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Breaking Down Silos: State and Local Efforts Now Have Toolkit to Improve Responsible Data Sharing

Mark GreenbergBy Mark Greenberg, Acting Assistant Secretary, Administration for Children and Families

This week we published our “ACF Confidentiality Toolkit.” It’s a document that we’ve been working on for several years. Its goal is to help state and local efforts to understand how and when it is appropriate to share information about a family or individual, in order to provide more effective services, in ways consistent with confidentiality laws and requirements.

This is the latest product of the ACF Interoperability Initiative designed to support improved integration across human service programs and the systems that support them. 

We hope the ACF Confidentiality Toolkit will help state and local efforts by:

  • Providing examples of how confidentiality requirements can be addressed and met in a manner fully consistent with governing laws and underlying policies
  • Including sample Memoranda of Understandings and data sharing agreements
  • Providing helpful guidance for states and localities

For decades, human services agencies have been looking for ways to promote better coordination and collaboration across the human services spectrum. In recent years, advances in technology have given us new opportunities to support what is sometimes referred to as “interoperability.” It is why we created the ACF Interoperability Initiative Project; a collection of collaborative, interdisciplinary information technology projects designed to promote horizontal integration, facilitate shared services, and improve the different systems supporting human services programs, including how well they integrate with health programs.

But developing systems for appropriate sharing of information is not simply a technology challenge. Individual programs often have laws and regulations written to protect the privacy and dignity of individuals and families. These confidentiality provisions serve important public purposes. In some cases, such as domestic violence programs, confidentiality provisions may literally be life-saving. And the rules recognize that a family in need should not have to share their very personal and private information with government agencies as a condition of receiving help.

While confidentiality provisions play a vital public purpose, we understand that the different privacy provisions in different programs can be a significant impediment to state and local efforts to improve service coordination. Sometimes it is unclear whether a particular rule is federal, state or local. Sometimes it may be unclear if there really is a rule or just a long-standing practice. Confusion also sometimes exists about whether or when confidentiality rules can be waived by a client in a particular program.

We hope the ACF Confidentiality Toolkit can support states and localities by bringing greater clarity to the rules governing confidentiality in a set of human service programs by providing both discussion and examples of how these requirements can be met. 

We understand that a single document cannot answer all questions, and that the issuance of this Toolkit will likely lead to new questions and issues that need to be considered. We’re committed to working with states and localities to help in these efforts, and look forward to hearing about successes, challenges, and ways in which we and other federal partners can do more in support of efforts to develop more comprehensive and effective service strategies. 

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