Toward Enhanced Information Capacities for Health: Achieving the Promise: NCVHS

NCVHS Concept Paper Looks How to Achieve the
Promise of Health Reform and Electronic Health Records
The National Committee on Vital and Health Statistics (NCVHS) met June 16-17, 2010 in Washington, DC, and used the NCVHS concept paper “Toward Enhanced Information Capacities for Health” as the basis of discussions for their 6oth Anniversary Symposium of the committee. The paper, issued May 26, 2010, focuses on policies HHS could establish to maximize the benefits that could be acheived through the appropriate use of the tremendous amount of health data that will be generated with Electronic Health Records.

The committee advises the Secretary of  HHS on policies toward health data, statistics, privacy, national health information policy, and Administrative Simplication of HIPAA.

NCVHS Concept Paper
“Toward Enhanced Information Capabilities for Health”
PDF FORMAT
The text of the 11-page paper is reproduced in whole below.

EXECUTIVE SUMMARYHealth care reform and federal stimulus legislation have created an unprecedented opportunity to improve health and health care in the United States. The nation’s ability to seize this opportunity will depend greatly on the existence of robust health information capacities. The National Committee on Vital and Health Statistics (NCVHS) is the statutory advisory body on health information policy to the Department of Health and Human Services. On the occasion of the Committee’s 60th anniversary, this concept paper outlines its current thinking about the necessary information capacities and how NCVHS can help the Department guide their development.

We are entering a new chapter in the health and health care of Americans. The expansion of health care coverage, the infusion of new funds and adoption of standards for electronic health records (EHRs), and increased administrative simplification offer us the potential to use the enriched data generated to better address our country’s health and health care challenges. Having better information with which to measure and understand the processes, episodes, and outcomes of care as well as the determinants of health can bring considerable health benefits, not only to individuals but also to the population as a whole.

To be able to achieve the promise of these new developments, we need to be attentive to the underpinnings of the data, ensuring that they are easy to generate and use at the front lines as well as easy to reuse, manipulate, link, and learn from within a mantle of privacy and security. It is important to remember that the new data sources are not necessarily a replacement for traditional sources such as administrative and survey data, which play a key role in our infrastructure. Rather, the new sources present an opportunity to augment and enrich traditional sources. While efficiency may be gained by replacing some survey and administrative data with newer EHR data, we must continue to nourish and sustain the traditional data sources that offer unique and irreplaceable information for both clinical and population health purposes.

National health information capacities must enable not just better clinical care but also population health and the many synergies between the two. More specifically, health information policy should foster improved access to affordable, efficient, quality health care; enhanced clinical care delivery; greater patient safety; empowered and engaged patients and consumers; patient trust in the protection of their health information; continuous improvement in population health and the elimination of health disparities; and support of clinical and health services research. A major priority of health information policy should be to enable the multiple uses of data, drawn from the full range of sources, while minimizing burden. Most sources have primary uses for which they were designed; however, with adequate standardization, privacy protections, and technology, the data from many sources can be used for multiple purposes. Realizing the collective potential of all information sources is what will allow the U.S. to maximize the return on its investments in system reform and health IT for the benefit of all Americans.

As information capacities expand, it is critical that the information be comprehensive, timely, efficiently retrievable, and usable, with full individual privacy protections in place. “Comprehensive” refers to the inclusion not just of traditional health-related data, but also of data on the full array of determinants of health, including community attributes and cultural context. Usability of the data—whether for initial use or reuse―requires a well-coordinated effort to assure the accessibility and availability of information as well as its standardization.

NCVHS will continue to use its consultative and deliberative processes, working collaboratively with other HHS advisory committees, to help the Department meet these opportunities and challenges. Given the rapidity of the changes now under way, we cannot over-emphasize the urgency of this endeavor and the need to move ahead with deliberate speed.

INTRODUCTION

Health care reform and federal stimulus legislation have created an unprecedented opportunity to improve health and health care in the United States. The nation’s ability to seize this opportunity will depend greatly on the existence of robust health information capacities. 1 To maximize the return on these enormous investments and make it possible to evaluate their impact, health information capacities must be carefully developed with an eye to their uses for improving health care and health for all Americans. New investments in EHRs and health information exchanges are important contributors, especially for clinical care, but the benefits from these investments will be limited unless the synergies with other types of health information are recognized and used. Population-level data from vital statistics systems, surveys, and public health surveillance and health care administrative data are equally important information sources. Assuring that all these sources are adequately developed and supported and can be integrated appropriately is essential to developing the information capacities the nation needs.

The National Committee on Vital and Health Statistics, the Department’s statutory advisory body on health information policy, has long assisted the Department in the development of national health information policy, providing thought leadership and expert advice in the areas of population health, privacy, standards, the NHII/NHIN, health care quality, and more. Nearly ten years ago, NCVHS put forward a vision for a national health information infrastructure in its 2001 report, Information for Health,2 followed in 2002 by a vision for 21st century health statistics.3 Today, as data and communication capacities explode and health care coverage expands, new thinking and visioning are needed to clarify the information capacities that will make it possible to meet our national goals for better health and health care for all Americans. On the occasion of the Committee’s 60th anniversary, this concept paper outlines its current thinking about the required capacities and their development.

In 2009, as course-altering legislation was unfolding, NCVHS began to consider how it could assist the Department’s development of the necessary information capacities.4 All four NCVHS subcommittees have contributed to the early thinking on this subject, and all plan further work

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1 We use the term capacities in the sense of the ability to perform or produce. That is, information capacities are understood in relation to specific needs, purposes, and functions of information.
2 NCVHS, Information for Health: A Strategy for Building the National Health Information Infrastructure, November 2001.
3 NCVHS, Shaping a Health Statistics Vision for the 21st Century, November 2002.
4 As part of this process, NCVHS in 2009 commissioned two authors of the 2002 health statistics vision report to help the Committee consolidate and update its recommendations. Their report to the Committee is posted on the NCVHS website. < http://www.ncvhs.hhs.gov/090922p3.pdf >
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in their respective domains, as described below. 5 The Committee has crafted a highly effective process for bringing multiple points of view and areas of expertise to bear as it develops recommendations to the Secretary, and this process is well suited to the work that lies ahead. NCVHS will continue to use its consultative process to create venues for dialog, eliciting input and perspectives from stakeholders and experts regarding critical challenges, potential opportunities, and next steps. It will use this external input and its own broad expertise to help the Department develop health information policies that are commensurate with new opportunities and needs. Given the rapidity of the changes now under way, we cannot over- emphasize the urgency of this endeavor and the need to move ahead with deliberate speed.

INFORMATION CAPACITIES FOR HEALTH AND HEALTH CAREPublic sector involvement in health information has a long history. State, local, and federal agencies have gathered information through vital records, hospital and ambulatory data sets, public health surveillance, population surveys, and other sources to monitor health trends, identify threats, and guide interventions to protect and promote health. Congress initiated a new type of government involvement in 1996 when the Health Information Portability and Accountability Act (HIPAA) recognized the importance of protecting individuals’ health care information while improving the efficiency of health care delivery through standardized electronic administrative transactions. Most recently, the American Recovery and Reinvestment Act of 2009 (ARRA) began another type of intervention, providing financial incentives for health IT adoption in the nation’s hospitals and physician offices as well as funding for infrastructure support.

While much current attention is focused on the ARRA funding of health IT and critical associated tasks such as defining and implementing “meaningful use” of EHRs, a broader perspective is required to take full advantage of evolving opportunities. Widespread use of optimally configured, standardized EHRs will greatly expand the information available on health care services, users, and providers. However, promoting the health and wellness of the population also requires information about those who have not received health care services, among other things, as well as information on other determinants of health beyond traditional health care, including environmental, social, and economic factors.6

In short, national health information capacities must support a broad array of uses and purposes that include improving access to affordable and efficient quality health care, supporting clinicians in delivering care, empowering and engaging patients and consumers in their care,
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5 At present, NCVHS has subcommittees on population health, standards, quality, and privacy/confidentiality/security.
6 See the NCVHS-developed graphic of the determinants of health on page 9 of its report on a vision for 21st century health statistics (see note 3).
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ensuring patient safety, promoting patient trust, eliminating health disparities, monitoring and improving population health, and supporting health services and clinical research. As these capacities are developed, it is critical that the information being collected be comprehensive, timely, efficiently retrievable, and usable, and that individual privacy be protected.

In the Committee’s view, this requires a well-coordinated effort that assures the following:

1.  Accessibility and availability of information. The availability of sufficient, timely information from relevant sources must be assured to meet the priority needs of diverse users (including clinicians, consumers, purchasers, payors, researchers, public health officials, regulators, and policymakers) for taking action and evaluating outcomes. To minimize burden, wherever possible data should be collected once, for multiple appropriate uses by authorized users. Where appropriate, the capacity to connect data from multiple sources should be provided.

2.  Standardization. Standardization is necessary to enable interoperability for the efficient collection and timely sharing of information among all types of users. Robust standards should be assured through the definition, application, and adoption of terminologies, codes, and messaging in the areas of reimbursement, public health, regulation, statistical use, clinical use, e-prescribing, and clinical documents.

3.  Privacy, confidentiality, and security protections. With the increasing adoption of interoperable electronic health records technology, along with the move toward global access to health data and emerging new uses of data, methods of access and information availability raise significant new and unique privacy and security concerns. Appropriate privacy, confidentiality, and security protections; data stewardship; governance; and an understanding of shared responsibility for the proper collection, management, sharing, and use of health data are critical to addressing these concerns.

Each is briefly discussed below.

1. ACCESSIBILITY AND AVAILABILITY OF INFORMATION

In today’s world, the boundaries between health care, population health, and even individual personal health management are permeable, and information exchange is increasingly multi- directional. The domains traditionally called “public health” and “health care” are increasingly intertwined, often sharing broad, common information sources and capacities. For example, promoting the health and wellness of individuals and the population requires attention to health determinants including not only the treatment and prevention of disease and the nature of community health resources but also environmental, housing, educational, nutritional, economic, and other influences. Continuously improving the quality, value, and safety of health care involves, among other things, research and knowledge management, meaningful performance measurement, education and workforce development, and support for personal and family health management. Finally, improving health and health care on a national scale requires monitoring and eliminating health disparities and assessing the health status of all Americans, including vulnerable sub-populations.

A major priority of health information policy should be to facilitate these interconnections and enable the multiple uses of information for current and emerging data needs. With health IT, complemented by the necessary privacy protections and data stewardship and facilitated by well designed standards, data can be combined to create richer information and used to address a broad array of current and emerging health and health care issues. Realizing the collective potential of all information sources is what will allow the U.S. to maximize the return on its investments in system reform and health IT for the benefit of all Americans.

