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Larry Wolf, chair Marc Probst, co-chair Certification / Adoption Workgroup March 4, 2014
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Certification / Adoption Workgroup

Feb 25, 2016

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Certification / Adoption Workgroup. Larry Wolf, chair Marc Probst , co-chair. March 4, 2014. Agenda. Review of Agenda 2015 Edition NPRM Update, Steve Posnack Review Final LTPAC/BH EHR Certification Recommendations HITPC Privacy and Security Tiger Team Update, Deven McGraw - PowerPoint PPT Presentation
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Page 1: Certification / Adoption Workgroup

Larry Wolf, chairMarc Probst, co-chair

Certification / Adoption Workgroup

March 4, 2014

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Agenda

• Review of Agenda• 2015 Edition NPRM Update, Steve Posnack• Review Final LTPAC/BH EHR Certification

Recommendations • HITPC Privacy and Security Tiger Team

Update, Deven McGraw • Next Steps• Public Comment

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Updated C/A WG Schedule

Date Schedule 2/21/2014, 3/4/2014 Workgroup review and finalization of LTPAC/BH EHR

certification recommendations

3/6/2014 Finalize LTPAC/BH recommendations; Workgroup review of standard occupational classification codes recommendations

3/11/2014 Recommendations to HITPC3/19/2014 Discuss feedback from March HITPC meeting, update

recommendations as needed

3/26/2014 Update to the HITSC4/2/2014 Update recommendations as needed4/8/2014 Revised recommendations to HITPC (if needed)

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2015 Edition

2015 Edition Notice of Proposed Rulemaking

- Steve Posnack -

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2015 Edition EHR Certification

• Certification Criteria Proposals:– Standards updated– FAQs addressed / bugs fixed– Incremental step with significant gap certification available

• Certification Program Proposals:– Propose to discontinue issuance of “Complete EHR”

certification – Propose “package” concept as a way to label multiple

certification criteria in a common grouping– Propose MU/non-MU distinction as part of certification

• Request for Comment for 2015 and 2017 Edition

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The future: 3-year ONC Rulemaking Roadmap(milestones reflect best guestimates)

Q1CY 2014 CY 2015 CY 2016

2015Ed NPRM

2015Ed Final

PublicComment 2017Ed

Final

2018Ed NPRM

PublicComment

PublicComment

2017Ed NPRM

& MU3 NPRM

& MU3 Final

MU2 EPStart Date

Announced Anticipated

MU3 EHStart Date

Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

2018Ed Final

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Resource Allocation Comparison: Rulemaking vs HIT Developer (with incremental rules)

Published 2010“2011 Edition”

Published 2012“2014 Edition”

Published 2015“2017 Edition”

Published 2014“2015 Edition”

1-year gap

Published 2016“2018 Edition”

1-year gap2-year gap2-year gap

MU1MU1MU2

MU1MU2MU3

0%

100%

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Review Final LTPAC and BH EHR Certification

Recommendations

PROPOSED LTPAC EHR

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Organizing Principles for Recommendations

For ALL Providers• Transition of Care• Privacy and Security• Enhancements to Privacy and Security

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For some LTPAC and BH Providers• Clinical Reconciliation• Clinical Health Information• Labs/Imaging• Medication-related• CPOE• Clinical Decision Support• Quality Measures• Patient Engagement• Advanced Care Planning• Data Portability• Public Health - Transmission to Immunization Registries (LTPAC only)

LTPAC Setting-Specific• Patient Assessments• Survey and Certification BH Setting-Specific• Patient Assessments• Consent Management (included under

Enhancements to Privacy and Security)

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Recommendations for ALL Providers

• Support the ability to receive, display, incorporate, create and transmit summary care records with a common data set in accordance with the Consolidated Clinical Document Architecture (CCDA) standard and using ONC specified transport specifications.(reference: §170.314(b)(1) , 45 CFR §170.314(b)(2))

• In addition, if approved by HHS for MU3, support the inclusion of emerging TOC and care planning standards being reconciled as part of Aug. HL7 CCDA ballot. [MUWG-identified MU 3 criteria].

