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2 Disclaimer This webinar may be recorded. This webinar presents a sampling of best practices and overviews, generalities, and some laws. This should not be used as legal advice. Itentive recognizes that there is not a one size fits all solution for the ideas expressed in this webinar; we invite you to follow up directly with us for more personalized information as it pertains to your specific practice and issues. Thank you, and enjoy the webinar.

3 Upcoming Webinars: 4 Part Series Government Regulations & Ramifications CMS Meaningful Use Audits** EHR Cloning** The Dangers of Information Blocking and Its Effect on Interoperability HITECH Security and HIPAA (December 16) **Recording and slides available online

4 Interoperability and Information Blocking

5 Introductions Lindsey Lanning Healthcare Informatics Coordinator Jeannie Logue Director, Management Consulting

6 Interoperability

7 Interoperability HIMSS AHIMA Interoperability describes the extent to which systems and devices can exchange data, and interpret that shared data. For two systems to be interoperable, they must be able to exchange data and subsequently present that data such that it can be understood by a user. Interoperability is the ability of different information technology systems and software applications to communicate, to exchange data accurately, effectively, and consistently, and to use the information that has been exchanged.

8 Levels of Interoperability According to the HIMSS Board, there are three levels of interoperability: 1. Foundational 2. Structural 3. Semantic

9 Why is Interoperability Important? EHR system interoperability is a necessary step toward transforming healthcare into a system that can achieve goals of improved quality, efficiency, and patient safety. For example, use of interoperable EHR systems could better enable healthcare providers to view results from diagnostic procedures conducted by other providers to avoid duplication; evaluate test results and treatment outcomes over time regardless of where the care was provided to better understand a patient s medical history; share a basic set of patient information with specialists during referrals and receive updated information after the patient s visit with the specialist to improve care coordination; view complete medication lists to reduce the chance of duplicate therapy, drug interactions, medication abuse, and other adverse drug events; and identify important information, such as allergies or preexisting conditions, for unfamiliar patients during emergency treatment to reduce the risk of adverse events.

10 Key Challenges Related to Interoperability 1. A lack of mandated health data standards 2. Differing state privacy rules 3. Accurately matching patients health record 4. Costs associated with Interoperability 5. Need for governance and trust among entities 6. Information blocking

11 Health Data Standards Health data standards are technical requirements used to facilitate health information exchange and interoperability of systems, including EHR systems. A standard provides the fundamental definitions for and structures of the data that can be communicated across a wide variety of use cases. Examples of standards include: Health Level 7 (HL7) version 2 Systemized Nomenclature of Medicine (SNOMED) Logical Observation Identifiers Names and Codes (LOINC)

12 Information Blocking Undermining Health System Interoperability

13 Information Blocking Information blocking occurs when persons or entities knowingly and unreasonably interfere with the exchange or use of electronic health information.

14 Information Blocking This definition requires 3 criteria be met: 1. Interference 2. Knowledge 3. No Reasonable Justification

15 Information Blocking vs. Other Barriers to Interoperability Barriers to Interoperability not considered Information Blocking: Lack of coordination among many persons and entities that participate in or facilitate health information exchange. Persons or entities may implement technical standards in inconsistent ways; Adopt divergent privacy, security, or trust policies that govern how electronic health information is exchanged and used; or Engage in other inefficient behaviors that inhibit or reduce opportunities to exchange and use electronic health information to improve care and care delivery. Inefficient and uncoordinated behaviors do not raise information blocking concerns because they result not from a knowing and unreasonable interference but from larger, systemic barriers to interoperability and health information exchange.

16 Other Barriers to Interoperability Figure 1: Technical, Operational, and Financial Barriers to Interoperability

17 Practices Likely to Cause Information Blocking Contracts, policies, or other practices that restrict access to health information. Charging high fees for interfaces. Developing or implementing health IT in non-standard ways that are likely to substantially increase the costs, complexity, or burden of sharing electronic health information. Developing or implementing health IT in ways that are likely to lock in users or electronic health information; lead to fraud, waste or abuse; or impede innovations and advancements in health information exchange and health ITenabled care delivery.

18 Information Blocking Complaints Most complaints of information blocking are directed at health IT developers. Allegedly charge a substantial per-transaction fee each time a user sends, receives, or searches for (or queries ) a patient s electronic health information. Charge comparatively high prices to establish certain common types of interfaces such as connections to local labs and hospitals. Many providers also complain about the costs of extracting data from their EHR systems for their own use or to move to a different EHR technology. Restrict users of a developer s technology from exchanging health information with users of competing technologies or services.