At present, the major sources of data on health are:

       Surveys (interview and examination) and Censuses    Public health surveillance data (e.g., notifiable disease reporting, medical device reporting)        Health care data (EHRs, HIEs, registries, and other such as prescription history, labs, imaging)
      Administrative data (claims, hospital discharge data, vital records)
      Research data (community-based studies, clinical trials, research data repositories)

Another essential set of sources for understanding health is the information on influences on health (including transportation, housing, air and water quality, land use, education, and economic factors) managed by various public and private sector agencies. In addition to all these well-established sources, new ones such as personal health records and computerized personal health monitoring devices are emerging with the potential to contribute to understanding health at individual and population levels. Social networking content has the potential to provide yet another new and novel resource.

Most data sources have primary uses for which they were designed. However, given adequate standardization, privacy protections, and informatics technology, these sources have great potential to be used for multiple purposes. For example, EHR data elements are collected to document and manage clinical care, but also can be used for public health reporting (such as communicable diseases and medication safety) and to evaluate population health and conduct health services research. Surveys are principally for population-level analysis, but survey information also contributes to clinical care. Vital records not only provide information about births and deaths, but also serve as the “bookends” of population health data. Administrative data (ICD-9-CM disease codes and CPT-4/HCPS procedure codes) were initially used for management and reimbursement, but today play a critical role in quality assessment and public health monitoring (e.g., quality and safety indicators and disease prevalence evaluation). As we look to the future, the goal is to leverage all these sources, when appropriate, and expand their utility for understanding personal and population health and their determinants while carefully protecting the confidentiality of the data they contain.

To bring about the needed improvements and efficiencies and draw all possible benefit from the large and growing investment in health IT, the emerging information capacities must enable both more effective and cost-effective clinical services and population health promotion, and their many synergies. This can be facilitated through multi-directional data sharing and linkages to generate information that is comprehensive and broadly representative. It will be critical to break down the silos that now make it difficult to share and connect data. This requires addressing the policy, institutional, technical, and other barriers that contribute to the existing silos. A workforce trained to take advantage of the broader data and informatics capacities is also essential. Detailed local data are needed to enable understanding of health and health care at local neighborhood, community, sub-population, and other levels of aggregation. Key decisions about health and health care are made at the local level, and we envision the potential to meet these needs in ways not previously possible. Finally, a critical use of population health data, especially with the advent of health care reform, is to assess the effectiveness, comparative effectiveness, and equity of health care.

Because resources are limited and burden must be minimized, information policy must set priorities regarding which data are most important in order to target investments in data collection. As noted, burden can be minimized by collecting data once for multiple uses. At least in the near term, provided that data can be put in the hands of trusted stewards, enhanced administrative data may be a powerful component that reduces the burden of multiple collections. As new capacities come on line, it may be possible to curtail or redirect some current collection activities.

An important criterion is that information, whatever its source, must be meaningful to users. Experience has demonstrated that having relevant data and information available does not ensure that it is accessible in a timely manner and useful form to the full range of potential users. Delays may be created by approval processes or regulatory requirements, as well as by the lack of data handling and analysis capacities that could enable a user to pose a question, indentify relevant data sources, and request a report that is understandable and protects the privacy of data sources. Ensuring access to useful information is a critical part of the challenge. An overarching goal of all these endeavors is to assure that data can be converted into information and ultimately into knowledge that can answer the priority questions about personal and population health in the U.S. and enable effective decisions and actions to improve them.

2.  STANDARDS FOR INTEROPERABILITY, USABILITY, QUALITY, SAFETY, AND EFFICIENCY

The purposes of health information standards are to ensure the efficient, secure, safe, and effective delivery of high quality health care and population health services; to support the information exchange needs of health care, public health, and research; and to empower consumers to improve their health.

The impending implementation of the next generation of HIPAA standards, the enactment of The Health Information Technology for Economic and Clinical Health (HITECH) Act in 2009, and the recent signing of health reform into law are creating an unprecedented convergence of driving forces, foundational components, technology advances and capabilities, and regulatory requirements. Together, these assets can help create a common national pathway toward achieving the vision and policy priorities of a 21st century health system that relies on a strong health information and health information technology foundation. The past five years have seen a remarkable transformation in the adoption and use of standards for electronic exchange of health information. The transformation encompasses privacy and security standards, standards for administrative and financial transactions, the establishment of unique identifiers, and more recently the adoption of standards for codifying, packaging, and transmitting clinical information between and across health care organizations. This rapidly evolving transformation is moving us closer to the ideal of a fully interoperable electronic health information collection and exchange environment that supports all functions and needs of the country’s health and health care ecosystem, as discussed in the previous pages.

Data standards provide a key architectural building block that supports the collection, use, and exchange of health information. Health information standards have been developed and are being adopted and implemented in many different areas. Capturing information in codified format through standard representations such as clinical vocabularies and terminologies, code sets, classification systems, and definitions is a key strategy for achieving semantic interoperability. The inclusion of standardized metadata, which describe characteristics of the data such as provenance, increases the potential for assessing the reliability and validity of the data for aggregation, research, and other uses. Organizing and packaging data through defined electronic message and document standards to be accessed and exchanged via standardized electronic transport mechanisms and protocols achieves access and exchange of health information. The availability and integrity of health information is protected and ensured through the deployment of security standards, thus guaranteeing confidentiality and privacy of protected health information. Finally, the certification of health information technology for Meaningful Use depends on the wise deployment and use of health information standards.

3. PRIVACY, CONFIDENTIALITY, SECURITY

With the move toward the management of health data in electronic form, there is a significant opportunity to enhance health data access, utility in patient care, and important secondary uses. The opportunity is further enhanced through the emergence of new methods to exchange health data, both on a regional and national basis. However, the ability to realize the potential of electronic health data depends greatly on ensuring that uses are appropriate and individuals’ reasonable privacy, confidentiality, and security expectations are met.

Individuals should have the right to understand how their health data may be used, and to provide consent where appropriate. Often, consent is difficult, as not all uses are known at the time the health data are collected. Further, standards do not yet exist to track an individual’s consent as data are exchanged. Although many of the population health uses described in this concept paper involve aggregated or de-identified health data, legitimate concerns exist about group harms and possible re-identification. In addition, the possibility of using health data from emerging information sources, such as personal health record systems, raises unique privacy concerns.

NCVHS has discussed many of these privacy challenges in numerous reports and letters to the Secretary. Most notably, NCVHS published two reports, a Primer on health data stewardship 7 and Recommendations on Privacy and Confidentiality, 2006-2008. Both are available on the NVCHS website.8

Further work is necessary to develop the privacy, confidentiality, and security standards that should apply as these data uses continue to evolve. In addition, work is needed to establish governance structures to provide the proper oversight of entities that exchange and use health data. In essence, governance is the accountability for ensuring that proper data stewardship (as described in the NCVHS Primer cited above) is practiced. To differentiate between governance and data stewardship, data stewardship is focused on the internal practices of the entity that uses health data, whereas governance is focused on the oversight of such entities to ensure that their data stewardship practices are adequate. Such oversight includes initially approving entities that have access to data, ensuring that such entities appropriately use and protect data, and ensuring that entities that misuse data are appropriately sanctioned.

THE WAY FORWARDTaken together, today’s emerging policy opportunities and the nation’s longstanding health challenges create a situation of considerable urgency for the United States. The openness to bold new approaches offered by recent legislation will disappear quickly. Given that the U.S. lags behind most other industrialized countries in the health status of its citizens, we must seize the opportunities to maximize the health benefits and begin to assess whether the huge investments are indeed having the desired impact.

This paper has noted the critical federal role in devising health information policy to support national health goals. Federal leadership is more needed than ever to create the comprehensive approaches that will guide the development of information capacities and coordinate efforts by actors in the public and private sectors. Whatever progress is made in the critical transition to electronic health records, clinical data alone will not suffice; broad information capacities that

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7
An NCVHS Primer: Health Data Stewardship―What, Why, Who, How, December 2009.
8 http://www.ncvhs.hhs.gov
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draw on all the sources and serve all the purposes discussed in this paper will be necessary. This will require shoring up the data resources for public functions such as surveys, safety surveillance, and vital records, along with strategic thinking to determine what capacities will be needed in the future and how to guide their development. Many issues require research and demonstration as part of a prioritized, adequately funded research agenda. In addition, further investments in a trained workforce are needed, to ensure the availability of professionals and leaders who can properly use information resources for analysis and decision-making.

As it develops policies and strategies, the Department has always invited input from experts and stakeholders; and NCVHS has long helped to facilitate this dialogue and distill the key messages and lessons. NCVHS will continue to use its consultative and deliberative processes, working collaboratively with other HHS advisory committees, to help the Department meet the current opportunities and challenges. As noted, all NCVHS subcommittees plan to be involved in this effort; this report is an early installment on subcommittee and full Committee work plans for the coming 18 months or more. NCVHS expects to develop recommendations on a research agenda, which may be the focus of one or more hearings. Each of the subcommittees is identifying the key issues in its domain, to be pursued through workshops, hearings, and internal deliberations as NCVHS develops recommendations for the Secretary. The subcommittees’ preliminary thinking is outlined below.

SUBCOMMITTEE ON QUALITY

Over the next two years, the NCVHS Subcommittee on Quality will focus on supporting the development of meaningful measures, leveraging both existing and emerging data sources (e.g., patient-generated data, remote monitoring, personal health records), and in particular identifying significant opportunities and gaps. Critical to meaningful measurement is the availability of relevant data elements that could be easily captured using certified EHR technology and functionality, among other tools. The Subcommittee on Quality will identify emerging health data needs for a health system where the individual engages in his or her health and health care. As a near-term priority, the Subcommittee will address the data needs of person-centered health and health care, emphasizing coordination and continuity of care across a continuum of services. A longer term goal is to develop a national strategy to leverage clinically rich health data to address important national questions about determinants of health and disease.

SUBCOMMITTEE ON PRIVACY, CONFIDENTIALITY AND SECURITY

The NCVHS Subcommittee on Privacy, Confidentiality and Security will focus its efforts on providing recommendations that support national priorities, in coordination with such groups as the ONC HIT Policy Committee’s Privacy and Security Workgroup. In the next year, the Subcommittee plans to develop recommendations regarding governance as well as a framework for the identification and appropriate management of sensitive data. The Subcommittee will also consider transparency and the role of patient consent. In addition, it will continue to review and make recommendations regarding new privacy, confidentiality, and security regulations; compliance with these regulations; and strategies for effective enforcement.

