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Rhode Island Quality Institute Behavioral Health Integration Project Statewide Session August 22, 2012. Agenda. Agenda (cont’d). CurrentCare and You: How We’re Doing 10 mins Walter (Bud) Hodes, Behavioral Health Program Manager
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Rhode Island Quality Institute Behavioral Health Integration Project Statewide Session August 22, 2012
Agenda (cont’d) • CurrentCare and You: How We’re Doing 10 mins • Walter (Bud) Hodes, Behavioral Health Program Manager • Rhode Island Quality Institute • Enrollment: Key to Successful Use 15 mins • Richard Leclerc, President David Boscia, Program Manager • Gateway Healthcare, Inc • Next Steps/Making It Happen 10 mins • Laura Adams, President & CEO • Rhode Island Quality Institute • Take Action • Plan three steps to advance Behavioral Health Information Exchange at your CMHO. • RIQI will call you within 2 days to talk about your plan and how to make it happen.
Rhode Island Quality Institute Behavioral Health Integration ProjectStatewide SessionBenefiting Clients, Benefiting Providers Jonathan Leviss, MD Chief Medical Officer, RIQI Physician, Thundermist Health Center Sajid Choudhry, MD Psychiatrist, Gateway Healthcare
Questions… • How do we achieve the Behavioral Health vision? • What services or technologies from RIQI are available? • What’s the status of the CurrentCare Viewer (HIE)? • Who is using the CurrentCare Viewer? • Could the Viewer help me? If so, how?
CurrentCare : RI’s Health Information Exchange • A secureelectronic network that allows doctors and healthcare providers access to patients’ most up-to-date health information • A repository containing healthcare data of enrolled patients • From participating hospitals, labs, pharmacies, and medical practices • For participating healthcare providers to use for treating patients • A means to provide services that lead to better clinical outcomes and better economic value
CurrentCare Services CurrentCare Hospital Alerts PCP’s receive email notification of ADT CurrentCare Viewer Secure repository containing healthcare data of enrolled patients Providers can access to view patient data
Safe, Secure, and Compliant • Based on best practices (e.g., payment card industry standards) • Highly secure system to assure integrity and privacy • “Industrial strength” technology and operating processes • Compliant with HIPAA, HITECH and RI Law
CurrentCare Viewer: How it works • The CurrentCare Viewer shows PHI for enrolled patients: • Labs – from different sources, all in one place • Encounters • Documents • Allergies & Alerts • Conditions • Medications • Improve quality of care • Eliminate need for redundant lab tests • Help to avoid high occurrence of readmission rates in RI Goal: to allow a healthcare provider access to clinical data for consented patients
CurrentCare Viewer—what’s available? • More than 240,000 patients; growing 6,000+ per month • 10.5 million transactions processed • 23 data feeds with more in progress As of 8/10/2012 *Admission/Discharge/Transfer **Continuity of Care Document
CurrentCare Data Feeds—what’s coming As of 8/10/2012 *Admission/Discharge/Transfer **Continuity of Care Document
CurrentCare Viewer: Demo Perspective of the Clinician CurrentCare Viewer Co-presented by: Steven Borek Business Systems Analyst, RIQI
Perspective of a Psychiatrist Sajid Choudhry, MD Psychiatrist, Gateway Healthcare
The CurrentCare Consent Modelfor the disclosure of substance abuse treatment recordsAugust 22, 2012 Presented By: Linn F. Freedman, Esq. Nixon Peabody LLP
RIQI’s Statewide Health Information Exchange (HIE): CurrentCare • The Rhode Island Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (“BHDDH”) indicates support for including patients’ substance abuse treatment information in CurrentCare • Use of CurrentCare will increase the efficiency and effectiveness of treatment
CurrentCare • Must comply with both federal and state regulations for the protection of patients’ confidential health information, in particular, the patients’ substance abuse treatment records • A uniform authorization form for CurrentCare is currently being drafted for each substance abuse provider to use specifically for the purpose of obtaining patient consent to transfer treatment records to CurrentCare • The uniform authorization form will hopefully be included in the BHDDH Regulations
Federal Regulations 42 U.S.C.§290(ee)(3) and 42 U.S.C. 290(dd)(3) • Disclosure of Substance Abuse Records Prohibited • Includes any identifying information or diagnosis or treatment in a federally assisted program (42 C.F.R. §2.12(a)(i)-(ii)) • Referred to as a “Part 2 Program” • Disclosure ALLOWED if patient provides written consent (42 C.F.R. §2.1(b), §2.2(b))
Written Patient Consent42 C.F.R. §2.1(b), §2.2(b) • Patient’s Part 2 Program first responsible for obtaining patient’s written consent prior to disclosing substance abuse records to CurrentCare • RIQI then responsible to obtain authorization from the patient to disclose or allow any other treatment provider access to substance abuse treatment records from a Part 2 Program through CurrentCare
Rhode Island Regulations R.I.G.L. §23-1.10-13 • Must maintain confidentiality and privilege of patient’s treatment records from BHDDH facilities
Rhode Island Health Care Communications and Information Act R.I.G.L. §5-37.3-1 • Protection of patient health information INCLUDING substance abuse treatment records
Rhode Island Health Information Exchange Act of 2008 R.I.G.L. §5-37.7-1 • Protection of the confidentiality of patient records • Patient may opt in or out of the enrollment in the HIE and designate only specific healthcare providers access • Only accessed, released or transferred from the HIE in accordance with authorization form signed by the patient or authorized representative • Includes alcohol and drug abuse information
CurrentCare’s Compliance with State and Federal Laws and Regulations • To protect patient confidentiality RIQI proposes the following consent and authentication process: • Ensure that each patient provides written specific consent for the disclosure of their substance abuse treatment records from a Part 2 Program to CurrentCare. • Absent such specific written consent, the patient’s substance abuse treatment records from that Part 2 Program will not be disclosed to or available through CurrentCare.