19 Actions to Address Information Blocking

20 Limit Standards and Implementation Specifications Although there is uniform criteria in place there is still a substantial amount of variability in the underlying required standards, unique clinical workflow implementations, and numerous types of interfaces to connect multiple systems. This variability has contributed to information sharing challenges and also creates opportunities for developers or health IT implementers to erect unnecessary technical barriers to interoperability and electronic health information exchange.

21 Promote Greater Transparency in Certified Health IT Products One of the most effective ways to reduce information blocking is to promote transparency in the health IT marketplace. Providing customers with more reliable and complete information and health IT products and services would make developers more responsive to customer demands and help prevent developers from engaging in behavior that raises serious information blocking concerns.

22 Establish Governance Rules that Deter Information Blocking Many types of information blocking could be mitigated by requiring everyone to adhere to certain basic expectations related to the availability and sharing of information for purposes of patient care. Two principles that will be adhered to regarding trust and interoperability among providers and developers will be: 1. Share Protected Health Information 2. Open Exchange

23 Work with HHS to Improve Understanding of HIPAA in regards to Information Sharing Efforts will be made to improve health IT stakeholders understanding of the HIPAA Rules and how they support interoperable exchange by permitting disclosures of protected health information (PHI) for treatment, payment, and healthcare operations (TPO). To achieve interoperability, all entities regulated by the HIPAA Rules must understand the circumstances under which the Rules permit the sharing of PHI.

24 Promote Competition and Innovation in Health IT and Healthcare The goals of advancing health information exchange and promoting competition and innovation are broadly compatible and will in most cases be aligned. FTC has acquired deep expertise in health IT markets and competition, which, enables it to provide valuable guidance to ONC as it formulates market-based policies and approaches to advance interoperability and exchange.

25 Find Ways to Reward Interoperability Evolving healthcare payment from a volume to value based system could play a significant role in preventing information blocking. Providers paid primarily on a feefor-service basis have incentives not to exchange electronic health information outside their organizations because increased coordination of care can result in reduced volume of billable services (including duplicate and inappropriate services). Under new value-based payment programs, however, providers are increasingly reimbursed based on the health outcomes of individuals and the degree to which providers can reduce the total cost of care while improving healthcare quality and the patient experience.

26 Limitations to Preventing Information Blocking Identifying information blocking is a difficult task that requires access to information about provider or developer business, technical, and organizational practices. ONC has no authority to require providers to produce relevant information (such as contracts with developers). ONC cannot take direct action against providers who block information, and current conditions of participation in federal healthcare programs do not specifically prohibit information blocking. Most information blocking does not violate any current provisions of law.

27 The Government s Focus on Interoperability and Information Blocking

28 The Senate HELP Committee The Senate HELP (Health, Education, Labor, & Pensions) Committee has made interoperability their number one priority. In July of 2015, the Senate healthcare committee conducted a hearing titled, Achieving the Promise of Health Information Technology: Information Blocking and Potential Solutions. On September 16th, 2015 the HELP committee held a hearing on improving interoperability calling on Congress to create standards and advance health data sharing. On October 1st, 2015 the HELP senate committee held a hearing on the promise of health IT where they urged the Office of the National Coordinator (ONC) to fast track the impending release of its roadmap to address the technical standards, certification requirements, privacy/security standards and other initiatives that will enable true HIT interoperability.

29 The House Passes Laws Focusing on Interoperability 21st Century Cures Act Included a section in the act titled, Ensuring Interoperability of Health Information Technology. SGR Repeal Included a section in the act titled, Promoting Interoperability of Electronic Health Record Systems.

30 ONC Interoperability Roadmap On October 6 th, the final ONC Interoperability roadmap was released. The roadmap outlines three broad components to achieving interoperability an alignment of incentives, the necessary technical standards and implementation specifications, and the appropriate governance structures. The roadmap, explains the ONC plan for achieving interoperability across the entire healthcare industry over the next decade.

31 ONC Standards Advisory ONC uses the Interoperability Standards Advisory process to coordinate the identification, assessment, and determination of the best available interoperability standards and implementation specifications.

32 ONC s Information Blocking Report ONC gave a report to Congress that details their findings on the extent and nature of health information blocking as determined by their detailed analysis on this issue gathered through complaints, anecdotes, empirical research, and discussions with industry sources gathered over the last year.