SUBCOMMITTEE ON STANDARDS

Health care reform legislation now provides a new opportunity to continue the administrative simplification that began under HIPAA―a process in which NCVHS will remain heavily involved. The NCVHS Subcommittee on Standards will continue to meet its responsibilities related to HIPAA; will implement the many administrative simplification responsibilities assigned by the Health Reform Act of 2010; and will meet new requests for recommendations on the use of standards to enhance interoperability of the transmission and semantics of health data as they arise. As we look to the future, several goals stand out with respect to standards. The Subcommittee will seek to ensure a comprehensive framework and roadmap for health information standards that support the national health IT strategic framework, vision and policy priorities; the public health policy agenda; the NCVHS proposed data stewardship framework; a national research agenda that includes comparative effectiveness; and the needs of all data users.

SUBCOMMITTEE ON POPULATION HEALTH

Understanding the population’s health and its determinants relies on multiple data sources, including population surveys, clinical data, administrative data (notably, birth and death records and billing data on use of health services), and public health and environmental reporting systems. At the national level, Federal agencies such as the National Center for Health Statistics are charged with developing methods, assessing validity, and reporting national population health information. As we envision building a comparable capacity for communities and states across America, the quality of information and its timeliness will be central to success. The Subcommittee on Population Health will focus on facilitators and barriers to data linkage at state and local levels as a critical part of health information infrastructure, specifically linking EHR data with existing administrative and local survey data. Fundamental to understanding population health is describing the underlying population, which also comprises those who have not seen a doctor recently or have refused to respond to a survey. The work of the Subcommittee will focus on methods to ensure that linked data sources provide valid health information, including methods to adjust for missing data and methods to protect privacy.

Ten States Seek Info on Medication Mgmt Technologies & Services: RFI

RFI led by Tennessee in conjunction with Alabama, California, Colorado, Georgia, Maine, Missouri, New York (Department of Health and the New York eHealth Collaborative), North Carolina, and South Carolina
Enterprise Medication Management Services RFI

Posted on Tennessee site on June 17, 2010 and on State HIE Toolkit on June 23, 2010.
“The State of Tennessee, in conjunction with nine other states, is conducting market research regarding enterprise medication management technologies and services.”

The nine other states are Alabama, California, Colorado, Georgia, Maine, Missouri, New York (Department of Health and the New York eHealth Collaborative), North Carolina, and South Carolina.

“Click the following link to download (pdf) our States’ request for information (RFI):
Medication Management RFI – 6-17-10.pdf

“Responses to this RFI will assist our States in understanding the current state of the marketplace, including commercial/government best practices, industry capabilities, innovative delivery approaches, commercial market service levels, and performance strategies and measures.  Information gained through this RFI will greatly assist our States in determining how best to advance innovative medication management services.”

These states appear to be looking for  technology and services which could be offered across multiple states. While the document reads like an RFP, it clearly states that it is not a competition but a method for the states to “improve” their “knowledge of private industry’s capabilities.”

RFI Time Line:
RFI published on June 17, 2010
Vendors may submit written questions to the Tennessee Office of e-Health Initiatives until 5:00 p.m. Central Time June 28, 2010
Answers to written vendor questions will be posted on the Tennessee Office of e-Health Initiatives website http://www.tennesseeanytime.org/ehealth by 5:00 p.m. Central time July 1, 2010
RFI responses are due by 5:00 p.m. Central Time July 12, 2010

Excerpted from RFI:
A.      STATEMENT OF INTENT:

“The State of Tennessee Department of Finance and Administration, Office of eHealth Initiatives (OEHI), issues this Request for Information on behalf of the states named above for the purpose of conducting market research regarding enterprise medication management technologies and services from industry leaders and top performers (see appendix for list of lead representatives from each participating state). These services will be offered statewide among our states to providers through coordinated access. Information provided will assist our States in understanding the current state of the marketplace, including commercial/government best practices, industry capabilities, innovative delivery approaches, commercial market service levels, and performance strategies and measures.

“This market research is not a competition. The information obtained from submitted written responses and/or oral presentations will be used only to improve the States’ knowledge of private industry’s capabilities. No evaluation of participating vendors will occur and your participation is not a promise of future business with any participating State. Responding or not responding to this RFI does not preclude the vendor from bidding on any future solicitations. Any pricing information provided in your information packet must meet the strict guidelines outlined in C.14.

“Information obtained through this RFI will be shared among participating states to encourage complimentary development of services across multiple states. Entities responding to this RFI should be aware that information they provide will be subject to the public records laws of each state. The Tennessee Public Records Act, for example, requires disclosure of State records unless there is a specific exception in State or Federal law. As we specify in C.14 we are not seeking pricing information regarding individual solution capabilities. In addition, the States reserve the right to amend, extend, or re-release this RFI.

“After reviewing the information obtained through this RFI, each participating State will determine its own next steps, including whether and how to pursue a procurement process.

“The States appreciate your cooperation and look forward to a very meaningful, productive, and collaborative market research effort.”

B.      BACKGROUND:

“The States are considering offering several enterprise services through existing and contemplated statewide health information exchange (HIE) to assist medical providers in complying with the meaningful use criteria developed by the U.S. Department of Health and Human Services. Among these services the States are specifically interested in gauging the need for and ability for vendor(s) to provide a medication management solution that offers medication retrieval and aggregation of prescription (new, refills, etc.) information from identified sources (e.g. private e-prescribing networks, medication management hubs, pharmacies, hospitals, others) to medical providers, including pharmacists. Further, the States are considering whether this enterprise medication management solution should include one or both of the following services: (1) medication history, including analytical services and medication reconciliation, and (2) e-prescribing support, including prescription management, eligibility, and formulary information. See Section C for more specific desired capabilities for both of these services.

“Medication management is an increasingly important part of health care, especially for those with chronic conditions and co-morbidities. It is relevant at almost every point of care, from primary to specialist to acute care and back. Ready access to aggregated, reconciled medication information has the potential to significantly reduce errors and enhance treatment effectiveness; more than half of patients experience one or more unintended medication discrepancies at hospital admission. Today the most promising medication management approach is still the “brown bag” method: ask the patient to bring every medication they have in a brown bag and attempt to reconcile through an interview at the encounter. Some information is now available from claims data or retail fill data, but it is not integrated and often has errors or is difficult to interpret. Claims data have latency issues and retail data only capture prescriptions filled in network, missing important sources such as samples and low-priced generics often paid for out-of-pocket. Over the Counter (OTC) medications, both non-prescription and previously prescribed (e.g. Prilosec), are also missing. Inpatient medication is also not integrated, though it is now more often available through Admission, Discharge, and Transfer (ADT) messages. Further, once these sources become available, new issues arise such as duplicate entries, inability to distinguish episodic vs. long-term therapy, data deluge if all records are returned in raw form, etc. Ultimately, creating a robust medication management platform is a challenging process. The lack of such a platform, though, impedes the move towards integrated care and poses even larger challenges to improving the quality of health care.

“Ideally, there would be a platform that would:

–Connect to all sources of information
–Facilitate e-prescribing and refill requests
–Provide decision support
–Analyze the raw data to provide a clean, comprehensive stream of information, including normalization of terminology, taking out duplicates, etc.
–Enable access to this information through standardized interfaces
–Easily add new sources of information
–Provide aggregate analysis of de-identified data to support integrated care and public health: trends by medication, condition, or geography; re-identification for public health issues such as surveillance, etc.

“For this market research, a special emphasis is placed on determining whether it is feasible and/or appropriate for the States to provide an enterprise medication management solution as well as what capabilities such a solution should/could include. We are also interested in exploring business models that would result in a financially sustainable solution. We believe this information will dramatically improve the quality of a possible forthcoming acquisition among our States, inclusive of the solicitation and resulting contract.

“The States will consider all service approaches and highly encourage vendors to participate is this market research effort.”
#               #               # END OF EXCERPT

See pdf for complete details, Medication Management RFI – 6-17-10.pdf , as well as check back with Tennessee Office of e-Health Initiatives for any updates.

Additional Item in State HIE Toolkit:
Accessed 6/24/2010.
Inventory of publicly available RFPs for technical services (updated 12/2009)

Enrollment for Health Insurance and Human Services Made Easy: HHS Wants Your Ideas

FACA Blog: Enrollment Workgroup solicits your help with information
on moving government into the 21st century

Monday, June 21st, 2010 | Originally Posted on FACA Blog by Judy Sparrow and reposted by e-Healthcare Marketing blog below.

In January 2010, at the White House Forum on Modernizing Government, President Obama noted that, “Improving the technology our government uses isn’t about having the fanciest bells and whistles on our websites – it’s about how we use the American people’s hard-earned tax dollars to make government work better for them.” Now, six months later, the newly formed Enrollment Workgroup of the Health IT Policy and Standards Committees has begun the discussion of how to bring eligibility determination and enrollment in health and human services programs into the 21st century.

What we critically need—and what these standards have the promise to support—is an eligibility and enrollment system that will make applying for health insurance and other human service programs as easy as using the Internet to pay your bills or file your income taxes.  It should be possible to apply for programs online, easily obtain the documents and information needed to confirm eligibility, and re-use this information to apply for a variety of programs, and re-certify your eligibility when the time comes. We need your help to uncover the examples, insights and best practices that will make this effort successful.

As background, the Enrollment Workgroup, authorized by the Affordable Care Act (ACA), has been tasked to recommend a set of standards to facilitate enrollment in Federal and state health and human services programs, including standards for:

  • Electronic matching across state and Federal data
  • Retrieval and submission of electronic documentation for verification
  • Re-use of eligibility information
  • Capability for individuals to maintain eligibility information online
  • Notification of eligibility

To follow up on the June 14th Enrollment Workgroup’s first meeting and public hearing and to elicit further public comment, the FACA Blog is open for comments until July 1st. Comments can be submitted online on the blog website or emailed to: judy.sparrow@hhs.gov (use “enrollment workgroup” in header)

Specifically, the Workgroup would like public comment on:

(1) Federal, state, local or tribal government initiatives to simplify and streamline eligibility and enrollment in health and human services programs.

We would appreciate your insights on: 

  • How should this work support health reform goals, including simplified and streamlined eligibility?
  • What standards are currently being used by state health and human services programs to determine eligibility?
  • In what areas would additional standards create clear progress towards the goal of a seamless eligibility system for consumers?
  • What standards or technology principles would enable rapid innovation in this space?

You might also describe your efforts, including use of standards and technology to simplify eligibility and enrollment, for: 

  • Front end check of eligibility/enrollment across multiple programs:
    • How do you check eligibility/enrollment across programs at the front end? Which programs are included?  Standards used? 
  • Approach and standards for data linking/matching? Is the matching probabilistic? What level of accuracy is required? Collecting information to determine multiple program eligibility
    • What interfaces do you use to obtain electronic verification information? What standards used?
    • Consumer entry of eligibility information, what data elements? Consumer authentication?
    • What standards are used for messaging? 

(2) Alternatively, if you are not in the healthcare sector, how have you solved challenges similar to those found in simplifying and streamlining eligibility and enrollment?  In other words, how can we move towards 21st century practices? 

