Electronic Health Record Enclosure 3
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- Bennett Whitehead
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1 Dedicated to the Health Of the Whole Community Mental Health Department Mental Health Services Act Capital Facilities and Technological Needs Electronic Health Record Enclosure 3 April 2, 2009
2 Mental Health Services Act Capital Facilities and Technological Needs Electronic Health Record - Enclosure 3 Guide to Packet Contents: Project Proposal Exhibit 1 Face Sheet Project Proposal Exhibit 3 Executive Summary Technological Needs Project Proposal Description Appendix A Project Risk Assessment Project Plan Project Proposal Exhibit 4 Budget Summary Project Proposal Exhibit 5 Stakeholder Participation
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4 Electronic Health Record (EHR) Executive Summary Project Type: Purpose: Overview: Need: EHR System Project To provide a comprehensive electronic medical record for consumers that can be shared in a secure and integrated environment across service providers. This project will: Reduce paper medical charts and provide an electronic mechanism to securely share critical client treatment data with all providers in the network; Improve coordination of care between providers of services through integration of data; Provide opportunities to reduce costs by streamlining and automation of clinic operations; Produce better treatment outcomes because of better coordination of care and integrated treatment protocols. Once completed, the EHR project will provide an integrated system for all administrative and clinical consumer information. Treatment plans, assessments and progress notes will be recorded and securely maintained electronically. Appointment scheduling, lab orders and medication prescribing will be done online. Client registration and all forms normally completed during intake, including medical histories, will be attached to the electronic medical record and will facilitate coordinated treatment. The full EHR will support a secure, web based Personal Health Record (PHR) for consumers and their families with web-enabled interface for appointment scheduling and clinician communication. The EHR is mandated by Federal, State and Local initiatives. The Federal Executive Order requires everyone to have an electronic health record by The Governor of California has backed this deadline with an Executive Order. SCVHHS has set a goal of switching to EHRs by The EHR will reduce paperwork and eliminate paper patient charts. This initiative will promote administrative efficiency and has been shown to be cost effective through national studies. EHRs improve patient safety and promote coordination of care amongst multiple providers. EHR Exhibit 3 Page 1
5 Project Management: The EHR is a complex project and Independent Project Manager (IPO) will be selected to oversee the implementation of the EHR. In addition, a Project Manager will be designated internally to guide the project. The Project Manager will oversee a thorough project planning process that will result in a Project Charter, Project Organization Chart and Project Work plan. The organization process will also establish a communication plan, a risk management plan and an issue management plan. Appropriate advisory and governance boards will be defined with representatives from across the organization and provider network. The Project Manager will be accountable to the Project s Executive Sponsor, IPO and Project Director(s). The Project Manager will be responsible for delegating responsibility Resources: Technical Considerations: Staff: SCVHHS existing resources will lead the project and form the project team. Supplemental staff consisting of selected vendor, contracted staff, IPO project management oversight, and additional development, interface, implementation, testing, user acceptance testing, documentation, migration, report development, training and associated technical and support resources will be required and are documented in the budget. Equipment: Dedicated hardware will be required which will include servers, storage devices and other associated hardware. Provider needs for additional PCs and printers will be analyzed and incorporated into the project during the planning and design phases of the project. Software: Off-the-shelf commercially available (COTS) software will be utilized when ever possible for the EHR. Technical support will be provided by SCVHHS IS and vendor(s) resources, as appropriate, and will conform to SCVHHS IS standards. Security administration will be centralized within SCVHHS IS and adhere to their existing standards. Timeline: September 2008 December 2014 Estimated Cost: $13.6 million EHR Exhibit 3 Page 2
6 Enclosure 3 Exhibit 3 Technological Needs Project Proposal Description County Name: Santa Clara Date: 03/26/09 Project Name: Electronic Health Record Check at Least One Box from Each Group that Describes this MHSA Technological Needs Project New System. Extend the Number of Users of an Existing System. Extend the Functionality of an Existing System. Supports Goal of Modernization / Transformation. Support Goal of Client and Family Empowerment. Indicate the Type of MHSA Technological Needs Project > Electronic Health Record (EHR) System Projects (Check All that Apply) Infrastructure, Security, Privacy. Practice Management. Clinical Data Management. Computerized Provider Order Entry. Full Electronic Health Record (EHR) with Interoperability Components (Example: Standard Data Exchanges with Other Counties, Contract Providers, Labs, Pharmacies). > Client and Family Empowerment Projects Client / Family Access to Computing Resources Projects. Personal Health Record (PHR) System Projects Online Information Resource Projects (Expansion / Leveraging Information-Sharing Services) > Other Technological Needs Projects that support MHSA Operations Telemedicine and Other Rural / Underserved Service Access Methods. Pilot Projects to Monitor New Programs and Service Outcome Improvement. Data Warehousing Projects I Decision Support. Imaging / Paper Conversion Projects. Other. EHR Exhibit 3 Page 3
