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Information Report
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institutions of higher education and other state education agencies, will determine qualified students and provide them free access to all educational services wit
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institutions of higher education and other state education agencies, will determine qualified students and provide them free access to all educational services within the appropriate school district. Security- OHCA's privacy and security policies will be in force for the Exchange. One principle of those policies is that OHCA only collects the minimum necessary information, and only collects information individuals freely agree to provide. The rules engine used for OE, which will be further developed for the Exchange, is adaptable in terms of the information requested. Rather than collecting all information possibly needed on a paper application, the rules engine has the capability to choose the questions presented to a given user based on that user's previous answers, thereby avoiding the collection of irrelevant personal information. The systems and infrastructure developed for OE use data standards, including data transaction standards, that allow for probabilistic matching of data originating from different state and federal agencies. These standards ensure that when OHCA sends a request to the Social Security Administration (SSA), both agencies are requesting and receiving information about the same individual. In the event that a match is made incorrectly, controls are in place that will allow individuals to provide accurate information to correct their records. For example, if data received in a match with the Oklahoma Employment Security Commission (OESC) contradicts data a user reported about him or herself, a notice will be generated advising the member and OHCA personnel that verification is necessary for validation of the information. Security measures in place will comply with federal standards. During the development of the Exchange, security protocols will be implemented and extensively tested at each phase. Given that the information and design necessary to recreate each module of the IT infrastructure of the Exchange will be made available to the public and other states developing their own Exchange, OHCA is committed to reducing and mitigating the risks reverse engineering could potentially pose to the security of the data in motion through the Exchange and the data held in the servers at the foundation of the Exchange. The Systems Development Life Cycle (SDLC) for the Exchange project will include integrated testing and assessments of security systems and risk management protocols. OHCA HIPAA information security policy is readily available online; all electronic information regulated by HIPAA is maintained and destroyed according to regulations. Before individuals access the OE service, they must agree to the statement of rights and responsibilities, which explains that by completing the enrollment process, they are giving OHCA permission to verify the information given with other agencies. The system also includes a timing out feature, which requires users to log in again if the session has been idle; that feature helps protect the security of information users are in the process of entering. Federal Information Processing Standards (FIPS) - Oklahoma State Agencies are already familiar with certain compliance regulations because of our current OE and IO programs. The FIPS, for example, is already being utilized by the Oklahoma Department of Human Services (OKDHS) and OHCA. When a consumer visits either one of these state agency websites, the privacy statement is clear; all consumer/health information is considered private and transferred through secure electronic transactions (i.e. - OHCA uses the SoonerCare Secure Site service). The privacy notice also states that electronic actions of visitors to the site (i.e. - date and time, web pages visited, etc.) will be tracked. The FIPS will be easily transferred over to the Exchange. The IT implementation team will make sure that all privacy standards are met for all stages of the Exchange Interface. The Exchange will use a format similar to the OKDHS' and OHCA's privacy notices to educate the public about the privacy guidelines. The Exchange will 10 5203
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