Readability Analysis of HIPAA Privacy Notices

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Readability Analysis of HIPAA

Privacy Notices

Donna Silsbee, Ph.D., RHIA, CTR, CCS

SUNY Institute of Technology


Research Partners

• Janice Welker, Ph.D. – Health Services Management Program

• Kimberly Jarrell, Ph.D.– Marketing Program


Motivation for Research

• Do Consumers Read and Understand Insurance Disclosures?

– Brenda J. Cude, University of Georgia– 2006 Marketing and Public Policy

Conference Proceedings


Objectives for Today

• At the end of the presentation, the participants will know:– Research questions– Some of the pertinent literature– Methodology used– Preliminary findings– Limitations of the research– Future Plans


Research Questions

• How many hospitals comply with the requirement to post the notice on their web sites?

• What is the readability of the posted notices?


Literature Review

• National Council for Educational Statistics:– 43% read below GED prep level– White and McCloskey (2006)


Literature Review

• Plain Language Principles and Thesaurus for Making HIPAA Privacy Notices More Readable

• HRSA

• 9th grade level – recommended– American general public

– Older Americans would be lower

• http://www.hrsa.gov/servicedelivery/language.htm


Literature Review

• Matthews and Sewell (2002) – Some states require lower levels on

consumer materials:• Minnesota: 7th

• Alabama: 6th

• Nebraska: 4th


Literature Review

• Hochhauser (2003)– 31 notices– 2cd to 4th year college level

• Walfish & Watkins (2005)– 40 academic medical center notices– 65% beyond 12th grade


Literature Review

• Collins, Novotny and Light (2006)– 51 research authorizations – High school or above reading level

• Paasche-Orlow, Jacob, and Powell (2005)– 115 Best Hospitals in America– Average grade level 12.3


Literature Review

• AMIA/AHIMA Joint Position Statement on Health Information Confidentiality

– Use of clear language– Journal of AHIMA (December 2006)


Literature Review

• “What did the doctor say?:” Improving Health Literacy to Protect Patient Safety– Joint Commission (2007) – Use plain language– Address community served


Methodology

• Initial sample:– 4 randomly selected hospitals from

• Each state

• District of Columbia

– 1 hospital volunteered by COP member

– Total = 205 hospitals


Two readability tests used:

• Flesh Reading Ease Test:– Microsoft Office 2003

0 30

Collegegraduates

60 90 100

5th

grade

70

9th grade

http://en.wikipedia.org/wiki/Flesch-Kincaid_Readability_Test


Two readability tests used:

• Flesh-Kincaid Grade Level Formula– Corel Word Perfect X3

– Grades 13-16 = college level


Preliminary Findings

0

20

40

60

80

100

<100 100-199 200-299 300-399 400-499 >500

Figure 1: Number of hospitals by bed size category



Figure 2: Distribution of hospitals by control type

63%

21%

16%

Voluntary, NonProfit

Government

Proprietary



95%

5%

Medical/Surgical

Specialty

Figure 3: Distribution of hospitals by type



Figure 4: Percent of hospitals with posted privacy notices

76%

24%Noticepresent

No notice



Figure 5: Number of privacy notices at each Flesch level of difficulty

16

122

25

050

100150

Verydifficult

Difficult Fairlydifficult

Standard FairlyEasy

Easy Veryeasy


Preliminary Findings:

Figure 6: Number of privacy notices by grade level

8 812 12

6

23

44

27

13 10

0

1020

3040

50

7 8 9 10 11 12 13 14 15 16

HRSA Recommendation


Limitations of Research

• Only used notices posted on the web

• Only used English-language notices

• Some disagreement about value of readability tests


Future Plans

• Increase the sample size

• Use purposeful sampling to develop a sample that more closely matches the general population of hospitals


Reference List

• Collins, N., Novotny, N. and Light, A. (2006) A cross-section of readability of health information portability and accountability act authorizations required with health care research. Journal of Allied Health 35:4, p. 223-225.

• Hochhauser, Mark. Why patients won't understand their HIPAA privacy notices. http://www.privacyrights.org/ar/HIPAA-Readability.htm. (retrieved January 17, 2007)

• Matthews, Trudi and Sewell, Jenny. State Official's Guide to Health Literacy. The Council of State Governments, 2002. http://www.csg.org/pubs/Documents/SOG02HealthLiteracy.PDF (retrieved January 18, 2007)

• Paasche-Orlow, M., Jacob, D. and Powell, J. (2005) Notices of privacy practices: a survey of the health insurance and portability act of 1996 documents presented to

patients as US hospitals. Medical Care 43:6 p. 558. • Walfish, Steven and Watkins, Keely. Readability level of health information

portability and accountability act notice of privacy practices utilized by academic medical centers. Evaluation and the Health Professions, Vol 28, No. 4, 479-486.

• White, S., and McCloskey, M. (forthcoming). Framework for the 2003 National Assessment of AdultLiteracy (NCES 2006-473). U.S. Department of Education. Washington, DC: National Center for Education Statistics.

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