7 > Indicate the Technological Needs Project Implementation Approach Custom Application Name of Consultant or Vendor (if applicable): Commercial Off-The -Shelf (COTS) System Name of Vendor:. The EHR will be a COTS system that is capable of meeting the CA DMH Medi-Cal and MHSA reporting systems. Product Installation Name of Consultant or Vendor (if applicable): To be determined during the planning and design phase of the project. Software Installation Name of Vendor: To be determined during the planning and design phase of the project. EHR Exhibit 3 Page 4
8 Full Electronic Health Record (EHR) Project Introduction to Santa Clara County Organization and Its Acronyms The Santa Clara Valley Health and Hospital System (SCVHHS) is the Santa Clara County organization that manages, operates and directs all healthcare services within the County. It is an umbrella organization comprised of the following organizations: The Valley Medical Center (VMC) Public Health Department (PH) Department of Alcohol and Drug Services (DADS) Mental Health Department (MHD) Children s Shelter and Custody Health Services (CSCHS) Valley Health Plan (VHP) Community Outreach Programs o School-Linked Services System (SLS) o Valley Children s Health Initiative (Valley CHI) o Community Health Services (CHS) SCVHHS has a centralized Information Systems Department (SCVHHS IS) that supports its organizations. In addition, Santa Clara County has a centralized Information Systems Department (ISD) that provides network and computing services to all County agencies. Project Management Overview The Electronic Health Record (EHR) Project is an integral part of the MHD strategic plan to modernize and transform clinical and administrative systems to ensure quality of care, parity and operational efficiency and effectiveness. A fully interoperable EHR with Personal Health Records (PHR) must be in place by 2014 to achieve compliance with both Federal and State requirements. This project will entail selecting and implementing a commercially available off the shelf software (COTS) product that will give SCVHHS an EHR for all of it MH clients. SCVHHS has an internal goal to complete this by MHD is currently assessing their Uni/Care system to determine if it can continue to meet its needs in the future and meet the federal, state and local mandates for EHR implementation. MHD is not using all of the available functionality that Uni/Care provides. The assessment is part of this project. The outcome of the assessment is not known at this time, but should MHD decide that another existing product would better meet their future needs, MHD will issue an RFP for a replacement system. The RFP will be developed and issued in accordance with Santa Clara County procurement rules. EHR Exhibit 3 Page 5
9 If MHD decides to remain with Uni/Care, they will re-implement the system enabling full EHR functionality to their clinics and treat it as if it they were implementing a new system. The EHR project is considered a high risk project. Determination of requirements, problem resolution, implementation, testing, determination of workflow changes, hardware and software changes in a volatile environment all contribute to the challenges that will be encountered. In addition the project is further complicated by intense training requirements across the service system and must be performed without diminution of consumer treatment, care and administration of operational programs. Since these types of projects can often lose energy and focus, MHD will create a project structure and methodology that will mitigate the risk. Independent Project Oversight The MHD will bring in an independent consultant (IPO) to oversee the project for its duration. The IPO will review all project documentation and meet at regularly with the Project Steering Committee. In between meetings the IPO will have weekly contact with the Project Manager to discuss issues and progress. The IPO will provide a monthly report containing their assessment of the health and progress and report any areas of concern related to the project. The primary responsibility of the IPO will be to see the successful implementation of the Project. They will be recognized as a project team member who will identify risks and risk mitigation strategies based on their experience. They will be able to contribute to problem resolution and be recognized by all participants as an authority on the health of the project. As such, they must be ready to recommend termination of a failed project and send up adequate warnings in advance of a potential disaster. The IPO will be an experienced professional, knowledgeable about the business operations of a public sector Mental Health organization and experienced in information technology project management. They will ensure that a standard project management methodology is utilized and that all documents are completed as requested. Project Management The Project Manager assigned to each of these projects will be responsible for organizing, documenting, communicating and managing the project. They will use a standard project management methodology and maintain an accurate project plan in MS-Project. The Project Manager will be responsive to the IPO and work collaboratively with them. The Project Manager will assign tasks and deadlines to resources as necessary to ensure success. The IS Manager and the Project Manager assigned to this project have experience with EMR implementations. The IS Manager has been involved in the Uni/Care implementation from the beginning and will continue to be involved in this project. The Project Manager gained valuable experience with the SCVHHS Ambulatory EMR project. The Project Manager will see that, at a minimum, the following will be created and EHR Exhibit 3 Page 6
