policy supported by sufficient resources and concrete plans to ensure that: - All schools have adequate sanitation facilities including hand washing facilities and separate toilets for boys and girls with access for students with disabilities. - Specific provision is made at school for establishing proper menstrual hygiene management facilities. - Hygiene promotion is featured as an important part of the school curriculum from primary level. • The role for public private partnerships in addressing the sanitation crisis has been formally recognised. More actors in the private sector must realise the social and business opportunities and invest in social development. More frequent and cross-sector collaboration is essential to achieving real progress. WaterAid Ghana Country Representative, Dr. Afia S. Zakiya, said: "With the current rate of progress, Ghana is currently 118 years off track from meeting the sanitation Millennium Development Goal target , which was due to be completed in 2015. Every year it is estimated that over 1,300 women and girls die from diseases brought about from a lack of access to sanitation and water in Ghana. We can and should be doing better." Jean-Laurent Ingles, Unilever Senior Vice President Household Care said:"We need a concerted effort that combines the experience, knowledge and resources of both public and private sector organisations to bring safe sanitation to hundreds of millions of people. Domestos has over 90 years of experience in toilet hygiene and germ protection and is committed to working in partnerships to help build a 'clean, safe toilet for all'. By doing this we aim to grow our business and help to improve the health and wellbeing of 1 billion people around the world." Dr. Chris Williams, Executive Director, Water Supply and Sanitation Collaborative Council: "Sanitation and hygiene are motors which drive health, social and economic development around the world. An environment that lacks sanitation and clean water is an environment where achieving other development goals is an impossible dream. The time to act is now."Nathaniel Yankson/Global News Reel.