33 2015 ONC CEHRT Certification Criteria To enhance EHR interoperability and health information exchange (HIE), the Office of the National Coordinator for Health IT (ONC) released its 2015 Edition Health IT Certification Criteria. The rule uses various strategies to improve interoperability and the transparency of health IT. To improve interoperability, ONC states that the certification rule will establish a mandatory standard for HIE as well as an updated data export facilitating better access and exchange of information.

34 OIG Policy Reminder On October 6th, 2015 the OIG released a policy reminder titled Information Blocking and the Federal Anti-kickback Statute This special report was meant to remind industry stakeholders of information blocking and the federal anti-kickback statute relative to EHR adoption and use. The OIG warns EHR users of information blocking consequences for EHR interoperability.

35 EHR Vendors Agree to Interoperability Standards On October 2, 2015, a group of 12 leading EHR vendors, agreed by consensus to objective measures of interoperability and ongoing reporting. These leaders proactively stepped forward to have an independent entity publish transparent measures of health information exchange that can serve as the basis for understanding our current position and future.

36 Impact on NextGen

37 Impact on NextGen It is likely that as a condition of attesting for meaningful use in the future, physicians will have to attest that they are not information blocking. While the definition of this practice remains vague, electronic sharing of relevant patient information with physicians inside and outside your health system satisfies your MU obligations in this respect, while improving efficiency and coordination of care. NextGen Share makes it easy to securely exchange information with other providers and is the best way to prove you are not participating in information blocking.

38 How can you share healthcare information right now?

39 NextGen Share NextGen Share was built using NextGen and mirth integration and provides secure connectivity between both NextGen Healthcare and non-nextgen Healthcare providers. NextGen Share supports interoperability across all certified EHR vendors to enable the exchange of clinical information. It includes a searchable provider directory and message translation between supported formats. Providers can exchange clinical data files such as C-CDA files and attachments, referral request letters, and intake notes. Access to these patient files and the ability to share them will improve patient safety and patient health outcomes across the network.

40 NextGen Share is now DTAAP Certified The Direct Trust Agent Accreditation Program (DTAAP) validates and supports compliance with the technical, security, trust, and business practices required for Direct messaging. This certification ensures NextGen Share is meeting the highest data privacy and security standards.

41 Why Use NextGen Share? Meaningful Use Modified Stage 2 requirements Better communication between physicians which means increased care coordination for patients Decrease in in manual data entry

42 Interoperability Objectives Objective 3: Use CPOE for medication, laboratory, and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines. Setup erx with Surescripts Install a lab interface for results via Rosetta Install a radiology interface for results via Rosetta Objective 5: The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral. Setup NextGen Share so it is integrated into the EHR in the referral template and medical summary utility

43 Interoperability Objectives Objective 10: The EP is actively engaged with a PHA or CDR to submit electronic public health data in a meaningful way using CEHRT, except where prohibited, and in accordance with applicable law and practice. Immunization export interface via Rosetta Syndromic Surveillance export interface via Rosetta NextGen Clinical Registry Service

44 NextGen Share and Registries Clients may register intent with these registries for 2015 MU Reporting Testing and implementation dates TBA Pricing is based on what each registry charges American College of Physicians Genesis Registry American College of Physicians Diabetes Registry American College of Physicians Immunization Registry American Academy of Allergy Asthma and Immunology Clinical Data Registry Oncology Nursing Society Quality Improvement Registry American Joint Replacement Registry Orthopedic Quality Resource Center American Gastroenterological Association Clinical Data Registry National Osteoporosis Foundation Quality Improvement Registry Renal Physicians Association Kidney Quality Improvement Registry

45 NextGen s Supported Connectivity elements

46 Mass HIway NextGen has connected to the Mass HIway, marking the opening of a new secure electronic communication channel for healthcare providers in Massachusetts. The Direct messaging connection between NextGen Healthcare and the Mass HIway clearly demonstrates our commitment to enabling the uninhibited exchange of patient data and reaffirms our commitment to data fluidity. Through the deployment of NextGen Share, we are lowering the barriers to data interoperability, and the cost to do so, thereby creating the necessary communications channels to circumvent data blockers while complying with state and federal privacy laws."

47 Lindsey Lanning Questions Healthcare Informatics Coordinator Jeannie Logue Director, Management Consulting

48 Thank you

49

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