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Data Element Library

Privacy Impact Assessment (PIA) published by CMS as an Operating Division of the U.S. Department of Health and Human Services

Date signed: 9/18/2023

PIA Information for the Data Element Library
PIA QuestionsPIA Answers

OPDIV:

CMS

PIA Unique Identifier:

P-4832795-583884

Name:

Data Element Library

The subject of this PIA is which of the following?

Major Application

Identify the Enterprise Performance Lifecycle Phase of the system.

Operate

Is this a FISMA-Reportable system?

Yes

Does the system include a Website or online application available to and for the use of the general public?

Yes

Identify the operator:

Contractor

Is this a new or existing system?

Existing

Does the system have Security Authorization (SA)?

Yes

Date of Security Authorization

7/19/2023

Indicate the following reason(s) for updating this PIA. Choose from the following options.

PIA Validation (PIA Refresh/Annual Review)

Describe in further detail any changes to the system that have occurred since the last PIA.

Migration to Single Tenant 6/2/2023: Provisioning the single tenant environments using Infrastructure as Code (IaC) with Terraform. IaC supports managing infrastructure with code published on Git and configurations that are tweaked for each environment, instead of using a Graphical User Interface. IaC allows the team to build, change and manage the infrastructure in a safe, consistent, and repeatable way, that can be versioned, reused, and shared. This change supports ADO ownership, total maintenance control and flexibility in making system changes.

Describe the purpose of the system

The Data Element Library (DEL) was developed to support the Centers for Medicare and Medicaid Services’ (CMS) responsibility to implement provisions of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act signed into law on October 6, 2014.  The goal of the IMPACT Act is to support the exchange of information regarding patient care to facilitate coordinated care, improved patient outcomes (quality measurement and the CMS Compare tools), as well as a reduction in provider burden (Patients over Paperwork).  CMS requires the tools listed below be used by certified Medicare and Medicaid providers to ensure patient needs are fully addressed in care being provided, and appropriate documentation is provided at discharge. 

The DEL serves as a database for assessment tools that have been published through public rulemaking. The DEL allows the targeted audience to conduct searches of the assessment tools to examine if there is alignment among each tool’s data elements. It allows access to only the tools themselves, not patient level information. By providing access to the tools, CMS can facilitate discussion among providers to achieve future integration across tools.
 

The targeted audience is Medicare and Medicaid providers, information technology vendors, researchers and others who rely on the post-acute care assessment tools listed below to complete required work for CMS and facilitate CMS compliance with the IMPACT Act. 

The DEL provides access to the following tools: Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI); Long-Term Care Hospital Clinical Data Set (LCDS); Minimum Data Set (MDS) for Nursing Facilities; Outcome and Assessment Information Set (OASIS) for Home Health Agencies; and Hospice Item Set (HIS).

Describe the type of information the system will collect, maintain (store), or share. (Subsequent questions will identify if this information is PII and ask about the specific data elements)

The purpose of the DEL is to centralize the creation, management, and governance of the setting-specific data elements and to publish the relational mapping of the data elements across the instruments and to national Health Information Technology (HIT) vocabulary standards. The DEL provides capabilities that promote standardization across settings and interoperability of data elements by mapping data elements to HIT standards. It is accessible by both CMS and public users, with separate levels of access for each.

The system does not collect, maintain, or store PII/PHI.

DEL User credentials are used to access the system and are stored temporarily within HCQIS Access Roles and Profile (HARP) in accordance with the CCSQ Records Schedule and File Plan. DEL system users access a separate system, HARP Entitlement Requester Application (HERA) to obtain access to DEL.

Provide an overview of the system and describe the information it will collect, maintain (store), or share, either permanently or temporarily.

The DEL is the centralized resource for CMS’s required Long-Term and Post-Acute Care (LTPAC) assessment instrument data elements (e.g., questions and their response options) and their associated mappings to health information technology standards.

DEL Goals include: To facilitate the maintenance of CMS assessments and quality measures; To serve as a centralized resource for LTPAC assessment data elements; To promote the sharing of electronic LTPAC assessment data sets and information standards; To influence and support industry efforts to promote Electronic Health Record (EHR) interoperability and care coordination.

DEL system does not collect user credentials from system and database administrators, CMS employees and direct contractors. DEL system users access a separate system, HARP Entitlement Requester Application (HERA) to obtain access to DEL

Does the system collect, maintain, use or share PII?

No

Identify the publicly-available URL:

https://del.cms.gov/DELWeb/pubNavSearch 

Does the website have a posted privacy notice?

Yes

Is the privacy policy available in a machine-readable format?

Yes

Does the website use web measurement and customization technology?

No

Does the website have any information or pages directed at children under the age of thirteen?

No

Does the website contain links to non-federal government website external to HHS?

No