Mass HIway Consent: Operationalizing Opt-in September 11, 2014
Massachusetts ehealth Institute THE INNOVATION INSTITUTE at the MassTech Collaborative MBI MASSACHUSETTS BROADBAND INSTITUTE Tech Hub Collaborative Big Data Consortium Advanced Manufacturing Collaborative Innovation Index Mass Broadband 123 MassVetsAdvisor MeHI is the designated state agency for: Coordinating health care innovation, technology and competitiveness Accelerating the adoption of health information technologies MeHI MASSACHUSETTS ehealth INSTITUTE Health IT Adoption & Use Connected Communities ehealth Services & Support ehealth Innovation ehealth Learning Center Promoting health IT to improve the safety, quality and efficiency of health care in Massachusetts MeHI is a division of the Massachusetts Technology Collaborative, a public economic development agency Advancing the dissemination of electronic health records systems in all health care provider settings 2 Massachusetts ehealth Institute
Learning objectives 1. Describe the Massachusetts HIE opt in legislative mandate 2. Locate and share community-developed Mass HIway consent resources 3. Describe the different approaches organizations are taking to meet the opt in mandate 4. Recognize the various technical, policy and procedural elements to consent 3 Massachusetts ehealth Institute
Agenda 1. Overview of the Massachusetts HIE opt in legislative mandate 2. Review community-developed Mass HIway consent resources 3. Organizational approaches to meeting the opt in mandate Partners Healthcare / Mass General Hospital Christine Griffin Beth Israel Deaconess Medical Center John Halamka 4. Questions 4 Massachusetts ehealth Institute
Meet the speakers Sean Kennedy, MPH, MS, PMP Health Information Exchange Director Massachusetts ehealth Institute at the Massachusetts Technology Collaborative Amy Caron, MPH Project Manager for Mass HIway Communications, Outreach, Education Executive Office of Health and Human Services Christine Griffin Health Information Services Manager Massachusetts General Hospital, Health Information Services John Halamka, MD, MS CIO Beth Israel Deaconess Medical Center 5 Massachusetts ehealth Institute
The Massachusetts Health Information Highway Operationalizing Opt In September 11, 2014 www.masshiway.net
What is the Mass HIway? Mass HIway: Secure, statewide health information exchange (HIE) network operated by the Massachusetts Executive Office of Health and Human Services. Mass HIway does NOT store clinical information or medical records (not a hub and spoke model HIE). Goals: Improve and enhance information sharing and communication among cross institutional care teams in a secure and efficient way to: Improve care coordination/transitions Avoid readmission and medical errors Reduce costs/duplication Improve patient outcomes/satisfaction Services: 1) Direct Messaging enables secure push of health information. 2)Query & Retrieve adds functionality to allow query, location, requests and receipt ( pull ) of health information.
Why Opt In? Opt Out: All or some pre-defined set of data are qualified to be included and available for e-exchange. Patients need to take action to opt out. Opt In: No patient data are made available for e-exchange until patients express that they allow their providers to use the HIE to send/receive health information. Builds patient trust and buy in to improve participation. Patient- centric and sensitive to privacy concerns. Increases patient engagement.
What are the consent policies? Consent is only applicable for use of the Mass HIway to exchange information as allowed by law. Must follow existing laws for sending sensitive information. Consent for Direct Messaging must mention that the Mass HIway is being used as a mode of exchange. Must obtain new consent if implementing Query & Retrieve because more information must be provided about the functionality requirements. Participants may get consent for all services at one time if all contract obligations are followed. Consent must be documented and auditable. Process must be in place for patients to change their consent preferences and for Mass HIway to be notified. Process must be in place for patients to request and receive an audit log of Mass HIway transactions from the Participant. Consent time limits are up to Participants; must follow consent policies for emancipated minors and minors turning 18 years old. Does NOT apply to mandatory DPH reporting or BAs.
Why is consent different for Q&R? Consent Publish Query & Retrieve Consent preference sent to Mass HIway in ADT Message using Direct Protocol. If Yes, demographic data is pulled and stored in Master Patient Index (part of the RLS). If No, it s discarded. Patient relationship to Participant published to Relationship Listing Service (RLS). Made viewable by search to other authorized users on the Mass HIway. Participant uses the RLS to search for where other records are held and are available, based on consent. Can request health information through Clinical Portal. Recipient can reply over Mass HIway. Reply sent to requestor directly, not viewable or stored by Mass HIway.