  • For example, share your perspectives on:
    • Opportunity to move towards a web-services model
    • Viability of a platform-based or enterprise service approach
    • Role of consumer in managing own data
    • Where we need standards to accelerate progress and consumer participation

Your responses will help form the agenda for the on-going work of the Enrollment Workgroup, and assist us as we work toward a September 30th deliverable deadline as mandated by ACA.

Thank you for your contribution!
– Aneesh Chopra, Chair, Enrollment Workgroup
– Sam Karp, Co-Chair, Enrollment Workgroup
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To make comments directly on the official FACA blog site, click here.

CMS Launches Official EHR Incentive Program Website: FAQs, Fact Sheet, Overview

The Electronic Health Record (EHR) Incentive Program Website is now available on CMS.gov!
Rec’d email from ONC on June 21, 2010
The Centers for Medicare & Medicaid Services (CMS) has launched the official website for the Medicare & Medicaid EHR Incentive Programs. This website provides the most up-to-date, detailed information about the EHR incentive programs.

“The Medicare and Medicaid EHR Incentive Programs will provide incentive payments to eligible professionals and hospitals as they adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology.”

Bookmark the new site and visit often to learn about who is eligible for the programs, how to register, meaningful use, upcoming EHR training and events, and much more!
http://www.cms.gov/EHRIncentivePrograms

Excerpted on June 21, 2010 from
The Official Web Site for the Medicare and Medicaid EHR Incentive Programs

The official web site provides up-to-date, detailed information about the Electronic Health Record (EHR) incentive programs. (On official site, there are  the tabs to the left to find additional information regarding various aspects of the program. On e-Healthcare Marketing, see the section below  called “EHR Incentive Programs Navigation” for other aspects of program.)

EHR Incentive Programs Navigation
The following program pages were published on June 18, 2010, contain  compilations of  links to most of the relevant  documents, and provide a central location to house future information.

Background
The nation’s healthcare system is undergoing a transformation in an effort to improve quality, safety and efficiency of care, from the upgrade to ICD-10 to information exchanges of EHR technology.   To help facilitate this vision, the Health Information Technology for Economic and Clinical Health Act, or the “HITECH Act” established programs under Medicare and Medicaid to provide incentive payments for the “meaningful use” of certified EHR technology.  The Medicare and Medicaid EHR incentive programs will provide incentive payments to eligible professionals and eligible hospitals as they  adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology.  The programs begin in 2011. These incentive programs are designed to support providers in this period of Health IT transition and instill the use of EHRs in meaningful ways to help our nation to improve the quality, safety and efficiency of patient health care.

NOTE: This is a new program, and it is separate from other active CMS incentive programs, such as Physicians Quality Reporting Initiative (PQRI), Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) and e-Prescribing.

Establishing the New Program
CMS is establishing the EHR Incentive program through formal rule making. A proposed rule on the EHR incentive programs (and the definition of meaningful use) was published, and CMS accepted public comments for 60 days, which ended on March 15, 2010. More than 2,000 comments were received. CMS is currently working to develop and release the final rule in late spring/early summer 2010. This rule will provide many of the parameters and requirements for the Medicare & Medicaid EHR Incentive Programs. A copy of the proposed rule and related documents is accessible below in the Downloads and Links Inside CMS sections.

CMS’ Role in Other HITECH Areas
CMS is also working with the Office of the National Coordinator for Health Information Technology (ONC) in developing standards, implementation specifications, and certification criteria for EHR technology. More information on certification can be found in the tab on the left.  

Patient privacy and security is an important consideration in implementing the EHR incentive programs. CMS is also working with the Office for Civil Rights (OCR) and ONC to address the privacy and security protections under HITECH Act. More information on privacy and security related to the Health IT is available by clicking “Health IT/Privacy and Security” and “HHS Office for Civil Rights” in the Related Links Outside CMS section below.

Downloads
Most of these downloads are from 2009, with published rule in a  January 2010 Federal Register.
Fact Sheet: Medicare and Medicaid EHR Incentive Programs: Title IV of Recovery Act

Press Release: CMS and ONC Issue Regulations Proposing a Definition of “Meaningful Use” and Setting Standards for EHR Incentive Program

Copy of Published Proposed Rule for EHR Incentive Programs and Definition of Meaningful Use [7.37 MB] 

Fact Sheet: Proposed Requirements for Medicaid EHR Incentive Program

Fact Sheet: Proposed Requirements for Medicare EHR Incentive Program

Fact Sheet: Proposed Definition of Meaningful Use

Related Links Inside CMS
Health IT Frequently Asked Questions

Related Links Outside CMS
HHS/Office of National Coordinator Health IT Web Site

Health IT/Privacy and Security

HHS Office for Civil Rights

FACT SHEET from June 2009 (last year) contains much of the basic information with new information coming in June/July 2010.
EXCERPTED FROM CMS site on June 21, 2010

MEDICARE AND MEDICAID HEALTH INFORMATION TECHNOLOGY: TITLE IV OF THE AMERICAN RECOVERY AND REINVESTMENT ACT

Background

On Feb. 17, 2009, President Obama signed the American Recovery and Reinvestment Act of 2009 (Recovery Act), a critical measure to stimulate the economy.  Among other provisions, the new law provides major opportunities for the Department of Health and Human Services (DHHS), its partner agencies, and the States to improve the nation’s health care through health information technology (HIT) by promoting the meaningful use of electronic health records (EHR) via incentives. For a copy of the full bill, go to:  http://www.hhs.gov/recovery/overview/index.html

The HIT provisions of the Recovery Act are found primarily in Title XIII, Division A, Health Information Technology, and in Title IV of Division B, Medicare and Medicaid Health Information Technology.  These titles together are cited as the Health Information Technology for Economic and Clinical Health Act or the HITECH Act.  This fact sheet focuses on the provisions of Title IV only.

Funding
Under Title IV, funding is available to certain eligible professionals (EPs) and hospitals, as described below.  Funds will be distributed through Medicare and Medicaid incentive payments to EPs, physicians, and hospitals who are “meaningful EHR users.” In addition, with regard to the Medicaid program, federal matching funds are also available to States to support their administrative costs associated with these provisions.

Criteria for Qualifying for an Incentive
The qualification criteria for incentives (i.e., meeting specified HIT standards, policies, implementation specifications, timeframes, and certification requirements) are still in development, and will be defined through regulation and additional guidance materials.  However, CMS generally expects that under Medicare, “meaningful EHR users” would demonstrate each of the following: meaningful use of a certified EHR, the electronic exchange of health information to improve the quality of health care, and reporting on clinical quality and other measures using certified EHR technology.  Medicaid programs will determine their own requirements in line with the Medicaid-related provisions of the Recovery Act. Funds will be distributed through Medicare and Medicaid incentive payments to EPs and hospitals who are “meaningful EHR users.”  CMS intends to publish a proposed rule in late 2009 to propose a definition of meaningful use of certified Electronic Health Records (EHR) technology and establish criteria for the incentives programs.  CMS is working extensively with the Office of the National Coordinator for Health Information Technology (ONC) to identify the proposed criteria.

Medicare Payment Incentives for Eligible Professionals

  • The Recovery Act establishes financial incentives beginning in January 2011 for eligible professionals (EPs) who are meaningful EHR users.  Beginning in 2015, payment adjustments will be imposed on EPs who are not meaningful EHR users.
  • Hospital-based physicians who substantially furnish their services in a hospital setting are not eligible.
  • Incentive Payments
  • The incentive payment is equal to 75 percent of Medicare allowable charges for covered services furnished by the EP in a year, subject to a maximum payment in the first, second, third, fourth, and fifth years of $15,000; $12,000; $8,000; $4000; and $2,000, respectively.  For early adopters whose first payment year is 2011 or 2012, the maximum payment is $18,000 in the first year.
  • There will be no payments for meaningful EHR use after 2016.
  • There would be no payments to EPs who first become meaningful EHR users in 2015 or thereafter.
  • For EPs who predominantly furnish services in a health professional shortage area (HPSA), incentive payments would be increased by 10 percent. 
  • Payment Adjustments
  • The Medicare fee schedule amount for professional services provided by an EP who was not a meaningful EHR user for the year would be reduced by 1 percent in 2015, by 2 percent in 2016, by 3 percent for 2017 and by between 3 to 5 percent in subsequent years. 
  • For 2018 and thereafter, if the Secretary finds that the proportion of EPs who are meaningful EHR users is less than 75 percent, then the reductions will be increased by 1 percentage point each year, but by not more than 5 percent overall. 

Medicare Payment Incentives for Hospitals

  • Incentive payments are provided, beginning with October 2010, for eligible subsection (d) hospitals and critical access hospitals (CAHs) that are meaningful EHR users. Reduced payment updates beginning in FY 2015 will apply to eligible hospitals that are not meaningful EHR users.
  • An eligible hospital that is a meaningful EHR user could receive up to four years of financial incentives payments, beginning with fiscal year 2011. There will be no payments to hospitals that become meaningful EHR users after 2015. 
  • Incentive Payments for Hospitals
    • The incentive payment for each eligible hospital would be calculated based on the product of (1) an initial amount, (2) the Medicare share, and (3) a transition factor. 

(a)The initial amount is the sum of a $2 million base year amount plus a dollar amount based on the number of discharges for each eligible hospital.

(b)The Medicare share is a fraction based on estimated Medicare fee-for-service and managed care inpatient bed days divided by estimated total inpatient bed-days and modified by charges for charity care.

(c)The transition factor phases down the incentive payments over the four-year period.  The factor equals 1 for the first payment year, ¾ for the second payment year, ½ for the third payment year, and ¼ for the fourth payment year, and zero thereafter.

The Secretary has discretion to use other data if the required data to calculate the incentive payment formula does not exist. 

  • The transition factor is modified for those eligible hospitals that first become meaningful EHR users beginning in 2014.  Such hospitals would receive payments as if they became meaningful EHR users beginning in 2013 (i.e., if a hospital were to begin EHR meaningful use in 2014, the transition factor used for the year would be ¾ instead of 1, ½ for the second year, ¼ for the third year, and zero thereafter ).
  • o   For CAHs that are meaningful EHR users, reasonable costs for the purchase of certified EHR technology would be computed by expensing such costs in a single payment year, rather than depreciating them over time.  In addition, incentive payments for CAHs would be based on the Medicare share formula used for subsection (d) hospitals, plus 20 percentage points (not to exceed a total of 100 percent).  CAHs would receive a prompt interim payment for the Medicare share of such costs (subject to reconciliation). Payments would not be made with respect to a cost reporting period beginning during a payment year after 2015, and in no case would a CAH receive payment with respect to more than 4 consecutive payment years.
  • Market Basket Adjustments for Hospitals that are not Meaningful Users
    • Eligible subsection (d) hospitals that are not meaningful users for a fiscal year would receive a net reduction of ¼, ½, and ¾ of the market basket update that would apply in 2015, 2016, 2017 and thereafter, respectively.
    • The Secretary of HHS may, on a case-by-case basis, exempt a hospital if requiring the hospital to be a meaningful EHR user would result in a significant hardship.
    •   Eligible CAHs that are not meaningful EHR users for a fiscal year and otherwise would be paid at 101 percent of reasonable costs are subject to the following payment adjustments: in FY2015, reimbursement for inpatient services at 100.66 percent of reasonable costs; in FY2016, reimbursement for inpatient services at 100.33 percent of reasonable costs; and in FY2017 and each subsequent year, 100 percent of reasonable costs..

