Care classifications and Honos+
You are providing detailed information about the registration of data for the care classification. The NZa indicates that, based on the Additional Regulation, the provider registers the following data for care classification:
- Answers to HONOS questions
- Advised care classification type
- Chosen care classification type
- Three elements related to historical care usage.
These data are automatically included in the declaration to the health insurer. According to the NZa: "On the declaration, the care provider only states the chosen care classification type."
These data are provided to the NZa
The NZa states: "Based on an information obligation in the Additional Regulation regarding care classification, the provider provides the following information elements directly to the NZa through a separate data stream (independently from the declaration stream):
- Answers to HONOS questions
- Advised care classification type
- Chosen care classification type
- Three elements related to historical care usage.
Additionally, this data stream contains aggregated information about care usage per month. This data stream does not contain data that can directly identify the patient, such as a name or pseudo-BSN."
The data provided to the NZa are generally not traceable
The NZa says about the potential traceability of personal data: "Viewed in isolation, the information flow for care classification is an anonymized stream, as it does not contain data that can be traced back to the individual. However, for safety reasons, the NZa treats this information flow as a stream containing special personal data. The reason for this is the possibility that a patient from the care classification stream can be linked to a patient from the Vektis data stream that the NZa also receives and which contains a pseudo-BSN. For example, the chosen care classification type is an information element that appears in both streams (Vektis and care classification)."
"In designing the information obligation for care classification, we made choices to minimize the number of unique information elements in both streams. For example, the patient's care usage in the care classification data stream is aggregated per month to limit the linkability to provided consultations in the Vektis data stream."
"Since we treat the care classification data stream as a stream containing special personal data, the privacy statement also applies to this."
The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) has no comments
The NZa indicates that the Additional Regulation was submitted to the Dutch Data Protection Authority (AP) twice to assess whether it complies with applicable privacy laws. The AP indicated both times that they had no comments on the draft regulation. The NZa's Data Protection Officer (Functionaris Gegevensbescherming, FG) also reviewed the documents. The FG acts as an internal supervisor on privacy law within the NZa. The FG provided a positive recommendation to the NZa's Board of Directors when the regulation was finalized.
Difference from providing ROM data
The NZa states, "We are of course familiar with the history surrounding the provision of ROM data to AKWA. Unlike AKWA, the NZa does have a legal basis that allows for the processing of special personal data, and we have used this basis when determining our regulations."
Privacy Statement
If your patient objects to the provision of data to the health insurer for invoicing and to the NZa for policy purposes, the patient can fill out a privacy statement. Data about care classification and diagnosis will not appear on the invoice and will not be provided to the NZa.
Information sourced from LVVP
