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Supervisors table decision on releasing CSN client records to state ASO over HIPAA, indemnification concerns

2396080 · February 26, 2025
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Summary

Muscatine County tabled a request to authorize release of CSN-stored client data to the state and incoming ASO. County staff proposed limiting any transfer to information specified by Iowa Administrative Code; county attorney and supervisors cited HIPAA and indemnification concerns and moved to delay action for further review.

The Muscatine County Board of Supervisors on Monday voted to table a request about sharing client data stored in the CSN case-management system with the state’s new administrative services organization (ASO) and Iowa Department of Human Services (IHHS).

Community Services Director Jessica Bose told the board the ASO has requested upload of all CSN data and that, as of a specified cutoff related to the ASO transition, the county could lose direct access to that information. "We are hopefully going to keep GA and VA because that has years and years of history," Bose said, referring to general assistance and veterans affairs records. She said ISAC (the system manager for many counties) and county staff were still seeking clarity on whether counties could independently purchase continued access.

County Attorney Jim and other supervisors flagged legal and liability risks. Jim said the indemnification language in the proposed waiver/transfer would leave the county responsible if the state or a third party mishandled records: "They are not going to take any responsibility essentially is what I'm seeing in this." He and others noted one county has already refused to release the information citing HIPAA concerns.

Bose said she had edited the release language to limit disclosure to the specific items required by the Iowa Administrative Code for mental‑health advocate records, rather than a wholesale transfer of CSN's contents. Officials stressed limiting the release to only the code‑required fields to reduce exposure.

Supervisor discussion focused on ensuring the ASO or IHHS would certify appropriate data handling. One supervisor said: "I want the ASO to step up and certify that it's going to handle the data correctly," adding concern about losing control once data leaves the county's possession.

After discussion, a motion to table the request carried. Supervisors recommended circulating the county attorney’s marked-up language to regional partners and to the ASO/contract manager (Karoche/Karoch—name as cited in meeting) for further review and agreed to revisit the matter after the regional governing board and CEO meetings later in March.

The item will return to a future board meeting after staff obtains additional legal opinion and clarifies what data must be released under Iowa Administrative Code.