Medicaid Payment Incentives
The Recovery Act establishes 100 percent Federal Financial Participation (FFP) for States to provide incentive payments to eligible Medicaid providers to purchase, implement, and operate (including support services and training for staff) certified EHR technology.  It also establishes 90 percent FFP for State administrative expenses related to carrying out this provision. 

Incentive Payments to Providers

  • Certain classes of Medicaid professionals and hospitals are eligible for incentive payments to encourage the adoption and use of certified EHR technology.  Eligible professionals include physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants who are practicing in Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant. 
  • Eligible professionals must meet minimum Medicaid patient volume percentages, and must waive rights to duplicative Medicare EHR incentive payments.  Eligible professionals may receive up to 85 percent of the net average allowable costs for certified EHR technology, including support and training (determined on the basis of studies that the Secretary will undertake), up to a maximum level, and incentive payments are available for no more than a 6-year period.  
  • Acute care hospitals with at least 10 percent Medicaid patient volume would also be eligible for payments, as would children’s hospitals of any patient volume. Entities that promote the adoption of certified EHR technology, as designated by the State, are also eligible to receive incentive payments through arrangements with eligible professionals under certain conditions.

Medicaid Incentive Program Qualifications

To be eligible for incentive payments not associated with the initial adoption/implementation/upgrade of EHR technology, the provider must demonstrate meaningful use of the EHR technology through a means approved by the State and acceptable to the Secretary.  In determining what is “meaningful use,” a State must ensure that populations with unique needs, such as children, are addressed.  A State may also require providers to report clinical quality measures as part of the meaningful use demonstration.  In addition, to the extent specified by the Secretary, the EHR technology must be compatible with State or Federal administrative management systems.

EPs may not receive an incentive under both Medicare and Medicaid in a given year.  CMS and the States will develop means to prevent such duplicate payments.  CMS expects that the prevention of duplicative payments will be addressed more fully through notice and comment rulemaking. 

Frequently Asked Questions (FAQs)

Question:  When will the Centers for Medicare & Medicaid Services (CMS) publish regulations to define certified Electronic Health Records and “meaningful use?”

Answer: CMS intends to publish a proposed rule in late 2009 to define meaningful use of certified Electronic Health Records (EHR) technology and establish criteria for the incentives programs.  We are working extensively with the Office of the National Coordinator for Health Information Technology(ONC) to identify the proposed criteria.

Question: What is CMS’ overall time frame for actions and activities related to the incentive program?

Answer: Although further details will be developed, CMS can provide the following timeline based on the current implementation plan: 

Date Milestone
2009
  • Coordinate with ONC to develop policies such as the definition of meaningful use
  • Develop proposed rules to allow public input to the incentive program policies
  • Plan systems and other requirements needed to support the incentives programs
  • Plan national outreach program
2010
  • Conduct outreach to eligible professionals and providers and to State Medicaid Agencies
  • Develop systems to support the payment of incentives
  • Develop final rules to establish policies needed to pay incentives
  • Develop systems to monitor and evaluate incentive payments
No sooner than October 2010 Start to pay hospital incentives for Medicare and monitor payments
No sooner than January 2011
  • Start to pay eligible professionals for Medicare and monitor payments
  • Begin and monitor Medicaid incentive payments to eligible professionals and hospitals
2011 – 2016 Continue paying hospital incentives for Medicare and monitor payments
2011 – 2016 Continue paying eligible professionals incentives for Medicare and monitor payments
2011 – 2021 Continue paying Medicaid incentives to eligible professionals and hospitals and monitor payments
2015 and thereafter Initiate payment reductions to Medicare hospitals and eligible professionals that fail to adopt EHRs

 

Question:  When will the Centers for Medicare & Medicaid Services (CMS) begin to pay incentives to eligible professionals and hospitals for using certified Electronic Health Records ( EHRs)?

Answer:  By statute, the earliest dates that CMS will be able to pay an incentive under Medicare is October 1, 2010, for hospitals and January 1, 2011, for eligible professionals. 

The statute does not define a date for the Medicaid incentives program.  Given the range of regulatory and planning activities that must precede States being able to make provider incentive payments, as well as the importance of coordinating Medicaid and Medicare payments to prevent duplication, CMS does not expect that States will be able to make such payments until 2011. 

Work is underway to define the meaningful EHR user criteria, as well as the requirements for applying for and receiving the EHR payment incentives, CMS expects to issue a proposed rule in late 2009. 

Question:  If an eligible professional uses a certified Electronic Health Record (EHR) in a meaningful way in accordance with the adopted regulations, and meets the requirements established by CMS, could that professional receive both the Medicare EHR payment incentive as well as the Medicaid EHR payment incentive? 

Answer:  No, an eligible professional may only receive an EHR payment under either Medicare or Medicaid.  CMS expects to more fully address the issue of duplicative payments under Medicare and Medicaid through rulemaking. 

Question:  If I already have an Electronic Health Record (EHR) that has been certified by the Certification Commission for Healthcare Information Technology (CCHIT), will I have to buy a new system if the government mandates that only EHRs that meet a higher certification level are considered certified EHRs? 

Answer:  Decisions about EHR standards, implementation specifications and certification criteria have not been made yet, and are under development.   Policies will be proposed in the regulation to be published in late 2009.

Question:  What is the maximum incentive an eligible professional can earn for using an Electronic Health Record under Medicaid?

Answer:  The statute does not define fixed amounts for the incentive payments, only ceilings that cannot be exceeded.  CMS expects that the actual payment amounts will be more fully addressed through notice and comment rulemaking.

Question:  What is the maximum Electronic Health Record(EHR) incentive an eligible professional can earn under Medicare?

Answer:  Eligible professionals(EPs), who adopt Electronic Health Records as early as 2011 or 2012 may be eligible for up to $44,000 in Medicare incentive payments spread out over five years (increased by 10 percent for EPs who predominantly furnish services in a health professional  shortage area).

Question:  What if my Electronic Health Record (EHR) system costs much more than the incentive the government will pay?  May I request additional funds? 

Answer:  The Recovery Act does not provide for incentive payments under Medicare or Medicaid beyond the limits established by the legislation, regardless of the cost of the EHR system chosen by eligible professionals or hospitals.  With regard to Medicaid, the purpose of the 100 percent FFP provider incentive payments to certain eligible Medicaid providers is to encourage the adoption and meaningful use of certified EHR technology.  While the incentive payments are expected to be used for certified EHR technology and support services, including maintenance and training necessary for the adoption and operation of such technology, the incentive payments are not direct reimbursement for such activities, but rather are intended to serve as an incentive for eligible professionals and hospitals to adopt and meaningfully use certified EHR technology

Question:  What is the earliest date the payment adjustments will start to be imposed for eligible professionals and hospitals that are not meaningful Electronic Health Record (EHR) users under the HITECH provisions of the Recovery Act?

Answer:  The HITECH provisions of the Recovery Act establish 2015 as the first year that payment adjustments will start to be imposed on Medicare eligible professionals and hospitals that are not meaningful EHR users.  There are no payment adjustments associated with the Medicaid provisions under Section 4201.

Question:  How will eligible providers and hospitals apply for incentives if they are using certified Electronic Health Records (EHRs) in accordance with the standards established by Health and Human Services (HHS) under the HITECH portion of the Recovery Act?

Answer:  The Department of Health and Human Services (HHS) will publish a rule establishing the criteria which eligible professionals and hospitals must meet in order to qualify for the EHR incentive payments, including defining meaningful EHR users.  The rule will also explain how to apply for those incentives. 

Question:  How will the public know who has received incentive payments under the Recovery Act?

Answer:  CMS will post the names of those receiving Medicare incentives online.  The list will include the elements identified in the Recovery Act: name, business addresses, and business phone number of all Medicare eligible professionals and hospitals who received incentive payments under the Recovery Act.  There is no such requirement for CMS to publish the names of those receiving Medicaid incentive payments under Section 4201 though States may opt do so.

Question:   What will be done to help prepare providers to take advantage of the incentive payments for the meaningful use of an Electronic Health Record (EHR)?

Answer:  A set of supportive programs will be announced after CMS publishes a proposed rule in late 2009, that is, regarding a definition of meaningful use of certified EHR technology and criteria for the incentives programs.  These programs are intended to educate and support providers, enable health information exchange, and build the workforce that will be needed for success. Information about these supportive efforts will be communicated to eligible providers through many channels.

Privacy and Security Tiger Team: Jun 29 Consumer Choice Tech Hearing

Consumer Choice Technology Hearing June 29, 2010 
Plus Tiger Team Archives
Privacy and Security “Tiger Team” Announces Consumer Choice Technology Hearing
Friday, June 18th, 2010 | Posted Originally on FACA Blog by Deven McGraw  and reposted by e-Healthcare Marketing in full.

The HIT Policy Committee (HITPC) invites you to attend the Privacy and Security Tiger Team’s upcoming hearing on consumer choice technology.  The Tiger Team is a workgroup which has been assigned the task of analyzing and providing recommendations on privacy and security issues on an expedited basis to the HITPC, and ultimately to the Office of the National Coordinator for Health Information Technology. Many consumers and consumer groups have expressed concern about the ability of patients to control the disclosure of their health information as providers transition to electronic health records and electronic health information exchange. The protection of information related to “sensitive” health conditions such as substance abuse, mental health and sexually transmitted disease is of particular concern.  Currently, some state and federal laws require patient consent to share this information. In the paper based exchange, control is maintained either by sharing the record only with patient consent or by redacting certain information from the record prior to sharing. Some experts have said there is no technology to support these consent requirements in an electronic environment. Others have stated that some technology supports these consent requirements. 

The purpose of the hearing is to learn more about the capabilities of existing consumer choice technology and the potential for future development in this area.  The morning session will focus on consumer choice technology in use today in health information exchange.  A user of the technology will speak about their specific implementation of the technology, accompanied by a demonstration.   The afternoon session will take a look at consumer choice technologies that are in the development stages for use within health information exchange.  These developers have been invited to demonstrate either a prototype of the technology or its current use, and discuss its potential for further development within health information exchange.

