Mendelson Criticizes Proposed HIV Reporting Rules
Dr. Ivan C.A. Walks, Director
Department of Health
825 North Capitol Street, NE, #4400
Washington, DC 20002
Dear Dr. Walks:
I am writing regarding the "Notice of Proposed Rulemaking" published in the December 8th edition of the D.C. Register amending Chapter 2 of Title 22 to require the reporting of social security numbers in addition to the unique numeric code. I find the amendment particularly troubling because it undermines the confidentiality of the "Unique Identifier System" that gained the support of the Council and Mayor back in 1999. Attached is the letter 11 Councilmembers sent Mayor Williams July 27, 1999 opposing any names-based reporting systems and supporting the use of a Unique Identifier System.
As proposed, Title 22 would provide an indirect, but relatively easy name identifying system by incorporating social security numbers into the unique identifying code. Thus, the intention of the Council and the Mayor to thoroughly safeguard individual privacy and encourage early testing would be thwarted. Names-based reporting, both direct and indirect, discourages testing. As an additional result, the accuracy of statistics reflecting the impact of the epidemic in the District will be compromised.
I urge you to do away with the proposed requirement to report social security numbers. Thank you for your consideration.
Councilmember At Large