10 maintained for each project: A Project Charter A Governance Body incorporating appropriate stakeholders A Project Organization Chart A Project Plan (including critical path and work breakdown schedule) A Project Communication Plan An Issue Management Plan A Risk Management Plan A Project Steering Committee A Project Dashboard Report to be submitted to the Steering Committee monthly A Monthly Project Status Report A Quarterly Project Status Report to the State DMH The Project Manager will be accountable to the Project s Executive Sponsor, IPO and Project Director(s). The Project Manager will be responsible for delegating responsibility or directly managing the following aspects of the project: Project Aspects Tasks Integration Management Delegated as appropriate Incorporated into the test plan for each project Scope Management Responsibility of the Project Manager Use Project Plan and Project Charter to manage Changes to scope will be addressed in the Issue Resolution Management Plan. IPO will monitor changes Time Management Responsibility of the Project Manager Use Project Plan and Project Charter to manage IPO will monitor timelines and deadlines Cost Management Responsibility of the Project Manager IPO will require monthly budget reports EHR Exhibit 3 Page 7
11 Project Aspects Tasks to monitor Part of the project dashboard presented monthly to the Steering Committee Quality Management Delegated as appropriate Governance Board will review and direct Indicators will developed and be incorporated into the test plan and user acceptance criteria Human Resource Management Responsibility of the Project Manager FTEs will be responsible to the Project Manager for this project and to their assigned supervisor. Consultants will be managed by the Project Manager. Project Manager will coordinate any vendor staff. Communications Management Responsibility of the Project Manager Delegated as appropriate Managed using the Communications Plan prepared during the Planning Phase of the project Procurement Management The Project Team, Governance Body and County procurement officers will work collaboratively to obtain any necessary hardware, software or other resources. Delegated as appropriate This project will entail selecting and implementing a COTS software product that will give SCVHHS an EHR for all of it MH clients. This project includes: Assessment of the functional components of the current transaction system is the first step in the project management. SVCHHS MHD must assess the current functionality and compare it to the new requirements for a full EHR. The process will require, at a minimum: Definition of requirements Identification of compatibility with current system Definition of hardware and/or software purchases or upgrades Determination of vendor, staff or other supporting resources needed to successfully implement, and; EHR Exhibit 3 Page 8
12 Identification of on-going maintenance staff and resource needs. Assessment of the functionality of the current system vendor. IS and MHD are jointly assessing their current system, Uni/Care, and may yield a decision that the current transaction system and available functionality is not the best choice for MHD, in which case, the assessment process will require the following: Development of a procurement RFP Letting of an RFP for a County approved procurement cycle. Selection and activation, procurement or purchase of enhancements to the current transaction system, or selection and contract development for a new system. Implementation Planning will be necessary whether additional components are added to enhance the current transaction system, or a new system is selected. Planning will need to define a phased in approach to implementation, based on efforts to maximize integration of the system. Planning will include all aspects of: Requirements definition Hardware and software infrastructure requirements Hardware and software upgrade or procurement Testing of hardware and software installations User acceptance testing Identification of workflow opportunities offered by the EHR Training of staff, both Contracted Provider and MHD staff Phased in staff hiring, contractor staff or other resources to support the implementation phases and on-going maintenance of the system. Implementation of a full Electronic Health Record (EHR) that activates functional components available in the selected transaction system with commercially available off the shelf (COTS) components based on upgrades available through the current system, or selection of a new transaction system that includes full EHR components. A detailed project plan is attached to this document. EHR Exhibit 3 Page 9
13 Project Costs The cost estimates for development of the EHR are documented in the Exhibit 4 Budget Summary. Nature of the Project The extent to which the Project is critical to the accomplishment of the County, MHSA, and DMH goals and objectives. The EHR Project is a critical component of the MHD compliance with Federal and State requirements that a fully interoperable EHR with Personal Health Records (PHR) is in place by It is also an integral part of the MHD strategic plan to modernize and transform clinical and administrative systems to ensure quality of care, parity and operational efficiency and effectiveness. SCVHHS has set an internal target goal of 2013 for implementation of a full EHR for the HHS and MHD. The goals and expected benefits for the EHR include: Reduce paper medical charts and provide an electronic mechanism to securely share critical client treatment data with all providers in the network. It is understood that many consumers received services with multiple providers and participate in service offerings in different programs across agencies. The EHR is a key enhancement that will improve treatment and operational efficiency. Access to EHR information will provide consumer treatment records across the spectrum of outpatient, inpatient and emergency room services. Information on services and consumer needs will provide better information on identification of candidates for FSP programs. The development of effective treatment protocols and new programs will be an expected outcome of EHR implementation. Clinic automation and streamlined processes will yield cost savings and enhanced billing related revenue capture. Revenue enhancement will occur through improved integration and automation of client services with billing. The full EHR will support a secure, web based, Personal Health Record (PHR) for consumers and their families with a web-enabled interface for appointment scheduling and clinician communication. Improved exchanges of defined data with other County agencies will improve coordination of care for at-risk children receiving services from multiple agencies. Improved opportunities to securely share consumer medical history and treatment information that will follow the consumer through other agencies, such as probation, juvenile halls, and jails services. The overarching goal is to provide a mechanism that provides for a more seamless follow-up of services, when needed and improve the referral and on-going service process. EHR Exhibit 3 Page 10