After each session, a panel of discussants, along with the members of the Tiger Team, will pose questions to the users and developers about the technological approaches presented.  The goal of the panel is to probe the presenters for further information regarding the implementation of the consumer choice solutions and potential for technological development.  There will be an opportunity for public testimony both in the morning and the afternoon.

We look forward to learning from the users and developers of these technologies as well as the various stakeholders for electronic health information exchange.

Privacy and Security Tiger Team Hearing Details:
Tuesday, June 29, 2010
8:00 a.m. – 5:15 p.m.

Grand Hyatt Hotel
1000 H Street NW
Washington, DC 20001
Meeting Location: Constitution Ballroom, Constitution Level

Registration Information and Agenda (pdf)
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AGENDA (pdf)
8:15am Opening remarks by Tiger Team co-chairs
–Deven McGraw, Center for Democracy & Technology
–Paul Egerman, Software Entrepreneur
8:15am  Opening remarks by David Blumenthal, MD
National Coordinator for Health IT
8:30am Consumer Choice Technology in Use Today — Panel 1
–Intersystems HealthShar
–CMBHS
9:30am  Break
9:45am Consumer Choice Technology in Use Today–Panel 2
–E-MD E-Chart
–TBD
10:45am Consumer Choice Technology in Use Panel Discussion
–Deborah Peer, MD
–Melissa Goldstein, JD, MA
–Iona Singureanu
–David Kibbe, MD
11:30am Tiger Team Discussion
12: 15pm Lunch
1:15pm Cutting-edge Consumer Choice Technology–Panel 3
–Tolven Institute
–Private Access
2:15pm Break
2:30pm Cutting-edge Consumer Choice Technoloogy–Panel 4
–DOD/VA VLER
–HIPAAT
3:30pm Cutting-edge Consumer Choice Technology Panel Discussion
–Deborah Peer, MD
–Melissa Goldstein, JD, MA
–Iona Singureanu
–David Kibbe, MD
4:15pm Tiger Team Discussion
5:00pm Public Discussion
5:15pm Adjourn

Privacy and Security Tiger Team Section on ONC site

Tiger Team Meetings Archive
June 15, 2010 Meeting
Agenda [PDF - 36 KB]
Recommendations [PDF 16 KB]
Meeting Audio [MP3 - 24 MB]

June 11, 2010 Meeting
Agenda [PDF - 13 KB]
Point to Point Exchange Risk Levels [PDF - 72 KB]
Meeting Audio [MP3 - 24 MB]

June 10, 2010
Agenda [PDF - 19 KB]
NHIN Policy and Technology Framework [PDF - 124 KB]
Meeting Audio [MP3 - 14 MB]

Privacy of Substance Abuse & Mental Health Info: New FAQs

New FAQs: Privacy of Individually Identifiable Health Information (Privacy Rule)
FAQs PDF Document
Emailed June 17, 2010 by Office of National Coordinator for Health IT
The Substance Abuse & Mental Health Services Administration (SAMHSA) and the Office of the National Coordinator (ONC) for Health Information Technology announced yesterday the release of the Frequently Asked Questions (FAQs) for Applying the Substance Abuse Confidentiality Regulations to the Health Information Exchange (HIE).

The Substance Abuse Confidentiality Regulations, 42 CFR Part 2, govern the use and disclosure of alcohol and drug abuse patient records that are maintained at federally funded substance abuse programs. Both SAMHSA and ONC want to ensure that our constituents receive every tool and resource possible to allow a more complete understanding of these Federal regulations, which were enacted in 1972 and 1975. The FAQs outline the general provisions of 42 CFR Part 2, provide guidance on its application to electronic health records, and identify methods for including substance abuse patient record information into health information exchange that is consistent with the Federal statute.

The FAQs will serve as a valuable resource to a variety of individuals, including specialty and medical providers, as well as HIE technical developers and policymakers. The FAQs are not meant to provide legal advice.

Both SAMHSA and ONC are committed to adhering to the Federal protections of 42 CFR Part 2 and recognize the importance of promoting behavioral health in electronic health records. A meeting is being planned for August 4, from 8:30 a.m. to 12:30 p.m. to provide those interested an opportunity to provide input on the utility of the FAQs.

Read More About Health Privacy
http://www.samhsa.gov/HealthPrivacy/
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From ONC site on June 21, 2010:
Substance Abuse Confidentiality Regulations FAQs - ”A Frequently Asked Questions (FAQs) document for applying the Substance Abuse Confidentiality Regulations to Health Information Exchanges (HIEs) was released on 6/16/2010. This document is an educational tool that serves as a resource for practitioners in the field, as they are applying the Substance Abuse Confidentiality Regulations to Health Information Exchange activities, but does not provide legal advice to its user. ”

From Substance Abuse & Mental Health Services Administration (SAMHSA)
Health Information Privacy
 June 21, 2010

Substance Abuse Confidentiality Regulations

Frequently Asked Questions: Applying the Substance Abuse Confidentiality Regulations to Health Information Exchange (HIE) Adobe PDF file format (pdf file | 81 kbytes) | Cover Page Adobe PDF file format (26 kbytes) | Posted on 06/16/2010

Privacy and e-Consent in Three Countries Adobe PDF file format (pdf file | 731 kbytes)
Feb 16, 2007

The Confidentiality of Alcohol and Drug Abuse Patient Records Regulation and the HIPAA Privacy Rule: Implications for Alcohol and Substance Abuse Programs Adobe PDF file format (pdf file | 192 kbytes)
June 2004

Confidentiality of Alcohol and Substance Abuse Patient Records regulation (42 CFR Part 2)
Electronic Code of Federal Regulations: e-CFR Data is current as of June 17, 2010

HHS, Office for Civil Rights – HIPAA

HHS, Office of National Coordinator (ONC)
#                            #                           #

Mary Mosquera of Government Health IT reported June 21, 2010 on the “guidelines on the conditions under which records pertaining to a patient’s alcohol and drug abuse can be shared via electronic health information exchange systems.”

AHRQ Webinar: Quality Measures to Improve Patient Care: June 23

Impact of Health IT on Quality Assessment:
Innovations in Measurement and Reporting

Excerpted from AHRQ on June 20, 2010
This free 90-minute teleconference will explore the use of quality measures to improve patient care.
 
Date: June 23
Time: 2:00 – 3:30 p.m., ET
Sponsored by the Agency for Healthcare Research and Quality’s (AHRQ) National Resource Center for Health IT

To register, click here.

Presenters:

•    Denni McColm, M.B.A., is Chief Information Officer for Citizens Memorial Healthcare. She has been at Citizens Memorial since 1988, serving as Director of Human Resources and Director of Finance before moving into the CIO role in June, 2003. Ms. McColm served on the Certification Commission for Health Information Technology as a Commissioner from 2006-2008. She also served on the Davies Awards of Excellence Organizational Selection Committee from 2006 -2008 and again in 2010.  She is a member of the Editorial Board for Healthcare IT News, published in partnership with HIMSS. Ms. McColm holds a Master of Business Administration degree from the University of Missouri-Columbia.
•    Karen Kmetik, Ph.D., is Vice President of Performance Improvement at the American Medical Association (AMA), where she provides strategic leadership for AMA initiatives in health care quality measurement and improvement.  She also leads the activities of the AMA-convened Physician Consortium for Performance Improvement® (PCPI) through continued development and effectiveness testing of performance measures, advancement of the   integration of the measures into health IT, and implementation in a variety of programs.  Dr. Kmetik is a founding member of the Collaborative for Performance Measure Integration with EHR Systems, co-sponsored by the AMA, the National Committee for Quality Assurance (NCQA), and the HIMSS Electronic Health Record Association (EHRA).
•     Henry Fischer, M.D., is an Assistant Professor at the University of Colorado Health Sciences Center and a practicing internist at Denver Health Medical Center (DH).  He is director of the diabetes collaborative at Denver Health, which serves over 7000 primarily indigent adult patients with diabetes.  He was the PI on an AHRQ funded study of,  i) the automated distribution of individualized diabetic performance report cards to patients by mail and at the point of care, and, ii) the electronic distribution of provider performance report cards on diabetes measures with patient-level data. He is currently studying the use of text messaging to help manage diabetes outside of clinic visits in a primarily low-income population.

Ms. McColm will begin the teleconference by providing an overview of the three year quality measurement project at Citizens Memorial Healthcare.  She will discuss the challenges involved with applying quality measurement in ambulatory care and describe how they were able to achieve their goals.  Dr. Kmetik will describe the Cardio-HIT project, whereby different practice sites with different EHRs exported data to a warehouse for the calculation of national performance measures.  She also will describe current efforts to design measure specifications to enable integration of measures into EHRs.  Dr. Fischer will conclude the event by presenting on the use of an integrated diabetes registry to improve the quality of care for adult diabetic patients in a safety net system.  He will describe the effects of providing both patients and providers information via report cards and the benefits and challenges of this process. 

Live Webcast Information
Start Time:
June 23, 2010 2:00 PM Eastern
1:00 PM Central, 12:00 PM Mountain, 11:00 AM Pacific
Estimated Length:
1 hour, 30 minutes
Registration Fee:

ONC Rules on Temp EHR Certification: Press Release, FAQs, Overview, Blumenthal Blogs

ONC Issues Final Rule to Establish the Temporary Certification Program for Electronic Health Record Technology

HHS Press Release June 18, 2010
The Office of the National Coordinator for Health Information Technology (ONC) today issued a final rule to establish a temporary certification program for electronic health record (EHR) technology.  The temporary certification program establishes processes that organizations will need to follow in order to be authorized by the National Coordinator to test and certify EHR technology. 

Use of “certified EHR technology” is a core requirement for providers who seek to qualify to receive incentive payments under the Medicare and Medicaid Electronic Health Record Incentive Programs provisions authorized in the Health Information Technology for Economic and Clinical Health (HITECH) Act. HITECH was enacted as part of the American Recovery and Reinvestment Act (ARRA) of 2009. The Centers for Medicare & Medicaid Services will soon issue final regulations to implement the EHR incentive programs. 

Certification is used to provide assurance and confidence that a product or service will work as expected and will include the capabilities for which it was purchased.  EHR technology certification does just that:  It assures health care providers that the EHR technology they adopt has been tested and includes the required capabilities they need in order to use the technology in a meaningful way to improve the quality of care provided to their patients. 

On March 10, 2010, the U.S. Department of Health and Human Services (HHS) issued a notice of proposed rulemaking (NPRM) entitled Proposed Establishment of Certification Programs for Health Information Technology. The NPRM proposed the establishment of two certification programs for purposes of testing and certifying EHRs —one temporary and one permanent.  The temporary certification program final rule issued today will become effective upon publication in the Federal Register.  The final rule for the permanent certification program is expected to be published this fall. 

