Data Exchange Policy for Patients 19 Years of Age and Older

Electronic data submission to NYSIIS for immunizations administered to individuals 19 years of age or older

The New York State Department of Health (NYSDOH) continues the statewide implementation of the New York State Immunization Information System (NYSIIS). NYSIIS is an electronic, web-based system developed to maintain immunization data. Health care providers are required by public health law to report to NYSIIS all immunizations administered to children less than 19 years of age (and past immunizations for that child, if not already reported) within fourteen days of administration.

Immunizations administered to individuals 19 years of age or older may be included in NYSIIS with the express written consent of the vaccinee. A consent form for this population is available on the NYSDOH website http://www.nyhealth.gov/prevention/immunization/information_system/providers/ as well as in the Forms section of the NYSIIS application. All health care providers must take the appropriate steps to collect the necessary consent from individuals 19 years of age or older and must indicate in NYSIIS this consent to share information.

The Health Information Portability and Accountability Act (HIPAA) 45 CFR 164.502(b) imposes a "minimum necessary" standard on health care providers regarding disclosure of information, even when disclosures to the NYSDOH are required for public health activities. For those offices participating in electronic data submission to NYSIIS, the data file that leaves the health care provider's office should only contain information on individuals 19 years of age or older who have given their written consent.

For electronic systems that contain a "consent to share" field, the process used to extract data for submission to NYSIIS must include a check of that field so that only consented records are submitted. The specification for the "consent to share" field is identified in both the flat file ASCII and HL7 formats.

We recognize that some providers' electronic medical record or billing systems may not currently include a "consent to share" field. In these instances, providers should work with their vendors to prevent the submission of ANY electronic data for persons 19 years of age or older. If a practice still desires to utilize NYSIIS for individuals 19 years of age or older who have provided consent to participate in NYSIIS, we recommend that the data for these patients be manually entered into the NYSIIS application until a technical solution to include a "consent to share" field for electronic data exchange can be established.

If you have any questions or concerns, please feel free to call the NYSIIS technical staff at 518-473-2839 or e-mail nysiis@health.state.ny.us .