MEMORANDUM OF UNDERSTANDING

Transcription

1 MEMORANDUM OF UNDERSTANDING Use of Oregon Web Infrastructure for Treatment Services (OWITS) Electronic Health Record (EHR) System by Behavioral Health Treatment Providers ADDICTIONS & MENTAL HEALTH DIVISION OREGON HEALTH AUTHORITY Revised: April 2014

2 MEMORANDUM OF UNDERSTANDING Oregon Web Infrastructure for Treatment Services (OWITS) I. PARTICIPANTS: a. Oregon Health Authority (OHA), Addictions and Mental Health Division (AMH) b. Behavioral Health Providers (hereafter referred to as providers or agencies): Addiction and substance abuse treatment and/or mental health service providers in Oregon which are implementing OWITS, including privately-funded providers, as well as providers that are publicly funded or AMH required reporters (such as DUII or methadone treatment providers) II. MEMORANDUM OF UNDERSTANDING: a. This Memorandum of Understanding (MOU) is made by and between AMH and providers. III. OWITS SYSTEM: a. The participants have formed a collaborative OWITS user group (OWUG) to help maintain OWITS, an Electronic Health Record (EHR). This MOU outlines the framework of the collaborative efforts as well as the responsibilities of both AMH and providers. IV. PURPOSE and RESPONSIBILITIES: a. The above participants enter into this MOU for a common goal of maintaining a statewide EHR known as OWITS. This MOU specifies the participants responsibilities in the joint effort to accomplish these goals. b. Participant responsibilities include: 1. Providing input for the current and ongoing business requirements. 2. Reviewing documents related to detail business requirements. 3. Meeting designated timeframes for completion of full implementation, if applicable (see Attachment B). 4. Attending training sessions conducted by AMH. 5. Conducting user acceptance testing upon request. 6. Inputting agency registration and ongoing status and encounter data into the OWITS EHR production web environment. 7. Actively participating and collaborating in the implementation of the OWITS EHR and in the ongoing discussions regarding system modifications, upgrades, and enhancements. 8. Assisting in the ongoing improvement and refinement of the requirements/procedures provided by AMH for using the OWITS EHR. Page 1

3 V. SPECIFIC RESPONSIBILITIES AMH: a. Coordinate, consult, and conduct business with Focused ehealth Innovations, Inc. (FEi) to provide the OWITS EHR until such time that AMH management passes support of the OWITS EHR back to the vendor. b. Establish open and candid lines of communication using non-technical language with providers. c. Establish, host, and attend the OWITS User Group (OWUG) meetings, held for the purpose of allowing AMH and provider staff to discuss potential enhancements, modifications, and additional modules for the OWITS EHR; to ask questions, raise concerns, and share solutions for improving business processes, until such time that AMH passes responsibility for this collaboration back to the vendor. d. Provide training and instruction to providers as resources allow. e. Proactively work to correct system issues and barriers. f. Provide technical support related to OWITS system errors and issues, use the OWITS EHR Support Ticket module for all Help Desk issues and enhancement requests (for a description of Help Desk tiers and responsibilities for each, see Attachment A), and notify providers via OWITS Announcment of all system outages or State mandated office closures. g. Assist providers in determining current and future business practices that utilize the OWITS EHR. h. Include partners when necessary or prudent to create future strategies for implementing additional OWITS EHR domains beyond Substance Abuse and Mental Health throughout Oregon. i. Use the OWITS EHR to gather all state and federally required data elements for both substance abuse and mental health services. j. Make collected data available to providers for reporting purposes (each agency will only have access to its data). k. Follow HIPAA and 42 CFR confidentiality and security policies and procedures. In the event that AMH determines that an agency or AMH employee has participated in or caused any illegal or potentially illegal activity, AMH will revoke all OWITS access rights for that employee; the agency and AMH management will be notified so that further investigation or action can be taken. l. Notify providers of changes or updates made to this MOU or other documents related to OWITS EHR. m. AMH responsibilities are limited by the following: 1. AMH will not implement data conversion. 2. AMH will not enter existing client data into the OWITS EHR on behalf of any provider. 3. AMH will not require fully implemented providers (see Attachment B) to submit data for CPMS or MOTS reporting, if all OWITS EHR modules containing state and federally required data elements normally reported via CPMS or MOTS are used for all clients. In such cases, no duplicate entry of OWITS EHR and CPMS or MOTS data will be necessary. 4. AMH will not provide training to all agency staff. (see d. above) Page 2