“By purchasing certified EHR technology, hospitals and eligible professionals and hospitals will be able to make EHR purchasing decisions knowing that the technology will allow them to become meaningful users of electronic health records, qualify for the payment incentives, and begin to use EHRs in a way that will improve quality and efficiency in our health care system,” said David Blumenthal, M.D., M.P.P., national coordinator for health information technology.  “We hope that all HIT stakeholders view this rule as the federal government’s commitment to reduce uncertainty in the health IT marketplace and advance the successful implementation of EHR incentive programs.” 

This final rule is issued under the authority provided to the National Coordinator for Health Information Technology in section 3001(c)(5) of the Public Health Service Act (PHSA) as added by the HITECH Act. 

For more information about the temporary certification program and rule, please visit http://healthit.hhs.gov/certification

For more information about other HHS Recovery Act Health Information Technology funding and programs, see http://www.hhs.gov/recovery/programs/index.html#Health

Picture picked up from ONC home page, June 19, 2010.
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Overview: Temporary Certification Program
Excerpted from ONC site June 19, 2010

The Office of the National Coordinator for Health Information Technology (ONC) has established a temporary certification program for health information technology (health IT). The program provides a way for organizations to become authorized by the National Coordinator to test and certify electronic health record (EHR) technology. 

Certification assures health care providers that the EHR technology they adopt includes the capabilities they will need to participate in the Medicare and Medicaid EHR incentive programs. 

Use of certified EHR technology is a core requirement for health care providers to become “meaningful users” and eligible for payment under Medicare and Medicaid EHR incentive programs. 

To become an ONC-Authorized Testing and Certification Body (ONC-ATCB), an organization must submit an application to ONC to demonstrate its competency and ability to test and certify Complete EHRs and/or EHR Modules. 

Applicants are required to request, in writing, an application for ONC-ATCB status from the National Coordinator at ATCBapplication@hhs.gov. The application has two parts: 

Part I: Provide general identifying and contact information; complete and submit the results of self-audits to all sections of ISO/IEC Guide 65:1996 (Guide 65) and ISO/IEC 17025:2005 (ISO 17025); submit additional documentation related to Guide 65 and ISO 17025; and agree to adhere to the Principles of Proper Conduct for ONC-ATCBs. 

Part II: Successfully complete a proficiency examination. 

Applicants are required to complete and submit both parts of the application to the National Coordinator for the application to be considered complete. Please review Section III of the final rule for more details about the application and application review processes. 

Learn more about the Temporary Certification Program: 

For other questions relating to the Temporary Certification Program, email ONC.Certification@hhs.gov

ONC FACT SHEET ON
HITECH Temporary Certification Program for EHR Technology

Excerpted from ONC site June 19, 2010
The Health Information Technology for Economic and Clinical Health (HITECH) Act provides HHS with the authority to establish programs to improve health care quality, safety, and efficiency through the promotion of health information technology (HIT), including electronic health records (EHRs) and private and secure electronic health information exchange. 

The HITECH legislation directs the Office of the National Coordinator for Health Information Technology (ONC) to support and promote meaningful use of certified electronic health record (EHR) technology nationwide through the adoption of standards, implementation specifications, and certification criteria as well as the establishment of certification programs for HIT, such as EHR  technology..
 
About the Temporary Certification Program and ONC-ATCBs
To provide assurance to eligible professionals, eligible hospitals and critical access hospitals (CAHs) that the EHR technology they adopt will assist their achievement of meaningful use, the Department of Health and Human Services (HHS) issued a final rule to establish a temporary certification program for EHR technology on June 18, 2010. The rule outlines how organizations can become ONC-Authorized Testing and Certification Bodies (ONC-ATCBs). Authorized by the National Coordinator, ONC-ATCB are required to test and certify that certain types of her technology (Complete EHRs and EHR Modules) are compliant with the standards, implementation specifications, and certification criteria adopted by the HHS Secretary and meet the definition of “certified EHR technology”. 

About the Standards, Implementation Specifications, and Certification Criteria
On January 13, 2010, the Secretary published in the Federal Register an interim final rule that adopted standards, implementation specifications, and certification criteria for HIT. A final rule, which will realign with the Medicare and Medicaid EHR Incentive Programs final rule, is expected to be released in the near future. 

What Certification Means for Health Care Providers
EHR technology, certified by an ONC-ATCB must be used in order to qualify for incentive payments. The temporary certification program provides assurance that the EHR technology health care providers adopt is technically capable of supporting their efforts to achieve meaningful use. 

What Certification Means for Developers of EHR Technology
The temporary certification program provides a way for developers of EHR technology to have their HIT tested and certified so that it can be subsequently adopted by eligible professionals, eligible hospitals and CAHs who seek to achieve meaningful use. 

For other questions related to the Temporary Certification program, please email ONC.Certification@hhs.gov

•    Temporary Certification Program, visit http://healthit.hhs.gov/certification
•    Medicare and Medicaid EHR incentive programs, visit http://www.cms.gov/EHRIncentivePrograms/ 

Frequently Asked Questions:
Temporary Certification Program Final Rule

Excerpted June 19, 2010 from ONC site. Please check ONC site for latest updates.

A.    Background/General

Key Messages 

Health Care Providers: Key Points
In order to qualify for Medicare and Medicaid EHR incentive payments, providers must use EHR technology that has been certified by an Office of the National Coordinator for Health Information Technology-Authorized Testing and Certification Body (ONC-ATCB, or ATCB). The temporary certification program provides assurances that the EHR technology adopted by health care providers is technically capable of supporting their efforts to achieve meaningful use.

Developers of EHR Technology: Key Points
The temporary certification program provides a way for developers of EHR Technology to have their EHR technology tested and certified so that it can be subsequently adopted by health care providers who seek to achieve meaningful use. 

A1. What is the temporary certification program final rule?
The Secretary of Health and Human Services (the Secretary) issued the temporary certification program final rule to establish a process through which organizations may become ONC-ATCBs. An ONC-ATCB is authorized by the National Coordinator to test and certify EHR technology (Complete EHRs and/or EHR Modules).

A2. What is the purpose of the temporary certification program?
The temporary certification program is the first part of ONC’s two-part approach to establish a transparent and objective certification process. The temporary certification program was established to ensure that “Certified EHR Technology” will be available for adoption by health care providers who seek to qualify for the Medicare and Medicaid EHR incentive payments beginning in 2011. ONC-ATCBs will be required to test and certify EHR technology (Complete EHRs and/or EHR Modules) as being in compliance with the standards, implementation specifications, and certification criteria to be adopted by the Secretary in a forthcoming final rule.

A3. When will the temporary certification program end?
The temporary certification program will be in effect until the permanent certification program is in place. We anticipate that certifications issued under the permanent certification program will occur no earlier than January 1, 2012.

A4. How will ONC work with the National Institute of Standards and Technology (NIST) in regard to certification and standards?
ONC will work with NIST to ensure the availability of relevant test methods and other resources for the temporary certification program.  ONC will continue to work with NIST in developing the permanent certification program.

B.    Application Process
B1. How does an organization become an ONC-ATCB?
An organization must submit an application to the National Coordinator to demonstrate its competency and ability to test and certify EHR technology (Complete EHRs and/or EHR Modules). Once authorized, ONC-ATCBs are required to comply with the principles and conditions applicable to the testing and certification of EHR technology as specified in the temporary certification program final rule.  

B2. Can you provide an overview of the application process?
Applicants are required to request, in writing, an application for ONC-ATCB status from the National Coordinator at ATCBapplication@hhs.gov. The application has two parts: 

Part I: Provide general identifying and contact information; complete and submit the results of self-audits to all sections of ISO/IEC Guide 65:1996 (Guide 65) and ISO/IEC 17025:2005 (ISO 17025); submit additional documentation related to Guide 65 and ISO 17025; and agree to adhere to the Principles of Proper Conduct for ONC-ATCBs. 

Part II: Successfully complete a proficiency examination. 

Applicants are required to complete and submit both parts of the application to the National Coordinator for the application to be considered complete. Please review Section III of the final rule for more details about the application and application review processes.

B3. When will ONC begin accepting applications, and when will applicants be informed if they have received ONC-ATCB status?
The National Coordinator will begin accepting applications on July 1st and any time thereafter while the temporary certification program is operating.  Because the final rule is effective immediately, the National Coordinator will review, process, and make determinations regarding submitted applications as soon as possible.

B4. Will ONC limit the number applicants who apply for ONC-ATCB status?
ONC will not restrict the number of applicants who may apply for ONC-ATCB status. Having available more organizations with ONC-ATCB status will give developers of EHR technology more options for testing and certification.  

C.    Certification Process 

C1. I have an EHR technology ready for market. Is there anything I can do to get the technology certified now so that I can start marketing to hospitals and physicians?
Until organizations are authorized by the National Coordinator to perform testing and certification, EHR technology cannot be tested and certified in accordance with the temporary certification program final rule.  At this time, no organizations are currently authorized to test and certify EHR technology under the temporary certification program established by HHS, but when organizations attain ONC-ATCB status ONC will make it publicly known and post their names on our website.  ONC will work with ATCBs to encourage them to begin certifying EHR technology as soon as possible after they are authorized to do so.

C2. When will ONC-ATCBs be up and running?
ONC-ATCBs are permitted to start testing and certifying EHR technology consistent with the scope of their authorization as soon as it is received. Some ONC-ATCBs may need more time to establish their processes than others; however, we anticipate that ONC-ATCBs would be ready to test and certify EHR technology within a few weeks of attaining their authorization.
    
C3. How long will it take for an EHR technology to be certified?
This will vary according to the process used by the ONC-ATCB.

C4. What does a developer of EHR technology need to do to get its EHR technology tested and certified?
A developer of EHR technology will need to (1) select an ONC-ATCB that is authorized to test and certify its EHR technology (Complete EHR or EHR Module), and (2) demonstrate in accordance with the ONC-ATCB’s processes that the EHR technology provides the capabilities required by all applicable certification criteria adopted by the Secretary.

C5. Where can I find out information about EHR technology that has been certified?
ONC will maintain on its website a Certified HIT Products List (CHPL) as a single, aggregate source of all certified Complete EHRs and EHR Modules reported by ONC-ATCBs to the National Coordinator.  The CHPL will comprise all of the certified Complete EHRs and EHR Modules that could be used to meet the definition of Certified EHR Technology.  It will also include the other pertinent information we require ONC-ATCBs to report to the National Coordinator, such as a certified Complete EHR’s version number.  Eligible professionals and eligible hospitals that elect to use a combination of certified EHR Modules may also use the CHPL webpage to validate whether the EHR Modules they have selected satisfy all of the applicable certification criteria that are necessary to meet the definition of Certified EHR Technology.  

