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Health Systems Can Now Validate Their Data Use Methods

Analysis  |  By Eric Wicklund  
   December 07, 2023

A new certification course offered by The Joint Commission will set guidelines for secondary use of data by healthcare organizations

Healthcare executives looking to validate their health system’s data use efforts can now apply for certification from The Joint Commission.

The organization has unveiled a voluntary Responsible Use of Health Data (RUHD) Certification program for US hospitals, including critical access hospitals, which aims to “provide guidance and recognize healthcare organizations navigating the appropriate sensitivities needed to safely transfer data to third-party organizations, also known as secondary use of data.”

The surge in virtual care, digital health, and AI programs, alongside a national effort to identify and address health inequity, puts the emphasis on how healthcare organizations capture secondary data. The Health and Human Services Department’s Office of the National Coordinator for Health IT (ONC) has reported that nearly 85% of all US hospitals now have the ability to export patient data for reporting and analysis purposes, yet many face challenges to integrating and using de-identified data because there are no standards in place.

How a health system uses its data will become even more important as the nation moves toward interoperability, highlighted by the federal government’s efforts to establish TEFCA, including setting up penalties for health systems that block data access by patients.

“As more healthcare organizations are leveraging clinical data for secondary purposes, there have been increased calls to assure responsible data stewardship,” Jonathan Perlin, MD, PhD, MSHA, MACP, FACMI, The Joint Commission’s president and chief executive officer, said in a press release. “The Joint Commission recognizes it can play an important role in validating that robust policies and procedures are in place to help protect, govern and accountably use secondary data. We believe our Responsible Use of Health Data Certification will help healthcare organizations use data responsibly to improve the safety, quality and equity of care, develop new technologies, and discover new therapies benefitting all patients.”

The RHUD certification process follows principles set forth in the Health Evolution Forum’s Trust Framework for Accelerating Responsible Use of De-Identified Data in Algorithm and Product Development, and will focus on six factors:

  • The de-identification process;
  • Data controls;
  • Limitations on use;
  • Algorithm validation;
  • Patient transparency; and
  • Oversight structure.

“The principles established within the Trust Framework are more pertinent than ever for organizations engaging in cross-sector collaboration to propel a new generation of data-powered solutions as artificial intelligence forges a new frontier of innovation and discovery in healthcare,” Richard Schwartz, Health Evolution’s CEO, said in the Joint Commission press release. “The Health Evolution Forum developed the Trust Framework with the intention that its enduring principles will serve as the groundwork for industry-leading organizations and coalitions to build upon this effort and chart the path forward in an ever-evolving technology, regulatory and business environment.”

Eric Wicklund is the associate content manager and senior editor for Innovation, Technology, and Pharma for HealthLeaders.


Some 85% of hospitals now have the ability to export patient data for reporting and analysis, according to the ONC, using that data in everything from AI programs to platforms that address health equity.

The Joint Commission’s new RUHD Certification program aims to set standards for the secondary use of data.

The program covers data de-identification, data controls, limitations on use, validating algorithms, enabling patient transparency, and establishing oversight.

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