The Madness Concludes: 2015 Certified Health IT APRIL 29, 2015

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1 The Madness Concludes: 2015 Certified Health IT APRIL 29, 2015

2 Agenda Update on Stage 2 modifications NoMUwithoutMe Advocacy Get involved! ONC s Health IT Certification Rule & Stage 3 Discussion, comment, feedback Upcoming: CPeH comment letters

3 Recap: Modifications Proposed On April 10, CMS released another NPRM proposing changes to Meaningful Use (Stages 1 and 2) Unexpectedly, the NPRM includes drastic changes to the patient and family engagement measures finalized in Stage 2: In , providers need only show that just one patient actually viewed, downloaded or transmitted his or her health information. For secure messaging in , the provider need only show that the function was turned on (patients don t need to send, and providers don t need to reply to secure messages)

4 No Advocacy without CPeH! #NoMUwithoutMe Twitter Takeover at HIMSS 2015! (April 12 16, Chicago) #NoMUwithoutMe Profile picture changes Included in top 17 Tweets of #HIMSS15 Public sign-on comment letter: Dropping to just one patient, and merely turning secure messaging on, signals a drastic change in CMS s expectations of providers and patient engagement. We urge you to reverse these proposed changes immediately. NPWF Action Alert Urge Obama Administration to reverse the proposed changes 4,701 s sent to administration officials

5 When you searched for #HIMSS15

6 No Advocacy without CPeH! #NoMUwithoutMe Coordinated, consumer response Focus on solutions; protecting engagement measures and grow awareness and support for consumer health IT Ideas: Short-term: Reverse Proposals on VDT & Secure Messaging (June 15, 2015) Mid-term: Data Independence efforts, launch event (July 4, 2015) Long-term: Transformed health care system with consumers at the center!

7 ONC s Certification Program To receive an incentive payment, providers must use EHR technology that is certified by ONC Technology is certified to include functionality necessary to accomplish all MU objectives; in addition to Functionalities CMS may not yet (!) require Thus, certification/technical criteria are important levers to secure and advance consumer priorities 2014 Edition CEHRT Stage 2 and/or Difficulties, delays with 2014 Ed. implementation PROPOSED: 2015 Edition CEHRT Stage 3 and 2017/2018+

8 CPeH Influence: Technology Certification ONC previously indicated plans to consider the following consumer priorities in 2015 rulemaking: Patient-specific education resources in the patient s preferred language Clinical quality measures (CQMs) stratified by demographics Transitions of Care Release includes functionalities for structural elements for care plans, patient goals, and health outcomes Patient lists stratified by multiple demographic variables Clinical Decision Support based on demographic data Amendments through patient-generated health data

9 CEHRT: Across the Care Continuum PROPOSED: Move beyond the certification of EHRs to health IT more broadly Other types of HIT: laboratory information systems, health information service providers, health information exchanges (HIEs) Other types of providers: long-term post-acute care (LTPAC), behavioral health, pediatrics Support both public and private programs using HIT e.g. Medicaid and Medicare payment programs, grant programs, private entities and associations

10 Common Clinical Data Set Common Clinical Data Set: Patient name Sex Date of birth Race Ethnicity Preferred language Smoking status Problems Medications Medication allergies Laboratory tests Laboratory values/results Vital signs Assessment/plan of treatment Goals Health concerns Procedures Care team members Immunizations Unique device identifiers for a patient s implantable device MISSING: Notes/narrative Disability status/ functional limitations Sexual orientation & gender identify data

11 Demographics: Race & Ethnicity ONC proposes to use a more granular standard to capture race & ethnicity, the CDC measure. This race & ethnicity code is part of the Common Clinical Data Set. Will be used in transitions/ referrals through Summaries of Care.