Tell me how its done Mass HIway does not prescribe or require any particular process. Allows for flexibility from small to large practices. Mass HIway, Advisory Groups, P&S officers, Participants, health literacy experts convened to develop a community approved approach to opt in that includes: 1. Using simple consent language that can be incorporated into existing consent forms or used as a stand alone form. 2. Giving the patient educational material to review before making their choice. 3. Training frontline staff on Mass HIway and consent so they can have a dialogue with patients. More details and links to resources can be found at: http://www.masshiway.net/resources/masshiwayconsent.jsp
Simple Consent Language
Educational Material
Final thoughts When planning consent for Mass HIway: Changing your process and forms, and educating your staff can take time, so start early and engage all teams. Think about your patient population and any specific needs, such as translations for educational material. If implementing Query & Retrieve, engage your vendor early. Your system needs to be able to generate HL7s with a Yes consent flag to populate the RLS. If considering getting consent for Direct Messaging only, that s ok- just remember the process needs to be auditable and new consent will need to be obtained if you get Q&R services. Remember, your staff should be able to discuss the Mass HIway with your patients and Participants should have an internal escalation path.
Christine Griffin September 11, 2014
Design and implement an enterprise on-line patient HIway consent model Collect patient consent one time Consistently apply patient choice throughout Partners Healthcare (including our EHR affiliates) Meet Meaningful Use Stage 2 measures related to HIE
but how?
HIPAA Privacy Notice & Patient Acknowledgement Form flag in local registration systems and Y/N stored at EMPI Patient Portal Release of Protected Health Information Form paper scanned
Build HIway consent into PHS e-care registration system (deploying over next 3 yrs) Sync with registration workflow Use e-form/signature pads & update form status Received (populates when patient signs) Patient Refused (staff selects if patient opts-out) Unable to Obtain (staff selects if applicable (e.g.: patient undecided)) Sites not on e-care are building or using existing flags in their local registration systems e-care and local systems interface with PHS EMPI EMPI populates future encounter visits MGH went live with e-care registration system in July
Use patient portal to collect consent Show EMPI consent status in the EHR for clinicians to use Flip Consent flag in the EHR allows a variety of workflows for obtaining consent medical assistants, nurses and other staff may obtain consent beyond the front desk
BICS will query EMPI at registration to determine if a consent already exists Consent is captured in BICS and transmitted to EMPI Consent is captured in Epic and transmitted to EMPI BICS Consent Data EMPI Single consent for all sites. Applies to all service areas in Epic. July 2014 Consent Data (Future) Epic to accept consent data from EMPI (Future) potentially other sites
HIway Consent Implementation Workgroup Met weekly since 2/12/14 to drive consent solution Health Information Services Information Systems Patient Access - Registration Areas PeCare Providers Legal Endorsed and supported by senior leadership via HIE Steering Committee
Establish governance and structure to effectively operationalize HIE Transition Consent Implementation workgroup into HIE Operating Committee set goals and objectives for 2014/2015 align with other existing committees efforts to accomplish MU/HIE goals, create efficiency and value determine required membership to get started
Dr. John Halamka Beth Israel Deaconess Medical Center
Existing processes General Consent form Medical Records release Example from the Social Security Administration
The push use case Automating existing processes Organized Health Care Arrangement issues, affiliates, and third parties HIPAA Considerations
The pull use case Meeting the needs of many stakeholders Putting the patients first Passing the Boston Globe Test The final solution Withdrawing consent
Discussion & Questions Sean Kennedy, MPH, MS, PMP Health Information Exchange Director Massachusetts ehealth Institute kennedy@masstech.org Amy Caron, MPH Project Manager for Mass HIway Communications, Outreach, Education Executive Office of Health and Human Services Christine Griffin Health Information Services Manager Massachusetts General Hospital, Health Information Services John Halamka, MD, MS CIO Beth Israel Deaconess Medical Center amy.caron@state.ma.us cgriffin7@partners.org jhalamka@bidmc.harvard.edu http://geekdoctor.blogspot.com 35 Massachusetts ehealth Institute
NEXT WEBINAR! Effective and Proper Use of the Mass HIway Directory Thursday, October 9 at 12:00pm-1:00pm The state's health information exchange network, the Mass HIway, is a secure way for health information to be shared among providers and organizations. The Mass HIway Directory, also referred to as the Provider Directory (PD), is a listing of authorized users of the Mass HIway that can actively send and/or receive information over the network. This session will include an overview of the Directory's components, best practices on listing your organization within the Directory, the proper usage of the Directory, and how to help ensure effective transmission of health information and communication with other Mass HIway participants. 36 Register at http://mehi.masstech.org/calendar/event/2896
617-371-3999 ehealth@masstech.org @MassEHealth www.mehi.masstech.org