Understanding Data Exchange Application Agreements (DEAA) for Health Homes

1. Health Home Implementation Webinars Session 14– April 10, 2013 Data Exchange Application Agreements

2. What is a DEAA? What data exchange is and is not allowed? • The DEAA allows the DOH to exchange lists of Health Home members with the lead Health Home. • The lead Health Home then completes subcontractor packets with network partners, permitting the lead Health Home to share lists and demographic data with their partners prior to member consent.

3. What is a DEAA? What data exchange is and is not allowed? The DEAA does not permit: • Data exchange between other lead Health Homes without a subcontractor packet (a lead to lead packet is being developed). • Data exchange with local social service districts without a subcontractor packet. (Comment: Local Districts have valuable information that can aid in identifying members. Subcontractor packets are an easy and recommended solution to permit data exchange to assist the local districts in updating data while providing Health Homes with valuable information.

4. What is a subcontractor packet and when is it used? What is the process? • The subcontractor (aka downstream or network provider) packet is designed to allow the lead Health Home to share data with network partners, e.g., with those that provide case management services or other services (e.g., outreach) prior to obtaining member consent. • Subcontractors are engaged by the lead Health Home, not vice versa. • Subcontractors complete their portion of the packet and then return it to their lead Health Home (not DOH).

5. What is a subcontractor packet and when is it used? What is the process? • The lead Health Home then authenticates the packet by signing the Executory Clause, BAA and Confidentiality Agreement. • The lead Health Home then submits the packet to DOH (Privacy Coordinator). • Once reviewed and approved, an Approval Letter is generated to the lead Health Home, permitting data sharing. • In order to permit data sharing between two network partners (subcontractors) a reciprocal subcontractor packet must be executed (this is being developed).

6. Is a DEAA needed for community referrals? • Members do not have to be on DOH lists or be approved by DOH in order to be accepted as a Health Home referral. • Health Homes, their partners, and MCPs are responsible for determining whether the individual presumptively meets Health Home criteria. • The State is not involved in the assignment of a community referral, hence a DEAA is not required for exchange of information about the prospective member. EXAMPLE: A member is seen in the ED , having signed the required ED Notice of Privacy, where the ED MD refers member to Health Home A. This is a community referral.

7. Can lead Health Homes refer or transfer members to other lead Health Homes? • If the member has been assigned by the DOH, the Health Homes must have executed agreements with each other to share information about the member and arrange referrals or transfers. The transfer must be reported on the Health Home tracking system using the appropriate reason codes. • If a Health Home determines that it cannot meet the needs of an assigned member, and cannot refer or transfer him/her to another health home or partner then: • If the member was assigned to the HH by DOH but has not received HH services, submit a rejection record to the tracking system. • If the member has received Health Home services, the member’s enrollment should be end dated by submitting a change record to the tracking system using the appropriate reason code. • DOH will reassign the member to another Health Home with the next list.

8. Data Sharing and Consent Can a care management provider share data on a converting member with the lead Health Home? • A care management provider can share data on a converting member with the lead Health Home after the subcontractor packet /agreement is in place. • Care management providers can collect and manage converting Health Home members prior to the subcontractor packet/agreement is in place, including obtaining consent. • Once the subcontractor packet/agreement is in place, the member’s information can be communicated to the Health Home.

9. Data Sharing and Consent Consent form • The Health Home consent allows sharing of health information with / from core health home partners involved in the members care that are listed on the consent form. It includes medical, behavioral health, & SUD treatment providers and CM agencies; & others per the website : http://www.health.ny.gov/health_care/medicaid/program/medicaid_health_homes/form) • It includes Regional Health Information Organization ( RHIO) consent for Health Homes participating with RHIOs • The member does not need to sign the consent at the same time as he/she agrees to receive and participate in Health Home services as long as that member can still be effectively managed without sharing/ obtaining Health Information.

10. Opt Out and Withdrawal of Consent • Opt Out ( DOH-5059) • Health Home participation is not mandatory and individuals who do not want to participate can “opt-out” of the program prior to consenting. . • Signing the Opt-out form (DOH 5059) indicates they do not want to participate or receive Health Home services • Health Home Patient Information Sharing Withdrawal of Consent Form- (DOH-5058) • For a Health Home member that has already consented and the member decides at any time to discontinue receiving Health Home services • The member/ legal representative should be filled out and sign Health Home Patient Information Sharing Withdrawal of Consent Form- (DOH-5058) • If the member cannot be located, disenroll the member according to Health Home policies/ procedures, and information sharing should be discontinued upon disenrollment.