12 Demographics: Preferred Language PROPOSED: Adopt new standard for recording preferred language (RFC 5646) Supports written, spoken languages and dialects. Identified as a best practice; most commonly used on the web. Requirement applies to HIT Module presented for certification - not health care providers Expectations for vendor and provider collaboration to tailor implementation to patient population / clinical setting Same preferred language standard used in Common Clinical Data Set

13 Patient-Specific Education Materials: Non-English Languages! PROPOSED: must be able to request patient-specific education resources based on a patient's preferred language identified Focus only on use of Infobutton Infobutton- standard mechanism for health IT systems to request context-specific clinical or health knowledge from online resources No longer require electronic identification of resources based on lab values/results

14 Patient List Creation by Demographics Variable PROPOSED: Must demonstrate capability to use at least one of the more specific data categories included in the demographics certification criterion. E.g. sex, race & ethnicity, preferred language CPeH Previous Comments: EHR technology be capable of using at least two of the specific demographic data categories to generate lists of patients

15 CQM Results: Filtering New! PROPOSED: Record data and filter CQM results at both patientand aggregate-levels by each one and any combination of the following: - TIN - NPI - Provider Type - Practice Address - Insurance - Patient Age - Patient Sex - Race & Ethnicity - Problem List Data Rationale: To identify health disparities and gaps in care for patients being treated at particular group practice sites or ACO Requires ALL combinations to be demonstrated for certification, not just any one. Request Comment On: Additional data elements to consider (and associated standard vocabularies)

16 UDIs: Implantable Devices New! PROPOSED: Ability to record, change, and access a list of unique device identifiers (UDIs) corresponding to a patient s implantable devices Able to parse the following data elements from a UDI: Device identifier Batch / lot number Expiration date Production date; and Serial Number Include a patient s UDI as data within the Common Clinical Data Set

17 Data Portability Intent: Give providers easy access and ability to export clinical data about patients for use in a different EHR or 3rd party system Challenges and poor performance reported with 2014 Ed. Criteria PROPOSED: Create an export summary for a given patient or set of export summaries for as many patients selected Create summary based on relative date/time; specific date/time; when user signs note or order Minimum data set to be included in export summary: Common Clinical Data Set Cognitive status Functional status Reason for referral, referring or transitioning provider s name and office contact information (ambulatory setting only) Discharge instructions (inpatient setting only)

18 Transitions of Care: Patient Matching Adopts updated C-CDA Release 2.0 New Document Templates for: Care Plan; Referral Note; Transfer Summary New Sections for: Goals; Health Concerns; Health Status Evaluation/Outcomes; Functional Status; Mental Status; Nutrition; Physical Findings of Skin. Patient Matching: Proposed standardized data include: Patient matching data collected to identify patient information as data is exchanged in Transitions of Care PROPOSED: Elements - First name; last name; middle name; suffix; date of birth; place of birth; maiden name; phone number; sex. CPeH Previous Comments: matching must include a combination of data elements that work for all individuals due to ethnic/cultural differences E.g. phone number may not apply for all patients

19 Care Plans PROPOSED: Enable a user to record, change, access, create and receive care plan information In accordance with the Care Plan document template in C CDA Release 2.0 Provides structured format for documenting goals, health concerns, health status evaluations and outcomes, and interventions Represents synthesis of multiple plans of care Request Comment On: Require certification of sections currently deemed optional Health status evaluations & outcomes Interventions

20 View, Download, Transmit: Win! Explicit recognition, inclusion of authorized representatives (caregivers!) PROPOSED: Updated Common Clinical Data Set and CCDA 2.0 Make diagnostic images available to patients Provide lab results in accordance with CLIA Includes WCAG 2.0 Level A (accessibility) conformance requirement for view capability

21 VDT ONC Requests Comment On: Should data on encounter diagnoses, cognitive status, functional status, etc. be made available to patients? Testing and certification of this additional patient data Ability to select information for viewing/downloading based on specific date or time Appropriateness of moving to Level AA for certification of the View capability? Additional requirements to ensure open ecosystem around APIs Patient choice of tools, apps and platforms

22 Application Access: Common Clinical Data Set New! PROPOSED: Capability to respond to requests for patient data from other applications Require demonstration of an API that responds to data requests for any one or more of the data in Common Clinical Data Set. Technical outcomes required: Security: API includes means for the establishment of a trusted connection with the application that requests patient data Patient Selection: API includes means for application to query for an ID or other token of a patient s record to execute data requests Data Requests, Response Scope & Return Format: API supports two types of data requests and responses: by data category (i.e., medications) and all (all data categories)

