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OCS has incorporated procedures to protect the confidentiality of data submitted by clients. These procedures cover data to be included in the OCS Comparative Database (the benchmark data warehouse), and for data forwarded to the Joint Commission on Accreditation of Healthcare Organizations' (JCAHO) for clients participating in the ORYX™ program.

The OCS subscription agreements that are signed by both the participating agency and OCS specifically state that the agency agrees to grant OCS rights to its data to be included “as a component part of the OCS Comparative Database; providing that any and all patients and Licensee identifying information within the Comparative Database products is masked to prevent identification of any individual patient, organization, or group of organizations."

OCS' data confidentiality procedures include:

• All OCS employees sign an acknowledgement form indicating they will perform their duties under the policies outlined in OCS’ HIPAA Compliance Operations Manual, which describes all procedures for handling confidential data.
• All data that is received at the OCS office is stored in a secure location, before being destroyed in a non-recoverable manner.
• All patient identifying information is stripped out of the dataset prior to its being uploaded to the OCS Comparative Database. The patient identifying fields are: Patient ID Number (M0020), Patient Name (M0040), Medicare Number (M0063), Social Security Number (M0064), and Medicaid Number (M0065).

If a client submits their database using the Benchmark Database Submittal Utility (which is part of the OCS-OASIS software), all patient-level data is stripped prior to submission to OCS.

• OCS does not include any patient-level data in any of the benchmark (comparative) reports it produces. All data is aggregated to the agency level.
• OCS does not include any agency-level data in any of the benchmark (comparative) reports it produces. Agencies receive reports that display their own outcome scores compared to aggregated norms, rather than other individual agencies.
• Norms are calculated/displayed only when they are comprised of at least five agencies.

For agencies using OCS as their ORYX program vendor, in addition to the above, OCS also protects data with these following procedures:

• OCS transmits the following data at the agency level, only for the measures the agency has selected: Numerator, Denominator, and Observed Rate.
• OCS transmits the following data at the national level, for all ORYX measures (including data from all agencies submitting to OCS): Numerator, Denominator, Observed Rate, Median, Mean, and Standard Deviation.
• Data transmitted to JCAHO via a dial-up (point-to-point) connection that meets present JCAHO specifications and requirements