HTI Reponse to OPM Notice of a Modified System of Records

The Healthcare Trust Institute (HTI) has submitted formal comments to the U.S. Office of Personnel Management (OPM) regarding its proposed expansion of a system of records to collect identifiable health claims data for Federal Employees Health Benefits (FEHBP) and Postal Service Health Benefits (PSHB) program members. While HTI supports OPM’s mission to ensure high-quality, affordable care and effective program oversight, we urge the agency to reconsider this approach. The proposal exceeds statutory authority, risks HIPAA non-compliance by failing to adhere to the “minimum necessary” standard, and unnecessarily centralizes sensitive health data—increasing exposure to cybersecurity threats. Instead, HTI recommends privacy-preserving alternatives, such as edge-server analytics, de-identified aggregated reporting, or partnerships with independent research institutes, that enable robust oversight while safeguarding member trust and data security.

Join HTI

Join a community of committed professionals with Healthcare Trust Institute

Work side-by-side with colleagues from multiple sectors in healthcare to influence data policy by becoming a valued member of the Healthcare Trust Institute. Our community is a vibrant hub of passionate professionals dedicated to driving positive change in the healthcare landscape. As a member, you’ll gain exclusive access to a wealth of resources, including a seat at the table to drive consensus-based recommendations on health data policy, connections to influential policymakers, insightful educational content, and networking opportunities with industry leaders.