23 Accessibility: Technology Compatibility New! PROPOSED: Opportunity to demonstrate compatibility with at least one accessibility technology for the user-facing capabilities For the clinical, care coordination, and patient engagement certification criteria Would need to demonstrate that it is compatible with at least one accessibility technology that provides text-to-speech functionality to meet this criterion. Request Comment On: Whether criterion would serve as valuable market distinction for HIT developers and consumers

24 Accessibility: Accessibility- Centered Design New! PROPOSED: Require identification of user-centered design standard(s) or laws for accessibility that were applied or complied with in development of Health IT Module Response that no accessibility standard or law was applied acceptable to satisfy criterion May encourage developers to pursue application of more accessibility standards in product development Could lead to improved usability for providers with disabilities and improved outcomes for patients with disabilities Request Comment On: Appropriateness of identified health IT accessibility-centered design standards and laws

25 Patient Information Capture: Advance Directives + More! PROPOSED: Demonstrate that user could record (capture and store) and access (ability to examine or review) health information documents. Broadly applicable to various patient health information documents (i.e., advance directives, birth plans) Health IT must be able to: 1.) Properly identify (label) 2.) Enable a user to record and access information, including information directly and electronically shared by a patient. From multiple sources, including mobile devices. 3.) Reference documents (narrative on where to access) 4.) Link to patient documents (stored on website)

26 Social, Psychological, and Behavioral: Social Determinants of Health New! PROPOSED: Enable a user to record, change, and access patients social, psychological, and behavioral data Financial resource strain Education Stress Depression Physical activity Alcohol use Social connection and isolation Intimate partner violence Also enable a user to record, change, and access a patient s sexual orientation and gender identity as part of certification criteria Include ability to record patient decision not to provide information Self-reporting of information linked to MU PGHD Objective

27 Social, Psychological, and Behavioral Data: ONC seeks comments on Additional data to include (and best available standard)? Should ONC set minimum number of data measures for certification (Minimum one, three, all)? If there should be standardized questions associated with SO/GI data collection? If so, what vocabulary standard would be best suited for these standardized questions? Include industry & occupation information for future editions of certification criteria? Usefulness to providers; current & historical positions

28 Privacy & Security Criteria Criteria unchanged from 2014 edition: Amendments Enables providers to accept or deny requested amendment, and appends it to the patient's record Authentication, access, control, & authorization Verifies identity and allowed types of access and actions person may take Auditable events and tamper-resistance Records specified access to patient data, and prevents disabling of the audit function Accounting of disclosures Records disclosures of patient's data made for treatment, payment and health care operations

29 Privacy & Security Criteria New! Data Segmentation for Privacy Applies to certain health information that has privacy protections stricter than the HIPAA Privacy Rule PROPOSED: Must be able to send documents using document-level tagging Must be able to receive documents tagged with privacy metadata tagging

30 Other: Surveillance & Decertication In-the-Field Surveillance and Maintenance of Certification Already a requirement of ONC Certification Program; previously no specific requirements PROPOSED: Establish certain minimum expectations and procedures for in-the-field surveillance Decertification of Health IT NPRM takes steps to support certification and permits unrestricted use of certified capabilities that facilitate HIE; additional rulemaking necessary to implement authority to issue and terminate certification Request Comment On: Circumstances, due process, remedies other factors to consider re: termination of a certification

31 Reminder: CPeH Comment Letters CPeH Plans for Comment 1.) CMS Stage 2 NPRM (save VDT & secure message!) 2.) CMS Stage 3 NPRM 3.) ONC 2015 Ed. CEHRT Stage 3 comments due May 29, 2015 Goal: Distribute CPeH comment letters for sign-on by Friday, May 22 (save Memorial Day weekend!) Stage 2 comments due June 15, 2014 CPeH comment

32 Get Involved! Contact us: Follow us: Erin Mackay Mark Savage Ali Foti Find us:

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