The Association of Federal Health Organizations (AFHO), representing health benefit plan carriers, opposes the proposed system of records modification that would allow OPM to receive claims data from the OIG. They express concerns regarding data re-identification and HIPAA compliance, recommending alternative methods like OPM-run queries or an "EDGE server" approach to maintain data security.

The Federal Judges Association opposes the Office of Personnel Management's (OPM) proposed modification to its system of records regarding health benefits. They argue that the proposal creates significant security risks for federal judges and their families by creating a centralized repository of sensitive medical information without adequate safeguards or de-identification.

The commenter opposes the proposed pseudonymizing protocol, arguing that it is insufficient to protect the sensitive medical information of federal judges and their dependents. They request that OPM reconsider the proposal to include advanced notice and more robust protections for released information.

The commenter opposes the proposed pseudonymizing protocol, arguing that it is insufficient to protect the sensitive medical information of federal judges and their dependents. They specifically highlight the lack of advanced notice and the absence of protections for information once it has been released.

The commenter opposes the proposed modification of OPM/Central-15, arguing that it converts a program-administration claims warehouse into a broadly shareable government-wide data resource without adequate legal justification or safeguards. They specifically argue that the new routine uses fail the Privacy Act's compatibility requirement, include sensitive clinical data in payment-screening systems, and lack sufficient pseudonymization and oversight.