Donald S. Clark
Federal Trade Commission
Room H-159
600 Pennsylvania Ave. NW
Washington DC

January 5, 2000

Re: Advisory Committee on Online Access and Security - Nomination, P004807

Dear Sir,

Healtheon/WebMD hereby nominates Dr. Charles E. Saunders, M.D. to the Federal Trade Commission Advisory Committee on Online Access and Security.

A noted expert on healthcare information technology, Dr. Saunders has played a leading role in information technology planning initiatives for diverse healthcare organizations, including major healthcare insurers, integrated delivery systems, physician practice management companies, hospitals, disease management companies and healthcare product/services companies.

As Vice President and Medical Director for the Healtheon Corporation, Dr. Saunders led the strategic planning and development of Healtheon's entry into the healthcare information technology market. Now that Healtheon has merged with WebMD, one of the nation's largest online healthcare information companies, Dr. Saunders has expanded his new role as Chief Medical Officer to handle the difficult issues of online medical data security and privacy.

From his substantial professional experience, Dr. Saunders is intimately familiar with the policy, technical, and business aspects of handling various types of online data. Healtheon/WebMD frequently deals with two distinctly different data sets, consumer commercial data (such as site traffic, online purchasing records, "click-through" rates, etc.) and personally identifiable medical data (such as can be found in an online medical history record, including illnesses, treatment history, and other highly sensitive information). Since the regulatory requirements and expected standards of conduct vary between commercial and medical data, the company must handle these unique types of data in different ways.

Dr. Saunders has been an integral part of Healtheon/WebMD's regulatory compliance work for medical data. New HHS regulations, for example, will require the company to comply with complex security procedures and strict confidentiality standards for online medical data. Similarly, the company will also have to establish mechanisms that allow for patients to review and correct their online medical data. While the Committee will likely not address medical data specifically, Dr. Saunder's experiences in the online medical data and Internet industries remain imminently applicable to the Committee's consideration of new data security and access processes.

Since the Advisory Committee will also be examining the technological feasibility of its security and consumer access proposals; Dr. Saunders will be able to provide real-world technical expertise to further assist the Committee in its deliberations. Prior to joining Healtheon, Dr. Saunders was a principal in the healthcare consulting practices of A.T. Kearney, Inc./Electronic Data Systems Corporation. While there, Dr. Saunders focused on healthcare payor and provider systems, creating methodologies and leading consulting engagements. His expertise also extends to strategic planning for complex information technology systems, technical assessment, and enterprise re-engineering and benchmarking methodologies.

We believe that Dr. Saunders would be an excellent addition to the Advisory Committee, since he blends a clear understanding of the policy issues with a distinguished technological background that would serve the Committee well. Dr. Saunders understands the commitments necessary for this position and agrees to the terms and conditions for Committee members set forth in the Federal Register. Please find copies of Dr. Saunder's bio and curriculum vitae for your consideration. Please do not hesitate to contact us if you require additional information.

Jeff Arnold Chief Executive Officer WebMD



Healtheon/WebMD Corporation 400 The Lenox Building 3399 Peachtree Road, NE Atlanta, GA 30326 Phone 404.495.7600 Fax 404.495.7822