14 The development and implementation of standard data sets with contracted providers and other agencies and the State will reduce costs and ensure improvements in data exchange capabilities. MHD clinical staff model with full EHR implementation includes the following components as presented in the graphic that follows. EHR Clinical Staff Model 2014 The degree of centralization or decentralization required for this activity. All publicly-funded Santa Clara Valley County Mental Health services are administered centrally. This includes billing, claims processing, FFS Medi-Cal, financial services, contract administration, QM, Compliance, IS and provider network management. Service delivery is de-centralized through a network of County operated facilities and Contract Providers. MHD has a dedicated group of IS staff to support their applications including, All other Network, WAN, & LAN services are centralized and provided by SCVHHS IS. EHR Exhibit 3 Page 11
15 The EHR Project is a centralized process in the activation of enhanced or currently available components within the current transaction system or, selection and implementation of other EHR solutions. SCVHHS IS will house and maintain the systems that support an EHR. The data communication requirements associated with the activity and; The characteristics of the data to be collected and processed, i.e., source, volume, volatility, distribution, and security or confidentiality. The EHR will integrate internal and external data currently captured by MHD and provide opportunities to capture additional data identified in new project proposals. For example, internal data sources include: Hospital/Inpatient providers Ambulatory and Outpatient services Department of Alcohol and Drug Services (DADS) Custody Health programs County Mental Health Clinics Contract providers, including FFS providers Pharmacy Labs Enterprise Data Warehouse (future, planned) External data sources include: County administrative systems State and other eligibility systems State claims processing Federal block grant Criminal Justice programs Juvenile Justice programs Other County agencies MH courts MHSA outcomes reporting. The EHR current and future components will integrate data from MHD as an administrator and provider of services and their contract providers. Some of the internal and external data exchange partners are include in those described in the following graphical representation as well as an overview of the characteristics. This represents the future state model for MHD of functionality and the users of the functionality. EHR Exhibit 3 Page 12
16 Santa Clara County EHR Exhibit 3 Page 13
17 During the Project Planning phase of the project, MHD will determine the volume and establish a growth factor in order to obtain the appropriate amount of hardware and infrastructure upgrades. SCVHHS IS understands that sizing and planning are critical to the success of this initiative. Our current client base is: Clients served: 23,000 Claims processed: 500,000 County end-users, including clinicians: 806 Contract Providers: 71 The data captured in the full EHR will contain PHI and will be maintained in a manner required for HIPAA compliance and DMH, State, Federal, and other required security/confidentiality procedures. SCVHHS has established policies and procedures for its current systems that comply with the all standards for HIPAA on the appropriate/secure and confidential maintenance of PHI. Additional information of the security mechanisms proposed for the EHR is provided in the Security Process section of this Exhibit. The degree to which the technology can be integrated with other parts of a system in achieving the Integrated Information Systems Infrastructure. The EHR Project and the Enterprise Data Warehouse (EDW) Project are integral components of the IISI. These two projects will enable SCVHHS to achieve secure, real-time system interoperability within the provider network and with all of its business partners. It will provide timely reporting and service information to managers, clinicians, and ultimately consumers. The EHR Project will provide an integrated tool to support all the day-to-day business operations of MHD administrators and providers. The EDW Project will provide comprehensive data and information tools to support decision making, outcome reporting and quality management initiatives. The County will comply with all State requirements. All COTS software will be selected to fit into the State DMH IISI and Santa Clara County standards established by SCVHHS IS. EHR Exhibit 3 Page 14
18 Hardware Considerations Compatibility with existing hardware, including telecommunications equipment. SCVHHS IS has a broad set of well defined technology standards in place today. The EHR will be constructed of standard hardware and will utilize existing software and telecommunication standards to the highest extent possible. Further, because MHD systems are hosted in the County's data center several system components, including networking, power, temperature control, security, and other components will leverage existing County systems and facility features wherever possible. A copy of SCVHHS IS Technology Standards and Network Management policies are included in Appendix B of Exhibit 2. Physical space requirements necessary for proper operation of the equipment. Mental Health Department (MHD) systems are currently hosted in a data center operated by the SCVHHS IS. This data center is a state of the art facility that hosts systems for several County Departments other than Mental Health. An evaluation of the data center determined that adequate space currently exists to accommodate the proposed EHR. It is known that there will be additional electrical power capacity needs and upgraded air conditioning in the current facility. These costs have been included as part of the budget included for the EHR. Hardware maintenance. The SCVHHS IS currently manages the networking equipment, all servers, power, and temperature controls. Currently the County s policy is to own, not lease, hardware equipment and refresh equipment on a 5 year cycle. Part of the proposed EHR implementation plan includes the hiring of additional technical staff to assist existing staff with systems administration and hardware management over time as capacity grows. While we anticipate that existing staff will be able to install and maintain hardware initially, it is likely that as system utilization grows over time that additional staff will be required. A copy of the Network Management and the Table of Contents for a confidential policy related to Business Continuity Plan are included in Appendix B of Exhibit 2. EHR Exhibit 3 Page 15
