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Insurers seek access to New Hampshire immunization registry for quality reporting; privacy advocates and some patients oppose SB 75

2165258 · January 29, 2025
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Summary

Senate Bill 75 would let health insurers query New Hampshire’s immunization information system to fill gaps in plan records used for quality measurement and member outreach.

A bill to allow health insurance carriers to query New Hampshire’s immunization information system (IIS) drew both support and opposition at a Health and Human Services hearing.

Jennifer Gallagher introduced Senate Bill 75 on behalf of Sen. Rosenwald; she told the committee that carriers seek registry access to help meet National Committee for Quality Assurance (NCQA) accreditation measures and to avoid repeated outreach to provider offices when members have immunizations recorded in the state registry. “The carrier may not always have that information available,” Gallagher said.

Harvard Pilgrim Health Care’s Peter Bragdon told the committee that carriers need accurate immunization data to improve member outreach and to meet quality ratings. He said three‑state access in Harvard Pilgrim’s footprint gives the company better coverage in most states and that not having New Hampshire data particularly affects smaller regional plans. “Allowing health insurance plans to query the state immunization registry will bring efficiency into the system and reduce or eliminate the administrative work required for provider office staff,” Bragdon said.

The Department of Health and Human Services said the IIS platform is opt‑in in New Hampshire and that an enhancement would be required to match insurer member lists to registry records without creating false matches. Anne Marie McCary, immunization section chief, said the department would require a third identifier (for example phone or email) to reliably match records and that a custom code change would be needed — a development the department estimated at about $100,000.

Opponents, including vaccine policy advocates and some patient and privacy commenters, raised broader concerns about registry completeness, privacy, and potential misuse. Laura Condon of the National Vaccine Information Center and public commenters argued that the registry should remain voluntary and warned insurers could use the data coercively; several witnesses urged stronger privacy safeguards and clearer limits on how insurers can use registry data.

Committee members pressed carriers and DHHS on specifics: how often matches would occur, whether insurers would use the data to adjust premiums or coverage (insurers said no), and how many provider offices already report to the registry. DHHS said roughly 400 provider sites currently use the system and the registry has about 1,700 authorized users; registry data remain incomplete because participation in New Hampshire is opt‑in.

Ending: The committee took testimony and asked DHHS and insurers to provide additional technical and privacy information. No vote was taken. If enacted, the bill would require vendor work and funding for a state IIS enhancement, and carriers would be limited to querying only for members for whom they are the plan.