CurrentCare’s Compliance with State and Federal Laws and Regulations (cont'd) • Obtain separate written consent (through the CurrentCare enrollment form) from each patient that authorizes disclosure of all of their PHI, including their substance abuse treatment records from a Part 2 Program, to CurrentCare and consenting to the disclosure of such records to either (i) any of the patient’s treating providers; or (ii) only specific treating providers explicitly named by the patient; or (iii) only in the event of an emergency. • Only treating providers of the patient authorized on the enrollment form to access the patient’s PHI, including Part 2 Program records, will have the option to access such records through CurrentCare. • Affirmative confirmation of a treating relationship with the patient is required before a provider can have access to any of the patient’s PHI
CurrentCare’s Compliance with State and Federal Laws and Regulations (cont'd) • CurrentCare will separate records received from a Part 2 Program from the patient’s other PHI. • Once the treating provider has certified to a treating relationship with the patient, the provider will have access to the Menu of PHI available through CurrentCare, including PART 2 Program information • If the provider clicks on the Part 2 Program tab of the Menu, the system will either advise that there is no Part 2 Program information or require additional affirmations of the provider in order to access the Part 2 Program information
CurrentCare’s Compliance with State and Federal Laws and Regulations (cont'd) • Any providers that attempt to access a patient’s Part 2 Program information through CurrentCare must again certify that they are accessing the Part 2 records in order to facilitate the patient’s treatment
CurrentCare’s Compliance with State and Federal Laws and Regulations (cont'd) • Before accessing PART 2 Program records, providers will also acknowledge that they are prohibited from redisclosing such records absent express authorization from the patient to do so (in order to comply with the redisclosure requirements of PART 2) • Consequently, an additional affirmative action will be required by all providers to access the Part 2 Program records and to acknowledge the prohibition of redisclosure
CurrentCare’s Compliance with State and Federal Laws and Regulations (cont'd) • CurrentCare will enter into a Data Sharing Partner Agreement/Data Use Agreement with each Part 2 Program that discloses patient records to CurrentCare or accesses patient records and a Data Use Agreement with any provider that accesses patient records through CurrentCare, including Part 2 Program records
Conclusion • RIQI’s proposed consent model and authentication procedures with respect to CurrentCare patient participants’ substance abuse treatment records comply with applicable federal and state regulations • SAMHSA has reacted favorably to the proposed consent model
Thank You! Questions? Linn Foster Freedman, Esq. Nixon Peabody LLP One Citizens Plaza, Suite 500 Providence, RI 02902 Phone: (401) 454-1108 Fax: (866) 807-6614 Email: lfreedman@nixonpeabody.com
Direct Messaging—Easy & Secure Jonathan Leviss, MD Chief Medical Officer, RIQI Physician, Thundermist Health Center
What is “Direct”? Direct messaging is secure email for exchanging health information—a simple, cost-effective mechanism to transport patients’ protected health information (PHI) to known, trusted recipients over the Internet. • Email • To Exchange Health Information • Trusted Recipients • Via the Internet
How does Direct messaging work? • Positioned to operate with HIEs and other NHIN (Nationwide Health Information Network) initiatives • The Direct Project is an integral component of a broader national strategy to have an interconnected health system through a Nationwide Health Information Network. The Nationwide Health Information Network is being developed “to provide a secure, nationwide, interoperable health information infrastructure that will connect providers, consumers, and others involved in supporting health and healthcare. This critical part of the national health IT agenda will enable health information to follow the consumer, be available for clinical decision making, and support appropriate use of healthcare information beyond direct patient care so as to improve health.”* • www.directproject.org * Taken from the Direct Project Overview Document @ www.directproject.org
Why Adopt Direct Messaging? • To securely exchange notes, referrals, CCDs, diagnostic images, and summary of care records in simple, fast, and inexpensive way. • For efficient and fast exchange of patient health information • To decrease the dependence on higher cost, less secure methods of exchange • To start the foundation for more advanced functionality in exchanging health information Service is provided by a HISP (Health Information Service Provider) – vendors are listed in our Vendor Marketplace Goal: to enable the secure exchange of protected health information (PHI)
Behavioral Health Program Overview • Progress is being made, but slower than expected • Rhode Island is a Nationally Recognized Leader in the Transformation of Health Care Delivery • We must move forward!
How Are We Doing • CurrentCare Enrollment • Target: 3500 Behavioral Health enrollments, to date we have about 350 • Gateway at Hartford did well, but overall we need to improve • Direct Adoption • Target: 9 CMHOs using Direct in their workflow • 4 CMHOs are completing the process to getting their accounts • 6 CMHOs have started the process • 3 CMHOs need to get started • We have some engaged, but we need to improve
How Are We Doing • CurrentCare Viewer • Target: 9 CMHOs and 21 sites using the viewer • 3 CMHOs are using the viewer at 11 sites • We have use, but we need to improve • Data Sharing from 2 CMHO EHR • 42 CFR Part 2 addressed - we can move ahead • Vendors and CMHOs reengaged • Project delayed 3 months, but we are moving ahead now
Enrollment - Key to Successful Use • Gateway Healthcare, Inc • Richard Leclerc, President & CEO • David Boscia, Program Manager
Next Steps/Making It Happen • Rhode Island Quality Institute • Laura Adams, President & CEO