Enterprise Consent Model for use with the MassHIway

1. Enterprise Consent Model for use with the MassHIway Deborah Adair Director Enterprise Health Information Management November 1, 2016

2. Agenda PHS Enterprise Consent Model Planning Stage Implementation: Staff and Patient Education Materials Sensitive Information Strategy Consent Metrics Challenges

3. PHS Enterprise Consent Model PHS eCare – One Patient, One Record Enterprise Electronic PHS Mass HIway Consent Collect Once From the Patient Apply Patient Choice Throughout Partners Healthcare including our EHR affiliates

4. Current State Collecting signed PHS MassHIway consent in registration system Integrated with registration staff workflow Interfaced with EMPI Consent Flag Uses e-form and signature pads Sites not on e-Care built or used existing flags in their local registration systems and interfaced with EMPI

5. Current State Collect consent in Patient Portal: Patient Gateway Message on PG homepage for patients who have not opted in or out Patients may change HIway status at anytime by logging into their PG account

6. Planning Stage • HIway Consent Implementation Workgroup created and met weekly: • Health Information Management • Information Systems • Patient Access (registration) • PeCare • Care Everywhere (Epic’s HIE) • Patient Gateway (patient portal) • Chief Information Medical Officers • MU project managers • Compliance Officers • Office of General Council • Workgroup reported to HIE Steering Committee

7. Implementation: Staff Education (toolkit)

8. Implementation: Staff Education (toolkit)

9. Implementation: Staff Education (Procedure)

10. Implementation: Staff Education (system)

11. Implementation: Patient Education

12. Sensitive Information • Initial roll-out, rules logic suppressed CCDAs with sensitive data • Epic 2015 version implemented functionality to apply rules logic to expire HIway Consent • For patients with sensitive data who sign HIway Consent, it is active for that encounter, then expires • Patient prompted to sign again next time • For Inpatient Psych admissions, 42 CFR programs, Ambulatory Psych visits and other highly sensitive departments: • CCDAs are not auto-sent upon discharge or referral workflows and encounters level data and notes are always suppressed

13. Mass HIway Metrics Cummulative Summary as of 10/1/16 Opt-In Total: 522,832 Opt-Out Total: 96,985

14. Greatest Challenges Patient Education (patients have no idea what this is and are weary of signing) Staff Education (registration staff don’t have time to explain it and also don’t have enough knowledge, even with training, to answer patients’ questions) ED environment (patients’ conditions make obtaining HIE consent extremely difficult and a voluntary consent falls to the bottom of the priority list) Sensitive data (requires resources to build logic and systems that can support suppression and/or expiration) State-wide education campaign is needed (People are not seeing the benefits or hearing success stories)

15. HIway Regulations: Opt-In & Opt-Out Mechanism • M.G.L. Chapter 118I describes that there shall be a mechanism for patients to opt-in and opt-out of the HIway. • EHS is proposing to clarify and focus the opt-in/opt-out mechanism based on specific HIE functions: • Opt-in mechanism: Provider Organizations give patients public notice • Public notice may include, but is not limited to: visible posters, handouts, inclusion in the privacy notice, banner on a web portal, letteror email to the patient • The HIway will provide a sample public notice that Provider Organizations may adapt and use • Opt-out mechanism: A centralized opt-out mechanism • Provider Organizations also have the option of an additional local opt-in/opt-out mechanism • EOHHS would accompany the regulations with state-wide education for both patients and Provider Organizations