19 Backup processing capability. The EHR will, to the extent possible, utilize existing hardware and processes so as to conform with existing backup processing practices and the County's Disaster Recovery Plan. Because the current backup processing capability planning process is designed for existing systems, it is likely that additional capacity will be required with the development and operation of the EHR. As such, provision has been made in the planning process and budget estimates for additional backup servers, backup application licenses, tapes, and other necessary supplies. Further, part of the planning process also includes provision for staff to manage and take responsibility for the backup process in general and compliance with all regulatory requirements and existing County standards. A copy of the Data Backup policy is included in Appendix B of Exhibit 2. Existing capability, immediate required capacity and future capacity. Expanding current capacity to meet future needs and added functionality will be considered during the project planning and design phases of this project. MHD currently purchases hardware at contracted cost through the SCVHHS IS contract. Because this project involves a capability that does not exist today, expansion of the servers, networking equipment, backup equipment, and other associated hardware will be required and is included in the budget assumptions. A key underlying assumption throughout the hardware budget is that SCVHHS IS will leverage existing purchase agreements and negotiated pricing wherever possible to procure hardware at the lowest possible cost. A secondary assumption throughout the hardware budget is that where possible MHD will utilize servers of a consistent type and build for ease of administration and configuration. SCVHHS has a well defined Technology Standards policy that defines hardware and platform requirements. The Technology Standards policy is included in Appendix B of Exhibit 2. EHR Exhibit 3 Page 16
20 Software Considerations Compatibility of computer languages with existing and planned activities. The EHR as proposed will utilize existing County and Mental Health Department standards with respect to the compatibility of computer languages, software, and all other aspects. The Technology Standards policy for software is included in Appendix B of Exhibit 2. Maintenance of the proposed software, e.g. vendor-supplied. The EHR will utilize Commercial Off the Shelf (COTS) software components. The vendor will provide software updates, software development, and other functions to update and maintain the core software that it produces. The EHR software deployed onsite in Santa Clara will be maintained and administered by existing or future SCVHHS IS staff. SCVHHS IS staff assigned to MHD currently maintain a wide variety of COTS software, including the current transaction system installation. SCVHHS IS currently has appropriate contractual Service Level Agreements (SLA s) for vendor supported software utilized and will add or expand agreements as needed for the development of the EHR. SCVHHS IS also maintains networking software. The County will remain current on releases of software. Provision has been made in the projected budget for vendor support and licensing agreements as well as some interaction with contracted staff who would provide SCVHHS with specialized skill sets at critical junctures in the development and operational phases of the project. Availability of complete documentation of software capabilities. The EHR vendor will be expected, via contract provisions, to provide documentation for the EHR product. Vendor supplied documentation will be adapted, printed, as needed and distributed to users and system maintenance staff resources. The County will need to develop some documentation that reflects specific processes in place that are unique to Santa Clara County and therefore not included in the standard set of vendor documentation. For example, data exchange documentation for partners/contracted vendors, backup and recovery documentation, internal systems management functions, and other such activities could require significant effort. MHD and IS will develop supplemental documentation. The attached budget summary includes provision of MHSA funds to develop documentation to support operations. EHR Exhibit 3 Page 17
21 Availability of necessary security features as defined in DMH standards noted in Appendix B. The Mental Health Department (MHD) has a wide ranging set of security responsibilities that it currently is required to meet with existing systems. These responsibilities include County, State, and Federal as well as other legislated security measures and mechanisms. After reviewing the security features as defined in California DMH standards as noted in Appendix B, we believe that the security features of the EHR will exceed DMH standards and meet all applicable County, State, Federal, and other security requirements. To ensure compliance with California DMH and other standards, we have planned for an annual security evaluation to be conducted to evaluate the extent to which the EHR meets current and future security standards. This evaluation, as planned, would be conducted by an expert and impartial third party. An abbreviated version of the IT Security policy for SCVHHS is included in Appendix B of Exhibit 2. Ability of the software to meet current technology standards or be modified to meet them in the future. SCVHHS IS has a defined and mature set of current technology standards. These standards were designed with the goal of future growth and in anticipation of technological changes over time. Further, to support these standards, SCVHHS IS has established relationships with a number of vendors and has negotiated pricing and upgrade terms to reflect future growth and change. The current practice management system conforms to all County technology standards. The vendor has a business relationship with Microsoft and utilizes Microsoft development tools. Should MHD seek a replacement EHR it will require the new COTS software package to conform to County technology standards and easily fit into its technical environment. The Technology Standards are defined in a SCVHHS IS policy included in Appendix B of Exhibit 2. EHR Exhibit 3 Page 18