4 VI. SPECIFIC RESPONSIBILITIES PROVIDERS: a. Agree to implement the OWITS EHR out of the box. b. Understand that state funding for support and maintenance of the OWITS EHR is available only until July 1, 2015, and that after that date, each provider organization must establish a contract with the vendor in order to pay for ongoing support and maintenance. c. Understand that the current state of the OWITS EHR is an ongoing project and may not mirror or accommodate all current business practices or forms. d. Agree to utilize the available OWITS EHR modules applicable to agency business practices. e. Use computers with a reliable high speed Internet connection (7 mbps or higher, 95% of the time or better). f. Be responsible for the establishment and cost of Internet service within their respective agencies. g. Understand that the Internet Service Provider (ISP) is responsible for maintaining the Internet connection and any related hardware as stated in its contract. h. Be responsible for obtaining and maintaining agency computers as well as providing technical assistance and computer use training to agency staff members. i. Ensure that OWITS EHR users possess sufficient computer knowledge and skills (primarily data entry and web navigation) to operate the system independently after training, using reference material provided by AMH when appropriate. j. Commit designated staff members to the OWITS EHR implementation process and schedule. When applicable, user acceptance testing and requirements gathering. k. Allow sufficient time for at least two to three of the proposed OWITS EHR users to participate in training sessions, which may follow a Train-the-Trainer format. At least one of the staff members attending the training should be the System Administrator and/or Central Contact described below. 1. Train-the-Trainer: Staff members who attend the sessions to train others within the agency regarding how to access and use the OWITS EHR. 2. Agency Administrator: (may also be the Central Contact) Designated staff member(s) (at least one back up) for creating and maintaining agency staff access and security data in the OWITS EHR. This will be the contact person for AMH regarding technical decisions, Help Desk issues, and system security (see Attachment A). 3. Central Contact: Designated staff member(s) (at least one backup) to be the Central Contact for the OWITS EHR (may also be the System Administrator see above). This will be the person with whom AMH maintains communication regarding business, clinical, and data related decisions. l. Use the OWITS EHR Support Ticket module for all Help Desk issues, except in cases of an OWITS system outage or login issues, in which case contact by phone or message is acceptable. m. Enter and maintain up-to-date staff and client data in the OWITS EHR, including required fields in Staff Profile to comply with Health Insurance Portability and Accountability Act (HIPAA) security verification (see Attachment C). Page 3

5 n. Determine what existing client data (if any) needs to be entered into the OWITS EHR and enter all required data. o. Identify all unique programs or services, such as people receiving Intensive Treatment Recovery Services (ITRS), using predetermined identifiers in the OWITS EHR. p. Continue submitting CPMS Pre-Commitment and Crisis service data until OWITS EHR modules become available to record these services. q. Determine current business practices and future business practices necessary to implement the OWITS EHR. Business practices are the procedures an agency uses from the moment a person makes contact with a staff member until that person is discharged or no longer receives treatment services from the agency. r. Create new internal policies and procedures or make changes and updates to existing policies and procedures, as needed, to accommodate the OWITS EHR. s. Participate in the OWUG--in monthly phone conferences or via the OWITS Forum--or accept decisions made by the OWUG on behalf of all providers. As an OWUG collaborative member, participate both with feedback and resources, as appropriate, to ensure that the OWITS EHR meets provider needs. t. Notify AMH in writing in the event of a decision to discontinue using the OWITS EHR. This notification must include a specific date on which usage will end, the reason(s) for the decision, and what changes (if any) would have to occur for this decision to be reconsidered. Providers that discontinue OWITS EHR use are expected to continue to submit required data via CPMS (or current data submission methods) as specified by the administrative rules. AMH is not responsible for data conversion from OWITS to other EHR systems. u. Maintain licensure or certification as an addiction treatment or mental health treatment service provider as appropriate. v. Become fully implemented in OWITS production within 6 months of final training (see Attachment B). VII. RECOGNITION a. AMH and the providers will work collaboratively and in partnership with each other to maintain and implement ongoing use of OWITS as an EHR. b. All participants recognize that OWITS EHR modules that do not contain state or federally required data elements only represent system capabilities. Business policies and decisions made by individual provider agencies and facilities will dictate which of these non-required modules will be used and in what circumstances. c. All users are expected to use the OWITS EHR in compliance with existing rules and regulations, including internal policies. d. At such time that AMH is no longer able to provide funding for OWITS maintenance and support, providers will assume financial responsibility or choose alternative methods of reporting required data (EDI or MOTS Client Entry). Page 4

6 VIII. CONCURRENCE Addictions and Mental Health Division Signature below indicates sponsorship of this MOU, including attachments. Print Name: Title: Signature: Date Signed: Print Name: Title: Signature: Date Signed: Provider Agency Signature below indicates agreement with this MOU, including attachments. This MOU may be subject to changes. Notice of changes will be provided. Agency Name: County Print Name: Title: Signature: Date Signed: Print Name: Title: Signature: Date Signed: Sign and fax to: Attn: OWITS System Administrator Or Mail to: Attn: OWITS System Administrator 500 Summer Street NE Salem, Oregon Page 5