C6. Will EHR technology previously certified under any other programs or organizations automatically be certified by this new process?
No. In order to meet regulatory requirements implementing the HITECH Act, including the definition of “Certified EHR Technology,” EHR technology (Complete EHRs and/or EHR Modules) must be tested and certified by an ONC-ATCB. Any other certifications issued by an organization that is not an ONC-ATCB at the time of issuance will be invalid for purposes of meeting the definition of Certified EHR Technology and cannot be used to qualify for incentive payments under the Medicare and Medicaid EHR Incentive Programs. Unless reissued in accordance with the requirements of the temporary certification program, certifications previously issued by an organization that has subsequently become an ONC-ATCB will also be invalid for purposes of satisfying the definition of “Certified EHR Technology,” because such certifications were issued prior to the organization achieving ONC-ATCB status. 

Certification by an ONC-ATCB means that EHR technology meets the specific standards, implementation specifications, and certification criteria established for the temporary certification program. (HHS issued an interim final rule outlining specific standards and certification criteria on December 30, 2009, and a final rule is expected to be issued in the near future.) 

EHR technology must be tested and certified by an organization authorized by ONC as an ONC-ATCB, using currently adopted standards and certification criteria. Once ONC has authorized testing and certification organizations as ONC-ATCBs, the follow actions are appropriate: 

  • Developers of EHR technology who wish to have their EHR technology tested and certified should contact an ONC-ATCB
  • Health care providers who are eligible under the Medicare and Medicaid EHR Incentive Programs should contact their vendors to ensure their EHR technology is tested and certified by an ONC-ATCB under the temporary certification program requirements

C7. Will EHR technology certified under the temporary certification program be automatically certified under the permanent certification program?
EHR technology tested and certified by an ONC-ATCB under the temporary certification program will remain certified once the permanent certification program replaces the temporary certification program.  The change in certification programs will not affect the certified status of EHR technology at the time of change.  However, we anticipate that new or modified certification criteria will be adopted by the Secretary to support future stages of meaningful use, and as a result, certifications issued by ONC-ATCBs will presumably no longer indicate or represent that a Complete EHR or EHR Module can provide all of the capabilities necessary for an eligible professional or eligible hospital to achieve a future stage of meaningful use. 

C8. Whose responsibility is it to make sure that EHR technology gets tested and certified as required to meet the certification criteria adopted to support meaningful use?
In most cases it will be the responsibility of developers of EHR technology that sell EHR technology.  However, a health care provider that has developed its own EHR technology and is eligible under Medicare and Medicaid EHR Incentive Programs likely will be responsible for getting it tested and certified. 

C9. If I buy an EHR technology that is tested and certified, does that qualify me for the Medicare or Medicaid EHR incentive payments?
Having EHR technology that is certified by an ONC-ATCB is an essential part of qualifying for the EHR incentive payments. For details on the Medicare and Medicaid EHR Incentive Programs, please visit http://www.cms.gov/Recovery/11_HealthIT.asp

C10. I already use EHR technology. If it gets certified, will I qualify for the Medicare or Medicaid EHR incentive payments?
If the EHR technology you currently use is certified in the HHS temporary certification program, you may be eligible for incentive payments. For details on the Medicare and Medicaid EHR Incentive Programs, please visit http://www.cms.gov/Recovery/11_HealthIT.asp  

D. Comments on Proposed Rule 

D1. Where can I learn about how my comments on the proposed rule on the Establishment of Certification Programs for Health Information Technology issued in March were addressed in the temporary certification program final rule?
ONC staff carefully reviewed and considered each comment received on the proposed rule. Section III of the temporary certification program final rule includes a discussion of how the comments were incorporated into the temporary certification program final rule.

E. Related Rules 

E1. How does this final rule relate to the Medicare and Medicaid EHR Incentive Programs Proposed Rule?
The National Coordinator will use the temporary certification program to authorize organizations to test and certify EHR technology (Complete EHRs and/or EHR Modules). Once tested and certified, these types of HIT may be used to meet the regulatory definition of “Certified EHR Technology.” Health care providers who are eligible to qualify for incentive payments under the Medicare and Medicaid EHR Incentive Programs are required to use Certified EHR Technology, as promulgated in the CMS final rule.
HHS expects to issue final rules related to the initial set of standards, implementation specifications, and certification criteria and to the Medicare and Medicaid EHR Incentive Programs in the near future.

E2. When will the permanent certification program final rule be published?
We anticipate that a final rule for the permanent certification program will be issued by fall 2010 and that the permanent program will be in place in 2012. 

For other questions related to the Temporary Certification program, please email ONC.Certification@hhs.gov

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ONC Health IT Buzz Blog Post by Dr.David Blumenthal
Temporary Certification Program
Originally posted on June 18, 2010 on Health IT Buzz Blog by Dr. David Blumenthal
A surgeon can’t operate without the proper equipment. A clinician can’t achieve meaningful use of electronic health records without an EHR that is designed to improve patient care and practice efficiency.

The Secretary of the Department of Health and Human Services announces today a big step in ensuring that clinicians can easily identify EHRs and EHR modules that have the capabilities needed to achieve meaningful use and thereby reap the financial incentives offered by Medicare and Medicaid. The temporary certification program lays out a path by which organizations can become authorized to test and certify EHR products. Certification can give physicians confidence that the EHR product they choose has the capabilities to help their practices achieve meaningful use.

However, it does not mean that choosing an EHR will be a simple decision, or that certification of an EHR guarantees the provider using it will accomplish meaningful use. Certification is another example of how ONC supports the nation’s clinicians in the move towards a fully functional, secure health information exchange system. Combined with the technical advice and support of Regional Extension Centers, certification helps level the playing field and enables practices large and small to make educated choices that will lead to meaningful use.

Community Colleges Participating in Consortia to Educate Health IT Professionals

State-sorted List of the 85 ONC-funded Community College Consortia
to Educate Health IT Professionals
Go to Office of National Coordinator’s Web site to sort columns by heading.
Excerpted on June 18, 2010
 

Community Colleges Participating in the Program
School City State
National Park CC – AR Hot Springs AR
Pima College Tucson AZ
Maricopa College Phoenix AZ
Los Rios Community College District Sacramento CA
Cosumnes River College Sacramento CA
Butte College Oroville CA
Mission College Santa Clara CA
Fresno City College Fresno CA
Santa Barbara City College Santa Barbara CA
Cypress College Cypress CA
East LA College Monterey Park CA
Santa Monica College Santa Monica CA
Orange Coast College Costa Mesa CA
San Diego Mesa College San Diego CA
Pueblo CC Pueblo CO
Capital Community College Hartford CT
Community College of DC Washington DC
Broward College – FL Coconut Creek FL
Indian River State College – FL Ft. Pierce FL
Santa Fe College – FL Gainesville FL
Atlanta Technical College Atlanta GA
U of Hawaii CC-Kapiolani Honolulu HI
Des Moines Area Community College Ankeny IA
Kirkwood Community College Cedar Rapids IA
North Idaho College Coeur d’Alene ID
Moraine Valley Community College Palos Hills IL
Johnson County Community College Overland Park KS
Kentucky Comm and Tech Coll System Versailles KY
Delgado CC – LA New Orleans LA
Bristol Community College Fall River MA
Community College of Baltimore County Baltimore City MD
Ocean County College Toms River MD
Kennebec Valley Community College Fairfield ME
Southern Maine Community College South Portland ME
Delta College University Center MI
Lansing Community College Lansing MI
Macomb Community College Warren MI
Wayne County Community College Detroit MI
Normandale Community College Bloomington MN
St. Louis Community College St. Louis MO
Hinds CC – MS Raymond MS
Itawamba CC – MS Tupelo MS
Montant Tech Butte MT
 Pitt Community College Winterville NC
Catawba Valley CC – NC Hickory NC
Central Piedmont CC – NC Charlotte NC
Pitt CC – NC Winterville NC
Lake Region College Devil’s Lake ND
Metropolitan Community College Omaha NE
Community College sytem of New Hamphsire Concord NH
Brookdale Community College Lincroft NJ
Burlington County College Pemberton NJ
Camden County College Blackwood NJ
Essex County College Newark NJ
Gloucester County College Sewall NJ
Passaic County Community College Paterson NJ
Raritan Valley Community College Branchburg NJ
San Juan College – NM Farrington NM
College of Southern Nev Las Vegas NV
 Bronx Community College Bronx NY
Suffolk County Community College Brentwood NY
 Westchester Community College Valhalla NY
Cuyahoga Community College Cleveland OH
Cincinnati State Technical & Community College Cincinnati OH
Columbus State Community College Columbus OH
Sinclair Community College Dayton OH
Tulsa CC – OK Tulsa OK
Community College of Allegheny County Pittsburgh PA
Florence/Darlington – SC Florence SC
Dakota State College Madison SD
Chattanooga State CC – TN Chaaannooga TN
Dyersburg State CC – TN Dyersburg TN
Walters State CC – TN Morristown TN
Dallas County Comm Coll District – TX Dallas TX
Houston CC – TX Houston TX
Midland College – TX Midland TX
Salt Lake CC Salt Lake City UT
Tidewater Community College Virginia Beach VA
Northern Virginia Community College Annadale VA
Community College of Vermont Waterbury VT
Bellevue College Bellevue WA
Portland C C Portland WA
Madison Area Technical College Madison WI
Milwaukee Area Technical College Milwaukee WI
West Virginia Northern Community College Wheeling WV
 

NJHIMSS joins National Health IT Advocacy Day in Washington

Bus journey from New Jersey starts early morning at NJHA, Princeton: June 17, 2010

NJHIMSS ready to board bus,

NJHIMSS members pose before bus journey to Washingon DC.

NJHIMSS

NJHIMSS Members start boarding bus for DC.

Starting the day’s journey to Capitol Hill in early morning, June 17, 2010, members boarded a bus at NJHA in Princeton. Stopping in Cherry Hill to pick up additional HIMSS members, the bus sped (within speed limits) to Washington, DC.

 Lunching at Top of the Hill Reserve Officers Association, near the nation’s Capitol, the New Jersey chapter welcomed guests from the Hill, and listened to updates on New Jersey initiatives in Health IT.

Bill O'Bryne

Bill O'Bryne, Exec Director, NJ HITEC

Bill O’Byrne, the new executive director of NJ-HITEC, New Jersey’s Regional Extension Center, spoke about the challenges facing the center in bringing 5,000 New Jersey physicians and other clinicians on to meaningful use of Electronic Health Records.

The night before, O’Byrne received HIMSS State Official of the Year award, one of only three presented this year, for his work supporting Healthcare IT initiatives in New Jersey.

Additional pictures on BluePrint Healthcare IT’s Community section–click ere.