22 Interagency Considerations Describe the County s interfaces with contract service providers and state and local agencies. Consideration must be given to compatibility of communications and sharing of data. The information technology needs of contract service providers must be considered in the local planning process. MHD exchanges consumer treatment and service information with a number of other agencies. The agencies include, but are not limited to the following: Contracted providers, including FFS providers State and other eligibility systems State claims processing Other County agencies including: DADS Public Guardian Custody Health Services SCVHHS FSP Programs MH courts (Future, planned) Contract Providers are currently entering in consumer treatment information directly into MHD s Uni/Care system. Some of the providers also do direct data entry of service information while others submit the service data via a proprietary EDI function. In the future, all Contract Provider agencies will be encouraged to submit their data via secure EDI using standard transaction sets. Planning, funding and transition planning will be developed during the planning and design phases of the project. MHD recognizes the complexity related to the sharing of information internally and across agencies. The SCVHHS IS currently maintains a robust WAN and exchanges data with State and local entities. The development of a set of electronic data exchange transactions that utilize industry-standard formats is imperative and will be a key driver of all planning. It is the intent of MHD to emphasis standard data set development and implementation as one of the goals for the EHR. This will include adopting the relevant HIPAA / ANSI transaction standards and HL-7 standards for other consumer health data. In addition, MHD will stay current with changes to standards and adopt the behavioral health data standards that are currently under development. MHD recognizes that contracted providers and consumers are valued partners and collaborators in this process. MHD has actively included providers and consumers in planning about the EHR strategy and its advantages for the entire service system. The MHD currently conducts regular meetings with providers and during the development and implementation of the EHR it is expected that contracted providers, especially, will actively participate in review of data and implementation decisions. We recognize that providers will need be to included in the EHR requirements process, will need clear support and lead time on any changes in transactions and will require training and technological support to facilitate implementation. The conversion of contracted provider strategy will be a key milestone in the planning process for EHR implementation. EHR Exhibit 3 Page 19
23 Training and Implementation Describe the current status of workflow and the proposed process for assessment, implementation and training of new technology being considered. Training and implementation are two different activities, but both require careful development, sufficient resources and active project management in order to achieve successful results. Implementation of the EHR will require: Clear understanding of the objectives o Define the data needed o Tie objectives to the best data sources o Establish business rules o Define users, applications, data load frequency and other issues Establishment of a migration path Procure or build software for migration, loads of data, user testing Development user acceptance test scenarios and process Development of policies and procedures that support the EHR Expansion of security, confidentiality, back-up and other procedures to maintain the systems Procurement, installation, set-up and tuning of hardware and software. In addition, prior to implementation, a business and operational assessment will be completed to identify and document: o Current workflows processes o New workflow opportunities that can/should be implemented to maximize the advantages of the new functionality o Documentation of processes that can be used for system configuration decision-making o Development of modified policies and procedures. Training of business users will be completed via collaborative meetings with endusers, software vendors and project team members and encompass, a minimum, the following: Identification of key users that will access the EHR components Implementation of appropriate security Scheduling of training that aligns with workload and service needs Identification of long term updates and maintenance of training information, and on-going training processes Identification of other basic computer skills training that may be required for endusers that may, now with the EHR, need to utilize the systems. See Appendix B of Exhibit 2 for SCVHHS training guidelines that will be considered during the project planning phase and incorporated into the EHR training plan. MHD is fully aware that the process to ensure the successful rollout and subsequent EHR Exhibit 3 Page 20
24 utilization of the potential of the EHR and reporting capabilities, training and implementation are key success factors. The budget documented in the Budget Summary includes line items for staff training and implementation costs are factored throughout. EHR Exhibit 3 Page 21
