Tag Archives: arra

Summary of Massachusetts Health IT Plan

Overview

The Massachusetts Health IT Draft Plan was released for public comment in January 2010 and the commenting period is now closed. The plan outlines high-level statewide goals and strategies for achieving improved health outcomes and reduced costs through the use of interoperable EHR systems and health information exchange (HIE). The document sets up governance structures and policy priorities for the planning for use and implementation of federal HI-TECH funds. Currently MA has been awarded ~$25mil, $14mil to MeHI for regional extension centers (RECs) and $10mil to MeHI for HIE. After the MA HIT Plan is adopted, the HIT Council is responsible for the governance structure and MeHI is the Project Management Office (PMO).

The HIT Plan was created in response to a number of MA statutes, including Chapter 305, MA 201 CMR 17:00, and Executive Order 504. The original plan was publicly announced in Jan 2009, but withdrawn due to the announcement of the HITECH Act portion of ARRA. The HIT Council and MeHI contracted Deloitte to update the plan to correspond with the HITECH Act and Meaningful Use regulations.

The tentative milestones lay out an aggressive plan in line with federal meaningful use requirements.

Tentative Milestones

Target Year Key Milestone Examples
2010
  • Develop HIT Strategic Plan
  • Establish PMO
  • Develop Governance structure with decision-making processes
  • Convene Ad-Hoc Workgroups
  • Produce Program communication plan
  • Initiate Vendor Management and contractual agreements
  • Submit the HIE operational plan including sustainability, privacy and security, etc.
  • Develop Certification Program IOO
  • Provider funding alternatives
  • Oversee the REC Operational Plan
  • Establish Medicaid Partnership
  • Recruit approximately 25% Priority Providers for REC
  • Coordinate Workforce development activities
  • Select HIE Vendor(s)
2011
  • Recruit approximately75% priority providers for REC
  • Establish Patient Engagement baseline
  • Provide Certification Program statewide HIE
  • Pilot Operational HIE (clinical)
  • Ensure REC Priority Providers achieve stage 1 meaningful use
  • Provide Initial Population Health Reporting (local)
2012
  • Ensure Operational HIE comleted with governance structure in place
  • Provide Consumer Engagement survey
  • Ensure the Integration of EHRs to operational HIE
2013
  • Ensure REC Priority Providers achieve stage 2 meaningful use
  • Develop Expansive Population Health Reporting (local, state, national)
2014
  • Pilot Interstate HIE Interoperability
  • Re-Certify IOOs
  • Perform Privacy and Security Audit
2015
  • Meet Chapter 305 requirement of implementing EHR systems in all provider settings and integrating those systems through a robust HIE Interstate
  • Complete HIE Interoperability
  • REC Priority Providers achieve stage 3 meangingful use
  • Provide Consumer Engagement survey
  • NHIN pilot if available

Statutory Overview

  • Chapter 2008 passed in August 2008
  • MA Legislation Chapter 305 formed the HIT Council
  • The HIT Council was charged with creating a statewide HIT Plan and updating it annually. Plans must be approved by the council and the MA Technology Collaborative Board
  • HIT Council Members – (look this up), includes Karen Bell
  • Background – contracted BCG to create plan which was completed by Jan 2009, right when the Stimulus bill & HITECH Act were released, so plan was pulled back. Deloitte was contracted to create updated plan which was released Jan 2010
  • “Community-Based Approach” – inspired by Mass eHealth Collaborative’s 2004 EHR deployment in 3 communities with attempted interoperability, supported by $50mil MA BCBS grant
  • MA Plan adopts opt-in HIE and anytime opt-out (which is different than many other states which are opt-out)

MA HIT Plan – Table of Contents

  • Executive Summary
  • Introduction
  • Establish Multi-stakeholder governance
  • Establish a Privacy Framework to Guide the Development of a secure HIT environment
  • Implement interoperable electronic health records in all clinical settings and assure they are used to optimize care
  • Create a local workforce to support HIT related initiatives
  • Monitoring success
  • Path forward

Discussion

  • ARRA
    • Regional Extension Centers (RECs): Provided ~$14mil to MeHI (the MA regional extension center) for implementation of regional extension centers in MA ($625mil total, and ~$100mil given out so far)
    • Health Information Exchange (HIE): Provided $10.6mil for HIE funds to MeHI (again, the state-selected entity), to create the plan (and no one knows where the plan will take us)
  • Carol Rodenstein, MeHI Program Director
  • HIT Council Members
    • JudyAnn Bigby, MD, Secretary of HHS Massachusetts
    • Deborah A. Adair, Director of Health Information Services and Privacy Officer, MGH
    • Meg Aranow, VP & CIO, Boston Medical Center
    • Karen Bell, MD, Sr. VP of HIT Services, Masspro
    • Lisa Fenichel, MPH, eHealth Consumer Advocate
    • Jay Gonzales, Secretary of Administration and Finance, Massachusetts
  • Median practice size in MA is 3 physicians
  • Masspro has a lot of experience with small practices and workflow issues associated with EHR implementation
  • End of April, governor is inviting governors from entire country, all 50 HIT coordinators, all 50 Medicare reps, all 50 Mecaid reps, and others to bang heads re: conference
  • Health care is the largest employer in Mass, employing ~450k workers with $29bil in revenue in 2005.
  • Small practices aren’t going away…will lead to the rise of the IPAs
  • Health delivery will look a lot different in 2015