Transitions of Care

• Support existing ONC-certified Privacy and Security requirements:

§ 170.314(d)(1) - Authentication, Access Control, and Authorization

§ 170.314(d)(2) - Auditable Events and Tamper-Resistance

§ 170.314(d)(3) - Audit Report(s)§ 170.314(d)(4) - Amendments§ 170.314(d)(5) - Automatic Log-Off§ 170.314(d)(6) - Emergency Access § 170.314(d)(7) - End-User Device Encryption § 170.314(d)(8) - Integrity § 170.314(d)(9) – Optional: Accounting of Disclosures

• HHS should support educational awareness initiatives for LTPAC/BH providers, incl. informing these providers that compliance with HIPAA requires actions that extend beyond the ONC-certified privacy and security criteria.

Privacy and Security

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Recommendations for ALL Providers

C/A WG requests that the P&S TT examine the proposed areas for certification for ALL providers (MU and non-MU) and provide recommendations to the HITPC:

Use of the HL7 privacy and security classification system standards to tag records to communicate privacy related obligations with the receiver.

Standards for controlling re-disclosure of protected data ONC should consider supporting equivalent functionality in MU 3 for standards for communicating

privacy policies and controlling re-disclosure of protected data. Developing consensus on standards for consent management functionality needed by BH providers to

comply with diverse federal and state confidentiality laws , including the Data Segmentation for Privacy Standard

Future work: Incorporate granular data segmentation when such standards are available.

Enhancements to Privacy and Security

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LTPAC Setting Specific Recommendations

• NEW Support the ability to create, maintain, and transmit (in accordance with CMS requirements) assessment instruments and data sets for LTPAC: MDS 3.0 (Nursing Homes), OASIC-C (Home Health) , IRF-PAI (Inpatient Rehabilitation Facility), CARE subset (for Long Term Care Hospital), and a Hospice Item Set.

• NEW Support the use of accepted vocabulary standards to enable the reuse of assessment data for: o various clinical purposes; and o administrative purposes.

• NEW Support the ability of the provider or a designated third party to create and exchange interoperable LTPAC Assessment Summary CDA documents

• Recommend HITSC examine the availability and readiness of vocabulary standards for patient assessments and the LTPAC Assessment Summary CDA documents.

FUTURE WORK• Harmonization of federal content and format for patient assessments with ONC specified EHR

standards (e.g. consistent standards on demographics).• Make the data element library publically available and link content to nationally accepted standards.

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LTPAC Patient Assessments

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Behavioral HealthSetting Specific Recommendation

FUTURE WORK:

• Recommend identification of vocabulary standards and data definitions to support behavioral health patient assessments.

• Recommend analysis of available standards and provide clarification on which standards are applicable to behavioral health patient assessments. If gaps exist, expand upon existing standards to develop relevant certification criteria for this purpose.

Available standards:HL7 Implementation Guide for CDA® Release 2: Patient Assessments, Release 1http://www.hl7.org/implement/standards/product_brief.cfm?product_id=21

HL7 Version 3 Domain Analysis Model: Summary Behavioral Health Record, Release 1 – US Realmhttps://www.hl7.org/implement/standards/product_brief.cfm?product_id=307

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BH Patient Assessments

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Why is there a “some” provider category?

• Not all LTPAC/BH providers need the same certification capabilities.

• BUT, there are certain criteria that we have learned is important to ‘some’ LTPAC/BH providers.

• Through a modular approach, certification of these capabilities could support providers and help improve patient care.

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Recommendations for Some LTPAC/BHProviders

Support the ability of a user to electronically reconcile the data that represents a patient’s active medication, problem, and medication allergy list. (Reference: § 170.314(b)(4))

Clinical Reconciliation

• Support the ability to record, change, and access the following data using ONC specified standards:

o Demographics - § 170.314(a)(3) o Problem list - § 170.314(a)(5) o Medication list - § 170.314(a)(6) o Medication allergy list - §170.314(a)(7) o Family health history - § 170.314(a)(13) o Smoking status - § 170.314(a)(11)

• Support the ability for a user to electronically record, change, access, and search electronic notes. (Reference: § 170.314(a)(9))

• Support ability to electronically and dynamically select, sort, access, and create patient lists. (Reference: § 170.314(a)(14))

• NEW ONC should consider including DSM-5 vocabulary standards in certification programs for ALL providers

Clinical Health Information

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Recommendations for Some LTPAC/BHProviders

Support the ability for an ambulatory setting to be capable of electronically receiving, incorporating, and displaying clinical lab tests and values/results. (Reference: § 170.314(b)(5))

Support the ability for an inpatient setting to be able to generate lab test reports for e-transmission to ambulatory provider’s EHR systems. (Reference: § 170.314(b)(6))

NEW Support the ability to electronically receive and incorporate narrative interpretations

NEW Support the ability to indicate to a user the availability of a patient’s images

NEW Support access to the patient’s images.