25 Security Strategy Describe the County s policies and procedures related to Privacy and Security for the Project as they may differ from general Privacy and Security processes. Because the data to be contained in and exchanged with the EHR involves PHI, it is recognized by SCVHHS that it is necessary to ensure that any proposed solution is fully compliant with all relevant regulatory and legal requirements. In addition to these regulations, compliance with all DMH standards will be part of the development and operations of the EHR. For any selected vendor(s) for COTS software SCVHHS IS will ensure that the vendor(s) pre-certify their product as being compliant with HIPAA and all other Federal, State, and Local legal requirements. To ensure system and data security the County ISD performs an annual security evaluation and test of all applications containing PHI. The SCVHHS IS Security policy in an abbreviated form is included in Appendix B of Exhibit 2. Protecting data security and privacy. Data security and privacy will be built in to the project from day one and be enforced by the stringent and fully compliant SCVHHS IS policies with Federal, State and Local regulations on security and privacy. All PHI is encrypted. Compliance with relevant security requirements is evaluated on an annual basis by the County ISD. The SCVHHS IS Security policy in an abbreviated form is included in Appendix B of Exhibit 2. Operational Recovery Planning. MHD currently ensures operational recovery planning through the existing County Wide Business Continuity Planning (BCP) process. The EHR will conform to existing requirements and be part of the County-wide planning, documentation, and testing procedures. The details for the Operational Recovery for the EHR will be incorporated into the BCP during the planning process. The Table of Contents for the confidential Business Continuity Plan has been included in Appendix B of Exhibit 2. Business Continuity Planning. EHR Exhibit 3 Page 22
26 MHD currently ensures business continuity planning through the existing County Wide Business Continuity Planning (BCP) process. The EHR will conform to existing requirements and be part of the County-wide BCP planning, documentation, and testing procedures. The Table of Contents for the confidential Business Continuity Plan has been included in Appendix B of Exhibit 2. Emergency Response Planning. MHD currently ensures emergency response planning through the existing County Wide Business Continuity Planning (BCP) process. The EHR will conform to existing requirements and be part of the County-wide BCP planning, documentation, and testing procedures. The Table of Contents for the confidential Business Continuity Plan has been included in Appendix B of Exhibit 2. HIPAA Compliance. The inclusion of PHI and other data in the EHR will require MHD to ensure compliance with the Health Insurance Portability and Accountability Act (HIPAA). HIPAA will be one of many sets of regulatory compliance that will require planning and operational practice over time. Where possible, the EHR will leverage existing stringent security mechanisms employed by other MHD or County systems. Compliance with HIPAA and other relevant security requirements will be evaluated on a yearly basis by a third party. SCVHHS maintains HIPAA required Business Associate Agreements and ensures compliance with all employees, providers and contractors required training, legal agreements regarding confidentiality, protection and privacy requirements for HIPAA covered paper and electronic records. A copy of the required Business Associate Agreement can be found in Appendix B of Exhibit 2. SCVHHS already has both a Security Officer or HIPAA Compliance Officer responsible for all data and operations within any of the SCVHHS agencies. State and Federal laws and regulations. In addition to HIPAA and DMH security requirements there will be a number of State and Federal laws and regulations that will require additional security mechanisms to be considered, implemented, and practiced. Where possible, the EHR will leverage existing security mechanisms employed by other MHD or County systems. Compliance with State, Federal, and other relevant security requirements will be evaluated on a yearly basis by a third party. EHR Exhibit 3 Page 23
27 Project Sponsor(s) Commitments Sponsor(s) Name(s) and Title(s) Identify the Project Sponsor name and title. If multiple Sponsors, identify each separately. The co-sponsors for the Electronic Health Record project are: Nancy Pena, Ph.D., SCVHHS Mental Health Department Director Dennis Kotecki, SCVHHS Chief Information Officer Commitment Describe each sponsor(s) commitment to the success of the Project, identifying resource and management commitment. The Project Sponsor agrees to provide direction and leadership for this Project and will: Provide Executive leadership and bidirectional communication on the EHR project. Accepts visible departmental ownership for EHR project. Set strategic direction and goals for projects. Has final approval on all project deliverables. Serves as the ultimate decision-maker on issues that cannot be resolved at a lower level. Is accountable for the Project s success and will hold all team members responsible for their contributions and assignments to the project. Approvals/Contacts Please include separate signoff sheet with the names, titles, phone, , signatures and dates for: Individual(s) responsible for preparation of this Exhibit, such as the Project Lead or Project Sponsor(s). Approval / Contact sign-off sheet is attached. EHR Exhibit 3 Page 24
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29 Team Experience Like Projects completed by at least 75% of Key Staff Elements of Project Type Hardware APPENDIX A - PROJECT RISK ASSESSMENT Electronic Health Record Category Estimated Cost of Project Project Manager Experience Like Projects completed in a "key staff" role New Install Update/Upgrade Infrastructure Factor Rating Score Over $5 million 6 Over $ 3 million 4 Over $500, Under $500,000 1 None 3 One 2 Two or more 1 None 3 One 2 Two or more 1 Local Desktop /Server 1 Distributed/Enterprise Server 3 Local Desktop /Server 1 Distributed/Enterprise Server 2 Local Network/Cabling 1 Distributed Network 2 Data Center/Network Operations Center 3 Custom Development Software *Commercial Off-The Shelf Software Application Service Provider 1 COTS* Installation "Off-the-Shelf" 1 Modified COTS 3 Number of Users Over 1,000 5 Over Over 20 2 Under 20 1 Architecture Browser/thin client based 1 Two- Tier (client / server 2 Multi-tier (client & web, database, application, etc. servers) Total Score Project Risk Rating High Medium 8-15 Low Total Score 25 Appendix A Template Project Risk Assessment Word 2003 version