7 Attachment A Help Desk Support Definitions Tier 1 Tier 2 Tier 3 This is the first contact for provider agency users who need assistance with technical problems or use of the OWITS EHR. Tier 1 is located at the provider agency. OWITS EHR contacts at AMH are not involved in Tier 1 support. Users contact their system administrator(s), trainer(s), business analyst(s), or other designated staff member(s) within the provider agency for help resolving the problem. Tier 1 support includes staff training, managing access to OWITS EHR, and password/pin maintenance including password resets, enabling disabled accounts and unlocking locked accounts. In addition, provider agencies are expected to resolve all technical issues related to desktop/laptop computers and/or Internet connectivity. Agencies are expected to identify and resolve user questions about or problems with: using the OWITS EHR application, agency business processes policies and/or procedures in relation to the use of OWITS EHR, and user access issues such as registering new users. A designated person from the provider agency contacts AMH through the use of the Support Ticket module for assistance in solving problems related to OWITS EHR not resolvable by Tier 1 personnel. The Support Ticket Screen must be filled out completely in order to reduce and phone follow-up. Screen shots are helpful and can be added to the ticket. These types of issues might include such things as error messages that cannot be resolved by the user, unresponsive screens, and unusual screen or system behavior. Tier 2 support will be available 8:00 a.m. 5:00 p.m., Monday through Friday, excluding federal and state holidays and state-required unpaid furlough days. Urgent matters may be addressed by (owits.support@state.or.us) or by phone call to OWITS EHR support personnel. Provider assistance can be found at the following website: AMH contacts FEi using the OWITS EHR Support Ticket module to resolve technical issues not resolvable by Tier 2 personnel. Tier 3 is the highest level of technical competence and support and will be involved if issues are determined to be technically complex, have a system-wide impact, represent significant system problems or defects, or are issues with a critical impact on AMH or the provider agencies. AMH maintains a contract with FEi that describes exactly how FEi is expected to respond to and resolve Tier 3 issues when reported. AMH, at its sole discretion, decides if and when to report an issue to FEi for assistance. Provider agencies are not permitted to escalate an issue to Tier 3. Page 6

8 Attachment B Definition of Fully Implemented Fully implemented providers have completed all required setup and training as described in in the policy below and have been signed off by an account coordinator. Access to the OWITS EHR Training environment is granted during the training process. Providers are required to close all lapsed CPMS records and work with state CPMS support staff to resolve all existing CPMS database errors before access will be granted to the OWITS EHR Production environment. When Production access is granted, providers will be required to enter data for all active treatment cases. Pre-Commitment and Crisis services must be submitted by CPMS until OWITS EHR can accommodate that information. Fully Implemented Policy Regarding CPMS for OWITS EHR Users To meet the contractual and reporting requirements of AMH, be fully implemented as a MOTS Client Entry Provider, and no longer using CPMS, a provider must do the following: 1. Provider must review the list of episodes currently open in CPMS (Open Client List). a. If an episode should be closed (services are no longer being provided), provider submits a termination form with the appropriate termination type code. This needs to be done first, as we need the discharge data on these clients. b. Provider works with the CPMS Data Team to resolve any errors that prevent current episodes from showing up on the Open Client List. 2. AMH to produce a report of open CPMS clients to support Provider Data Entry. 3. Provider will enter their current case load. 4. Provider will then stay current on status and service data entry with clients in MOTS. In addition, the COMPASS project staff will: 1. Verify that all the client episodes for the provider are closed out of CPMS. 2. Delete any remaining errors that do not affect the providers ability to close their open episodes. 3. Assist the provider with any questions or concerns. After June 1, 2014, if any CPMS errors still exist on records for the provider, AMH will delete those records and the provider will not receive credit for serving those clients. AMH will also close any remaining open CPMS clients. Page 7

9 Attachment C HIPAA Required Security Verification AMH requires user verification upon receiving requests to access client information or view or modify client data in OWITS. Phone Call Requests Users must identify themselves by giving the following information: first name, last name, the name of the agency they work for or represent,, and their date of birth. Requests All requests should be sent to OWITS.SUPPORT@state.or.us. The Sender/From address must be documented in OWITS. Two addresses can be entered in the Staff Profile record for each staff member. The field in the Staff Profile should contain the business address (if available), such as: john.smith@smithagency.org. In the Staff Profile Comments field, an alternative business or personal address may be entered if business-related messages are sent from that account when the primary business account is not accessible, such as when a user would be working remotely. An example personal address would be: johnnys@yahoo.com. addresses containing inappropriate language are not permitted and will be removed by the AMH system administrators. AMH will verify staff member s security level and access to client information. If access or security information indicates the user should not be given client information, AMH staff will refer the user to the Agency Administrator. If person contacting AMH requesting client information cannot be verified as a valid OWITS user, AMH will contact the Agency Administrator to alert them of the suspicious inquiry. For password reset requests, it is the users responsibility to alert OWITS Support if the alternate address is to be used. The default for sending password resets is the primary address entered in the field. Page 8