An Invitation to Responsive Leadership

The Imperative for Enhanced Privacy Practices

Read Full Recommendations here.

Henry Ford Health System (HFHS) serves over four million patients across Michigan. With this reach comes the vital responsibility to lead on patient data privacy, especially during a time when digital threats and data misuse are escalating. Prevention at the Intersections calls on HFHS to immediately implement the full suite of privacy protections outlined in The Imperative for Enhanced Privacy Practices, authored by Dr. Crystallee Crain, with particular emphasis on the Tiered Consent Model.

The Case for Tiered Consent
The Tiered Consent Model empowers patients to determine how their sensitive health information is used and shared. Patients can opt into one or more of the following tiers:

Tier 1: Basic Clinical Care – Data used only for direct care within HFHS. Sensitive information like mental health, substance use, 2SLGBTQIA+ status, or immigration history is kept confidential by default.
Tier 2: Care Network Sharing – Broader sharing within the HFHS network for coordination of care, excluding any Tier 1–locked data.
Tier 3: Research & Quality Improvement – Optional contribution of de-identified data for internal research and care enhancement.
Tier 4: External Data Sharing – Data shared outside HFHS (e.g., public health agencies) only with explicit patient consent.
This model fosters trust, enhances transparency, and aligns with patient-centered care, ensuring autonomy and respect for individual privacy boundaries.

Our Asks
Immediate Pilot Launch
Deploy a 30–60 day pilot program at select HFHS facilities serving high-privacy-concern communities, such as LGBTQ+ clinics, reproductive health services, and immigrant health centers, to test and refine the consent protocols.

System-Wide Implementation
Following a successful pilot, implement the Tiered Consent Model across all HFHS sites, supported by training, infrastructure upgrades, and accountability milestones.

Clear and Transparent Policies
Publish updated privacy policies in plain language with tier-specific consent forms that allow patients to make informed decisions.

Comprehensive Staff Training and Infrastructure Investment
Train all personnel and upgrade electronic systems to support consent tracking, secure data access controls, and appropriate use protocols.

Heightened Protection for Sensitive Data
Codify protections for identity-based and stigmatized health information by defaulting it to Tier 1 and requiring explicit patient consent for any broader sharing.

Ongoing Compliance and Oversight
Develop audit systems, real-time tracking tools, and reporting channels for monitoring consent adherence and privacy incidents.

Long-Term Privacy Commitment
Establish mechanisms for policy review, patient advisory input, and firm restrictions against monetizing or improperly sharing data.

Rebuilding Trust Through Action
HFHS has long been a trusted health leader in Michigan. To preserve and strengthen that trust, especially in vulnerable communities, it must now act decisively. Implementing these reforms is not only ethically sound—it’s necessary for ensuring equitable and trauma-informed care. Patients must never be forced to choose between privacy and health.

Call to Action
We urge HFHS leadership to:

• Publicly commit to adopting the Tiered Consent Model and all associated privacy recommendations; and engage in a community driven process.
• Begin implementation immediately, with community oversight.
• Foster transparency and ongoing engagement with stakeholders.
• Prevention at the Intersections, and others, stands ready to collaborate with HFHS in making Michigan a national leader in privacy-forward, patient-centered healthcare.

In solidarity,
Prevention at the Intersections