Is having a contact person in the manifest essential?

[cooperthompson]

In https://fhir.org/guides/hrsa/uds-plus/StructureDefinition-uds-plus-import-manifest.html

Is the inclusion of the hcContactPerson in the manifest with a required given and family name necessary? The proposed approach has a few side effects:

1. The manifest now contains PII (Personal Identifiable Information), where it wouldn't otherwise.
2. Because of the requirement for given and family name, the implication is that the contact is a specific person, rather than a team. Though I suppose if the contact phone number is for a department-level phone number, even if the specific person is on vacation or there was a staff transition, you'd still be able to contact someone.

[cooperthompson]

P.S. I do consider this a pretty minor issue. Just something that seemed odd to me.

[cooperthompson]

In terms of a proposed approach, I was thinking it might make sense to have the contact information for a health center be identified when the health center is registering for a client ID to use for the submission.

[nbashyam]

Need to discuss with BPHC SMEs, this requirement was levied to mimic the existing EHB approach where there is a contact person that interacts with HRSA when there are issues with the submissions and reporting.

[rachelfried]

The UDS+ Project is collecting PII. The goal is to mitigate collection of PHI based on HHS Safe Harbor.

[nbashyam]

HRSA collects PII for operational purposes but still mandates conformance to the De-identification requirements as per HHS provisions as specified in the IG. So the Contact Name for the Health Center falls under the operations requirement and will be retained in the manifest.