Labs/Imaging Medication Related

Support the ability for a user to electronically create and transmit prescriptions/rx-related information. (Reference: § 170.314(b)(3))

Support the ability to automatically and electronically check whether a drug formulary exists for a given patient or med. (Reference: § 170.314(a)(10) )

Support the ability to enable drug-drug and drug-allergy interaction checks. (Reference: § 170.314(a)(2))

Support electronic medication administration record.(Reference: § 170.314(a)(16))

CPOE

• Support the ability to electronically record, change, and access the following order types: Medications; Laboratory; and Radiology/imaging. (Reference: § 170.314(a)(1))

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Recommendation for Some LTPAC/BHProviders

- Support the ability to have: Evidence-based decision support Linked referential clinical

decision support Clinical decision support

configuration Automatically and electronically

interact Source attributes(Reference § 170.314(a)(8))

Clinical Decision Support Quality Measures

C/A Workgroup requested that HITPC Quality Measures WG discuss clinical quality measures further and provide recommendations to C/A WG on potential LTPAC CQM opportunities for LTPAC EHR certification.

Patient Engagement

Support the ability to provide secure online access to health information for patients and authorized representatives to electronically view, download their health information in accordance with the CCDA standard and transmit such information using ONC specified transport specs. (Reference: § 170.314(e)(1))

Support the ability to enable a user to create a clinical summary in accordance with the CCDA standard in order to provide it to a patient. (Reference: § 170.314(e)(2))

Support the ability to use secure electronic messaging to communicate with patients on relevant health information. (Reference: § 170.314(e)(3) )

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Recommendation for Some LTPAC/BHProviders

•§ 170.314(a)(14) - Support the ability to record whether an advance directive exists for the patient

In addition, if approved by HHS for MU3, support the ability to store an advance directive document in the record or provide a link to the advance directive in a repository or other location. [MUWG-identified MU 3 criteria].

Future work: Standards for content of the advance directive

Future work: Standards for content of the advance

directive

Advance Care Planning

Public Health Transmission to Immunization Registries(LTPAC Only)•Request that the MUWG examine whether there is a need to collect public health immunization information from LTPAC settings and whether certification could support the need.

Data Portability

• § 170.314(b)(7) - Support the ability to electronically create a set of export summaries on all patients, formatted in accordance with the CCDA.

More info was requested on previous WG call. See below.

• The data portability criterion is meant (as a first step) to support data migration if a provider were changing systems.

• Question: Does the MU2 final rule address receiving the CCDA?

• Answer: Yes, this is addressed in 170.314(b)(1). “Receive, display, incorporate" is one of two TOC certification criteria. 19

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Additional WG Recommendations

• Some WG members commented that ‘past history’ is not part of the MU certification criteria but noted that this information can be important, particularly in LTPAC/BH. Clarification needed: Is this criteria being recommended for inclusion in certification ? By ALL providers?

• As ONC explores LTPAC/BH certification, the WG recommends that ONC track national trends in LTPAC health IT adoption. Such efforts should include tracking use by functionality and criteria.

• National survey data on LTPAC/BH EHR adoption and use should utilize definitions that are consistent with those in the MU program.

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Appendix

Appendix

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Factors Driving LTPAC and BH Adoption of Health IT

Payment Models

Care Coordination

Performance Improvement

Administrative Efficiencies

HIT Funding (as available)

Consumer Engagement

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Factors Driving LTPAC and BH Certification of Health IT

Care Coordination HIT Funding (as available)

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Certification Criteria Principles

• Leverage existing certification program• Voluntary• Modular• Interoperability (exchange and use across organizations)• Privacy and Security (with enhancements)• Setting-specific needs

(assessments, code sets, group documentation)• Alignment across state and federal programs• Minimum burden• Limited funding• Very heterogeneous provider group

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Goal: All-Provider Criteria

Eligible Hospital

Eligible Professional

Long-Term/Post-Acute Care

Behavioral HealthEligible Hospital

Eligible Professional

Goal: All-Provider CriteriaCurrent State

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