Contexture Board Votes to Expand Arizona Permitted Use Policies to Support Public Health

Published On: August 29, 2022

On July 26, 2022, Contexture’s Board of Directors voted to approve changes to Contexture’s Arizona Permitted Use Policies (“PUP”) to expand the Limited Public Health Activities conducted by a Public Health Authority (PHA) that Contexture can support, subject to applicable law and Contexture administrative and technical controls. This policy is effective 30 days from the posting of this notice.

This change aligns Contexture’s Arizona PHA permitted uses with Colorado’s permitted uses and activities permitted by the HIPAA Privacy Rule. Specifically, the revised PUPs permit Contexture to use and disclose data to support a Public Health Authority “that is authorized by law to collect or receive data for the purpose of preventing or controlling disease, injury or disability, including but not limited to, the reporting of disease, injury, vital events such as birth or death, and the conduct of public health surveillance, public health investigations and public health interventions; or, at the direction of a public health authority, to an official of a foreign government agency that is acting in collaboration with a public health authority, see 45 C.F.R. § 164.512(b)(1)(i). Limited Public Health Activities do NOT include fraud and abuse detection activities, provider or facility monitoring, or other health oversight activities or law enforcement activities.

Before this change, Arizona PUPs more narrowly supported the release of HIE data for PHA investigations in response to a voluntary or mandatory public health report into a communicable disease or report of opioid poisoning.

The Limited Public Health Activities will be subject to applicable law and Contexture’s administrative and technical controls. In accordance with HIPAA, the Limited Public Health Activity must be authorized by a state or federal law. Further, proposed public health activities must be reviewed and evaluated for legal compliance through a formal activity intake process conducted by Contexture. Use of HIE data by PHAs will be subject to Contexture’s audit processes, and Contexture will place limitations on HIE data to comply with minimum necessary and fair information practices.

The updated Arizona Participant Policy Manual containing the PUPs for the Arizona HIE is available here.  Please direct any questions to Contexture’s compliance director at

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