11. Questions, Comments, or Concerns? • Questions on the DEAA process, subcontractor packets and Business Associate Agreements (BAAs)regarding sharing Medicaid data should be directed to: • doh.sm.medicaid.data.exchange@health.ny.gov

12. Alert Use Cases Eric Weiskopf, M.Ed – OHITT Ellen Flink – OHITT

13. Fully Operational Health Home with Embedded or Subcontracted Care Manager • Health Home Consent signed • Single-Entity RHIO Consent signed in ED

14. HH Partner RHIO Consent Subcontractor packet All American Hospital Health Home with Embedded Care Manager Alert RHIO Care Management Application Health Home Consent RHIO Consent Subcontractor packet Alert Subcontracted Care Manager HH Member enters All American Hospital Emergency Department All American Hospital

15. Fully Operational Health Home with Embedded or Subcontracted Care Manager • Health Home Consent signed • Multi-Entity RHIO Consent signed in ED

16. HH Partner Subcontractor packet All American Hospital Health Home with Embedded Care Manager RHIO with Multi-Entity Consent Alert Care Management Application Health Home Consent Alert Subcontractor packet Subcontracted Care Manager All American Hospital HH Member enters All American Hospital Emergency Department

17. Health Home Member Enters Emergency Department of Health Home with Embedded Care Manager • Health Home Consent not signed • Single-Entity Consent signed in ED

18. All American Hospital - Lead HH with Embedded Care Manager RHIO Alert No Health Home Consent RHIO Consent HH Member enters All American Hospital Emergency Department All American Hospital Emergency Department

19. Scenario: Health Home wishes to send member tracking file to local RHIO RHIO uses information to match patient to appropriate Health Home and sends alerts to care manager. Prerequisite: To share information that comes directly from Medicaid, a RHIO must sign a subcontractor packet with the lead Health Home to become a Heath Home sub-contractor. Previously signed BAA that existed between RHIO/Health Home as a part of a RHIO participation agreement is not enough to allow Health Homes to send information gleaned directly from Medicaid to the RHIO.

20. Health Home Member Enters Emergency Department of Health Home with Embedded Care Manager • Health Home Consent not signed • Single-Entity RHIO Consent signed • Health Home has an approved subcontractor packet with RHIO

21. Subcontractor packet All American Hospital - Lead HH with Embedded Care Manager Demographic Alert RHIO No Health Home Consent RHIO Consent HH Member enters All American Hospital Emergency Department All American Hospital Emergency Department

22. Health Home Member Enters Emergency Department of Health Home with Sub-Contracted Care Manager • Health Home Consent not signed • Single-Entity RHIO Consent signed at ED • Health Home has an approved subcontractor packet with both RHIO and Sub-Contracted Care Manager

23. Subcontractor packet Demographic Alert All American Hospital – Lead HH RHIO No Health Home Consent Demographic Alert Demographic Alert RHIO Consent Subcontractor packet Subcontracted Care Manager HH Member enters All American Hospital Emergency Department All American Hospital Emergency Department

24. Health Home Member Enters Emergency Department of Health Home with Sub-Contracted Care Manager • Health Home Consent not signed • Single-Entity RHIO Consent signed for Sub-Contracted Care Manager • Health Home has an approved subcontractor packet with both RHIO and Sub-Contracted Care Manager

25. Subcontractor packet All American Hospital – Lead HH Demographic Alert RHIO No Health Home Consent Demographic Alert RHIO Consent RHIO Consent Demographic Alert Subcontractor packet Subcontracted Care Manager HH Member enters All American Hospital Emergency Department All American Hospital Emergency Department

26. Health Home Member Enters an Emergency Department of a Different Health Home • Health Home Consent not signed

27. HH Member assigned to All American Hospital Health Home enters New York Hospital Emergency Department New York Hospital RHIO Consent Demographic Alert All American Hospital Health Home with Embedded Care Manager RHIO No Health Home Consent Subcontractor packet RHIO Consent Demographic Alert Subcontracted Care Manager All American Hospital Emergency Department

28. Health Home Member Enters an Emergency Department of a Different Health Home • Health Home Consent not signed • Health Home has an approved subcontractor packet with RHIO and Sub-Contracted Care Manager • Sub-Contracted Care Manager has RHIO consent

29. New York Hospital HH Member assigned to All American Hospital Health Home enters New York Hospital Emergency Department RHIO Consent Subcontractor packet Demographic Alert All American Hospital – Lead HH with Embedded Care Manager RHIO No Health Home Consent Demographic Alert Subcontractor packet RHIO Consent RHIO Consent Subcontracted Care Manager All American Hospital Emergency Department

30. Health Home Member Enters an Emergency Department of a Different Health Home • Health Home Consent not signed • Health Home has an approved subcontractor packet with RHIO, Sub-Contracted Care Manager, and a 2nd Health Home • Sub-Contracted Care Manager has RHIO consent

31. New York Hospital New York Hospital Health Home RHIO Consent Subcontractor packet Subcontractor packet Demographic Alert All American Hospital Health Home with Embedded Care Manager RHIO No Health Home Consent Demographic Alert Subcontractor packet RHIO Consent RHIO Consent Subcontracted Care Manager All American Hospital Emergency Department

32. Questions, Comments, or Concerns? Contact: Eric Weiskopf esw01@health.state.ny.us 518 473 7960

33. Webinar Questions