Implementing Electronic Health Records for Public Health Practitioners & the Public: Ethical Challenges

While some ethical concerns are common to clinical and public health electronic records as expressed in privacy requirements for personal health information (HIPAA), additional ethical and practical challenges intersect in the HIIT implementation of EHRs for public health practitioners and the public. Several may be clarified through addressing specific questions: 1) What ethical framework is selected and why for forming HIIT policy concerning public health EHRs? 2) What is the role of public consultation (involving the public at large) and public values in cocreating policy for EHR implementation beyond clinical EHRs? 3) What ethical and practical challenges for implementation arise due to differing scopes, interests, and legal prescriptions for public health data compared to clinical data embodied in EHRs (e.g., compulsory vs. voluntary submissions, state to state variation, data sunsets, etc.)? 4) What interagency firewall issues must be addressed regarding genetic or other data (e.g. between public health and state and federal bureaus of criminal investigation)? 5) What (intra-agency) access controls for identifiable and disidentified data are required in research and other contexts and what ethical challenges do such present HIIT professionals as data gatekeepers? 6) Are context-specific ethical boundaries considered routine design parameters in HIIT/EHR system design and implementation? 7) What equity considerations do HIIT infrastructure and public health EHR implementations highlight or embody in resource discrepant contexts (urban/rural, developed/developing world)? 8) What are HIIT-specific vulnerable population risks in EHR implementation and how will an HIIT-specific lens on these influence the recursive regulatory process? What institutional support is provided HIIT practitioners to develop (and defend) critical vigilance in issues such as these? Such highlight the ethical import of HIIT disciplines.