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Agenda
Paul Wormeli will describe how the Public Safety and Justice domains interact with others, including those encompassed by the National Interoperability Collaborative. He will describe the standards and conventions typically in place in those domains, and will facilitate a conversation about ways to better-integrate their experience, knowledge and tools to support a multi-disciplinary approach to improve health, safety and well-being.
About the presenter
Paul, a former presidential Justice Department appointee, was the founder and first executive director of the Integrated Justice Information Systems Institute (IJIS). He is also a member of the SOC Institute Board of Directors and the author of our recently published Opioid Use Disorder Prevention Playbook.
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Daniel Stein & Dave Walsh
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Comments
Questions (Q), Answers (A) and Comments (C) about justice and public safety information systems and data management
Q: In these design processes, are there established principles that guide designers and stakeholders through the process of distinguishing between use cases in which interoperability is good and desirable, and use cases in which interoperability is potentially harmful and undesirable?
A: Yes, agencies developing case management systems are required in some cases to conduct a Privacy Impact Assessment (PIA) as part of the development process and many agencies do so as a matter of course. Guidelines have also been published by the U.S. Department of Justice Global Information Sharing Advisory Committee to address these issues. See https://it.ojp.gov/global
Q: It’s also my understanding that police are exempted from HIPAA restrictions.
A: the reality is a little more nuanced. See the section on HIPAA exceptions in NIEM Health 102: An Introduction to Security and Privacy of Protected Healthcare Information (http://niem.github.io/health/tutorials/102/)
Q: Is it possible we can anticipate instances in which HHS<>Justice interoperability might make it easier for law enforcement agencies to act in ways that might violate and supersede the purposes of local health information sharing systems? And if so, to what extent should such risks be mitigated and monitored through design of interoperability protocols?
A: Even well intentioned design efforts can fall into this trap. Again, the use of a PIA and Global guidelines can mitigate this risk.
Q: Any thoughts about sharing/integrating this data with behavioral health to improve coordination of care?
A: This area of data exchange is extremely important and has significant implications for reducing recidivism and providing more effective coordination of care. A 2017 report from the Bureau of Justice Statistics noted that 54.3% of prisoners and 35% of jail inmates who had past 30-day serious psychological distress have received mental health treatment since admission to the current facility; and 63% of prisoners and 44.5% of jail inmates have a history of a mental health disorder.
Q: Is there a single identifier that is used to identify a person across all domains -police, corrections, probation, etc or are each domains identifiers just cross referenced?
A: Yes, each offender that is arrested and fingerprinted gets a state identification number and as long as the arrest information is forwarded to the FBI the offender receives an FBI unique identification number associated with the fingerprint submission. The aggregation of criminal history information for a single person is based on biometric matches, mainly on fingerprint comparisons. The FBI or state ID number is used in many places to follow the offender through the criminal justice process. There is no equivalent single ID number for victims and witnesses.
Q: Paul, this is nice news about the use of ontologies! Which public safety ontologies exist so far? Is there a link?
A: Yes, the most comprehensive ontology available today is contained in the National Information Exchange Model (NIEM) and can be accessed at http://niem.github.io/niem-releases/.
Q: I’m sure the reality [of HIPPA exclusion] is nuanced, but the very complexity of the matter suggests a considerable amount of risk that interoperability between systems designed for different purposes, with different legal frameworks, might yield unanticipated and harmful outcomes.
A: Yes, and more extensive and sufficient policies are needed to control the secondary use of data when it is shared across domains, giving rise to the absolute necessity of privacy impact assessments and conformance to the basic privacy principles.
C: and add education when it is a juvenile offender
C: and states are beginning to mandate school level threat assessment teams
C: Recidivism and homelessness, community by community especially amidst our nation's decline in social cohesion.
C: The concept of a single identifier that could be used across many domains is a topic of many arguments (e.g. National Patient Id). The problem with any single identifier such as Social Security Number is that it becomes a high value target for identity thieves. So a better approach is to take the same approach that we often have for user authentication - multi-factor identification. Copying a random set of demographic information such as past addresses or emergency contacts is a lot harder than plucking a single id number.
Q: On the NIC forums, Navah Stein raise some important topics about systemic racism. One of the most important takeaways of those readings, for me, is that the intentions of designers are insufficient when it comes to the evaluating the question of potential harm. I wonder what else can be said about these dilemmas beyond merely referring to the “purpose” of these initiatives.
A: System designers need to be governed by explicit policies covering the definition of what data may be collected in support of a specific government function, how the data must be safeguarded while under the stewardship of a governmental agency and what use may be made of the data beyond the rationale for which it was collected. We have some answers to the policy questions in federal and state privacy laws and policies for the distribution of grant funds.
C: For public health, there are many data sharing barriers that will require changes to laws and policies.
C: Adams County, CO has been successful at info sharing between behavioral health and law enforcement as well
Thanks Paul for your presentation and responses to the questions. I'm interested in also hearing from people and organizations that are effectively sharing information between law enforcement and any other program in another domain e.g. healthcare, education, public health. It would be great to build a library of effective data sharing efforts so others can learn from them.