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781-890-7446 Health Delivery Services May 29, 2009 1
Eastern Massachusetts Healthcare Initiative
Policy Work GroupSession 2
May 29, 2009
781-890-7446 Health Delivery Services May 29, 2009 2
Agenda
• Progress and Remaining Activities
• Resolution of Previous Issues
• New Questions and Issues
• Policy Framework Document
• Next Steps
781-890-7446 Health Delivery Services May 29, 2009 3
Policy Group Work Session Plan
Period Agenda Preparation
Thru May 8Complete
• Obtain agreement on approach, schedule, and work group membership
• Obtain agreement on scope• Review general principles• Review policy document outline• Review example policies• Review open questions/issues
• Request existing policies from work group members and other groups
• Research policies from NEHEN/MA-SHARE and other sources
• Document principles• Develop policy document outline• Develop example policies• Document open questions/issues
May 29 • Hold Policy Work Group Meeting:• Review draft policies• Review open questions and issues• Assign follow-up responsibilities
• Develop additional policies
June 5 • Distribute interim work products to Advisory Group
• Prepare presentation outlining framework, content, open questions/issues
June 12 • Send policy framework to other EMHI members for review
• Update framework• Prepare summary presentation
June 19 • Hold Policy Work Group Meeting:• Review final framework/policies• Review open questions and issues• Assign follow-up responsibilities
• Develop/update policies• Finalize policy document• Draft plan for maintaining policies• Draft communication plan
June 26 • Present framework to Advisory Group • Prepare presentation outlining framework, content, open questions/issues
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Policy Guiding Principles
• General– Decisions Based on Guiding Principles
– Openness and Transparency
– Patients’ Rights
– Patient Access and Participation
– Data Collection and Use Limitation
– Privacy and Security Policy Compliance
– Coordinated Decentralization
– Broad Adoptability
– Anticipation of Change
• Technical– Open Standards
– Federated Data Architecture
– Flexibility and Agility
– No Rip and Replace
– Multiple Implementation Models
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Definitions
• Participant: A Provider Organization, Payer Organization, or Other Organization that has directly entered into a Data Sharing Agreement with NEHEN, accesses Protected Health Information via NEHEN, and actively participates in the exchange of electronic healthcare data via NEHEN.
• Sending Participant: A Participant engaged in sending clinical data to another Participant via NEHEN.
• Receiving Participant: A Participant engaged in receiving clinical data from another Participant via NEHEN.
• Sending User: A person who is associated with a NEHEN Participant and sends clinical data via that association.
• Receiving User: A person who is associated with a NEHEN Participant and receives clinical data via that association.
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Policy Questions and Issues:Resolutions for Review
• What is NEHEN’s responsibility as regards Participant compliance with data sharing agreements and policies? Assume compliance or audit for compliance?
– Resolution: Create a "statement of compliance" and require a legal signatory of the Participant to sign on an annual basis. The statement should include the right to make unannounced audits regarding privacy at any time.
• Should all disclosures be reported to a patient upon patient request, or just selected disclosures?
– Resolution: Report on all disclosures based on available data. Provide capabilities for Participants to use local NEHEN audit logs in their disclosure reporting work flows.
• What should be the baseline for privacy and security protection—meeting minimum legal requirements or developing/meeting community best practices?
– Resolution: Meet minimum legal requirements. Review Participant practices, and consider common practices for “best practice” implementation.
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Policy Questions and Issues for Discussion:Responsibilities of the Exchange
• Do we need to define the purpose of the exchange to address the issue of the Receiving Participant/User’s liability (e.g., lab results received by a physician other than the physician who ordered the test)?
– Examples:• The intent of the exchange is to support “live care”
• The intent of the exchange is to support “better care management”
• Must NEHEN restrict participation in order to comply with legal requirements, including state laws?
– Examples:• May individuals and organizations operating in/licensed in New England states other than
Massachusetts be users of the clinical data exchange? Must NEHEN policies address requirements for those states (e.g., sensitive information requirements)?
• Can an organization operating in/licensed in another state be made responsible for compliance with that state’s laws?
• May an individual operating in/licensed in another state be a user of the exchange?
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Policy Questions and Issues for Discussion:Responsibilities of the Exchange
• Are NEHEN and/or Participants responsible for :– Attempting to influence legislation?
– Educating the public about the exchange of clinical data?
– Informing users of the potential for increased liability due to increased availability of information?
– Informing or training Users on appropriate use of the exchange?
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Policy Questions and Issues for Discussion:Responsibilities of Persons/Organizations Receiving Messages
• Must a Receiving Participant/User view a message received from an external source?
– Examples:• May a receiver “turn off” receipt of some or all messages?
• May a receiver “reject” a message that has been appropriately addressed?
• May a receiver discard a message without viewing it?
• What are a Receiving Participant/User’s responsibilities for acknowledging a message?
– Examples:• Notify the sender that the message was received.
• Notify the sender that the message was delivered to its final destination.
• Notify the sender that the message could not be delivered (i.e., “addressee unknown”)
• Notify the sender that the message was addressed to the wrong recipient (i.e., “not me”)
• Must a Receiving Participant/User retain a message received from an external source?
• May a Receiving Participant/User specify preferences for how/when they receive messages regardless of message type (e.g., “as soon as available”, “bundled” at end of day)?
781-890-7446 Health Delivery Services May 29, 2009 10
Policy Questions and Issues for Discussion:Responsibilities of Persons/Organizations Sending Messages
• May/must a Sending Participant/User include in a message information that was received from an external source (i.e., not originally collected by the sender)?
– If so, should it be identified as having come from an external source?
• Must a Sending Participant/User resolve ambiguous destinations for a Receiving User (e.g., a physician who practices in multiple organizations or physical locations)
– May/must a Receiving User identify a “preferred address” for cases where the ambiguity is not resolved?
• May a Sending Participant/User specify preferences for how and when messages will be delivered (e.g., specify urgency or method of delivery)?
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Policy Questions and Issues for Discussion:Provider Registration/Addressing
• May a message be addressed to an organization rather than an individual (e.g., a clinic or a CHC)?
• May a message be addressed to a Receiving Practitioner who is other than a licensed care provider?
• May a message be addressed to a Receiving Participant who acts as an intermediary for practitioners (e.g., a vendor offering portal access)?
• Must a Receiving Practitioner be affiliated with a Receiving Participant organization for the purpose of authentication, authorization, and routing?
– Examples:• California pediatrician refers patients to Children’s and wishes to be “added” as a Children’s user.
• MMS or a vendor wishes to offer portal access.
• NEHEN wishes to make access available via the NEHEN Portal.
• Must NEHEN or the Participant organization obtain a provider’s consent to register the provider in the community directory?
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Next Steps
• Distribute update to Advisory Committee week of June 1
• Incorporate today’s decisions and redistribute draft for Policy Group review week of June 1
• Distribute draft document and summary presentation to EMHI members not represented on Policy Group week of June 1 or June 8