30 EHR Project DRAFT svs ID Task Name Duration Start Finish Predecessors 1 EHR Project 1393 days? Wed 10/1/08 Wed 2/5/ Determine EHR Strategy for MHD (Uni/Care or other product) 105 days Wed 10/1/08 Fri 2/27/09 3 Perform Current State IT Assessment 33 days Wed 10/1/08 Fri 11/14/08 7 Conduct EHR Readiness Survey 63 days Wed 10/1/08 Tue 12/30/08 12 Perform Gap Analysis 47 days Wed 10/1/08 Fri 12/5/08 17 Conduct meetings with Uni/Care to discuss future plans 9 days Wed 10/1/08 Mon 10/13/08 20 Conduct Market Study Research of other vendors 39 days Wed 10/1/08 Mon 11/24/08 25 Present Findings and Facilitate Discussion 21 days Mon 12/8/08 Wed 1/7/09 20,19,12 29 Identify MHD/ IT team to review other systems 2 days Thu 1/8/09 Fri 1/9/ Review existing BH EMRs in use 11 days Wed 1/14/09 Wed 1/28/ Discuss Findings 6 days Thu 1/29/09 Thu 2/5/ Develop recommendation to the MH Executives 16 days Fri 2/6/09 Fri 2/27/ Develop Contract Provider Strategy 105 days Wed 10/1/08 Fri 2/27/09 45 Perform Current State Assessment 33 days Wed 10/1/08 Fri 11/14/08 49 Identify Possible Contract Provider Models 30 days Mon 11/17/08 Tue 12/30/ Conduct Contract Provider Needs Assessment and Input Meeting 13 days Wed 12/31/08 Mon 1/19/ Determine Feasible Strategies 7 days Tue 1/20/09 Wed 1/28/ Develop Position Paper 6 days Thu 1/29/09 Thu 2/5/ Present to Contract Providers for Review 13 days Fri 2/6/09 Tue 2/24/ Obtain approval of Contract Provider Stategy 3 days Wed 2/25/09 Fri 2/27/ Develop EHR Project Organizational Strategy and Structure 40 days Mon 2/2/09 Fri 3/27/09 71 Establish Project Structrure 11 days Mon 2/2/09 Mon 2/16/09 77 Establish Centralized Project Files 6 days Tue 2/17/09 Tue 2/24/09 82 Establish Project Charter 4 days Mon 3/2/09 Thu 3/5/09 86 Establish Project Communication Plan 4 days Fri 3/6/09 Wed 3/11/ Establish Project Management Processes 12 days Thu 3/12/09 Fri 3/27/ Determine External Resource Needs for the project 6 days Tue 2/17/09 Tue 2/24/ Develop RFP for New System, if needed 86 days Mon 3/2/09 Mon 6/29/ Procure External Resource to Support RFP Development, if Needed 40 days Mon 3/2/09 Fri 4/24/ Determine review and approval process for RPF 10 days Mon 3/2/09 Fri 3/13/ Develop RFP for New System 46 days Mon 4/27/09 Mon 6/29/ Complete a Workflow Analysis 92 days Mon 2/23/09 Tue 6/30/ Procure External Resource to Support Workflow Analysis 40 days Mon 2/23/09 Fri 4/17/ Identify Internal Resources to Support Workflow Analysis 20 days Mon 3/2/09 Fri 3/27/ Gather Any Existing Workflow Documents 10 days Mon 3/30/09 Fri 4/10/ Develop Workflow Workgroup Teams (Subject Matter Experts and IT) 18 days Mon 3/30/09 Wed 4/22/ Convene Meeting #1 - Review and Validate Existing Workflows 2 days Wed 5/6/09 Thu 5/7/ Complete Meeting #1 Post Meeting Activities: Update Workflows and Redistribute 6 days Fri 5/8/09 Fri 5/15/ Convene Meeting #2: Develop Missing Workflows 1 day Fri 5/22/09 Fri 5/22/ Complete Meeting #2 Post Meeting Activities: Develop Workflows and Distribute6 days Mon 5/25/09 Mon 6/1/ Convene Meeting #3 - Analyze Workflows 1 day Mon 6/8/09 Mon 6/8/ Page 1
31 EHR Project DRAFT svs ID Task Name Duration Start Finish Predecessors 221 Complete Meeting #3 Post Meeting Activities: Update Workflows and Redistribute 5 days Tue 6/9/09 Mon 6/15/ Validate All Updated Workflows 11 days Tue 6/16/09 Tue 6/30/ Procure new system / services (or, contract with Uni/Care) 304 days Tue 6/30/09 Fri 8/27/ Develop Vendor Proposal Evaluation Methodology 81 days Tue 6/30/09 Tue 10/20/ Select a Vendor 150 days Tue 8/11/09 Mon 3/8/ Develop Proposed Agreement, SOW and Exhibits 75 days Tue 3/9/10 Mon 6/21/ Negotiate Contract 49 days Tue 6/22/10 Fri 8/27/ Develop Implementation Plan for System Implementation 504 days Mon 3/30/09 Thu 3/3/ Establish External Project Leadership and Support Needs 56 days Mon 3/30/09 Mon 6/15/ Establish Project Oversight Strategy 64 days Tue 6/16/09 Fri 9/11/ Develop Preliminary Implementation Strategy 14 days Tue 6/16/09 Fri 7/3/09 2,44,70, Evaluate Vendor Implementation Strategy 8 days Mon 8/30/10 Wed 9/8/ Finalize Implementation Strategy and Timeline 26 days Thu 9/9/10 Thu 10/14/ Identify Temporary Staffing and Provider Needs 100 days Fri 10/15/10 Thu 3/3/ Identify Super Users to Assist with Configuration, Training and Ongoing Support 12 days Fri 10/15/10 Mon 11/1/ Develop a Training Strategy and Plan 74 days? Fri 10/15/10 Wed 1/26/ Determine Training Needs (for Practice Mgmt, eprescribing, EHR, Portals, PHR)10 days Fri 10/15/10 Thu 10/28/ Determine Training Approach 5 days Fri 10/29/10 Thu 11/4/ Develop Training Material 41 days? Fri 11/5/10 Fri 12/31/ Design Training Sessions 10 days Mon 1/3/11 Fri 1/14/ Schedule Training 3 days Mon 1/17/11 Wed 1/19/ Conduct Training (Super User/ End User Training inc in Phase Detail) 5 days Thu 1/20/11 Wed 1/26/ Upgrade Hardware / Network Infrastructure 41 days Mon 8/30/10 Mon 10/25/ Determine Hardware Needs 5 days Mon 8/30/10 Fri 9/3/ Procure Hardware and Network Components 26 days Mon 9/6/10 Mon 10/11/ Install and Test Upgraded Hardware and Network Infrastructure Components 10 days Tue 10/12/10 Mon 10/25/ Implement the Practice Management System/EHR Lite 200 days Mon 9/27/10 Fri 7/1/ Install and Configure Practice Management System Software 98 days Tue 10/26/10 Thu 3/10/ Test Practice Management System 34 days Fri 3/11/11 Wed 4/27/ Convert Data 168 days Mon 9/27/10 Wed 5/18/ Pilot Practice Management at One Site 180 days Fri 10/15/10 Thu 6/23/ Train Staff on Practice Management System 5 days Fri 6/24/11 Thu 6/30/ Go-Live on Practice Management System/EHR Lite 1 day Fri 7/1/11 Fri 7/1/ Implement eprescribing 294 days Mon 10/18/10 Thu 12/1/ Install and Configure eprescribing 43 days Mon 7/4/11 Wed 8/31/ Test eprescribing 33 days Thu 9/1/11 Mon 10/17/ Accept System Software 1 day Tue 10/18/11 Tue 10/18/ Pilot eprescribing 288 days Mon 10/18/10 Wed 11/23/ Train Staff on eprescribing 5 days Thu 11/24/11 Wed 11/30/ Page 2
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