High Level Policy Goals:

  • Goal 1: Improve access to comprehensive, coordinated, person-focused health care through widespread provider adoption and meaningful use of certified EHRs
  • Goal 2: Demonstrably improve the quality and safety of health care across all providers through HIT that enables better coordinated care, provides useful evidence-based decision support applications, and can report out data elements to support quality measurement.
  • Goal 3: Slow the growth of health care spending through efficiencies realized from the use of HIT.
  • Goal 4: Improve te health and wellness of the Commonwealth’s population through public health programs, research, and quality improvement efforts enabled through efficient, reliable and secure health information exchange processes.

Strategies to Accomplish these  Goals:

  1. Establish multi-stakeholder governance
    1. The components of the proposed governance structure are:
      1. These organizations: HIT Council, MTC, MeHI
      2. 6 Ad Hoc workgroups: Clinical Quality and Public health, consumer engagement, education, and outreach, Privacy and security, regional extension center, HIE, workforce development
    2. Estimated that this will be >= 90% private funded
    3. HIT Council oversees governance structure
    4. MeHI is acting Project Management Office
  2. Establish a privacy framework to guide the development of a secure HIT environment
    1. ONC’s 6 Privacy Principles: Individual Access, Correction, Openness and Transparency, Individual Choice, Collection, Use and Disclosure Limitation, Data Quality and Integrity
    2. Commonwealth’s privacy and security framework will focus on four key areas: Compliance with policies and standards, Secure HIE technology, Process for certification, Consent management
    3. Privacy/Security rules based on the following previous rulings:
      1. Federal: HIPAA, HITECH Act, FISMA, MITA, HITSP, NIST 800 Series, Privacy Act of 1974
      2. State: Chapter 305, MA 201 CMR 17:00, and Executive Order 504
  3. Implement interoperable health records in all clinical settings and assure they are used to optimize care
    1. MA  has officially adopted the goal of meaningfully used EHR in all physician practices by January 1, 2015
    2. MA will provide direct assistance to ~2500 providers to achieve Meaningful Use by contracting with Implementation Optimization Organizations (IOOs)
    3. To ensure adequate funding – 1) promote a loan program, 2) endorse use of state funds, 3) provide support to providers to receive Medicare incentives
    4. Build an effective REC program for the Commonwealth focusing on: individual & small group practices, public and critical access hospitals, community health centers and rural health clinics, other clinics serving the underserved
  4. Develop and implement a statewide HIE infrastructure to support care coordination, patient engagement, and population health
    1. HIE Priorities: administrative simplification, e-prescribing, electronic laboratory ordering, electronic public health reporting, quality reporting, prescription status, coordination of care/clinical summary exchange
    2. Will continue to support PHR’S currently supported by MA providers and payers
    3. This effort will be lead by MeHI
    4. Existing HIE Initiatives in MA: Northern Berkshire eHealth Collaborative, Newburyport, SAFEHealth, CHAPS, and NEHEN
    5. MeHI has selected a hybrid HIE model (as opposed to centralized or federated) which will use both centralized and distributed data repositories, allowing the majority of the data to stay at the site of collection
  5. Create a local workforce to support HIT related initiatives
    1. High demand and low supply right now for health IT employees
    2. Estimated through 2016 that 64k new health care jobs will be created in the Commonwealth
    3. Development of training programs using federal dollars focusing on implementation, project management, practice management, and data management. Programs will intentionally seek out unemployed persons.
  6. Monitor success
    1. Quality measurement program for REC, HIE, and Workforce Development programs
    2. Indicators selected for reporting will fit into the objectives of the high-level goals of the MA HIT Plan
    3. The HIT Council is responsible for selecting the indicators

CCHIT Announces MU Stage 1 Certification Program

Today, the Certification Commission for Health Information Technology (CCHIT) announces its Certification Program for Meaningful Use Stage 1, the first in 3 stages of the CMS/ONC health IT incentive program. The press release is available here: http://www.cchit.org/media/news/2010/01/commission-updates-certification-programs-new-hhs-rules.

CCHIT released 3 gap analyses for Eligible Providers, Hospitals, and Security to assist those that were previously CCHIT Certified get into compliance with MU Stage 1. The gap analyses and certification program details are available here: http://www.cchit.org/get_certified.

CCHIT is hosting a public “Town Call” on January 27 at 3PM CT to discuss the gap analyses and ARRA Preliminary Certification programs. For details about connecting to this call, go here: http://www.cchit.org/about/towncalls/hhs-ifr-hit-gap-analysis.

HIT Policy and Standards Committees Convene

Over the past 2 weeks, David Blumenthal, the National Coordinator for Health IT and HHS announced members of the Health IT Policy and Standards Committees. Dr. John Halamka, author of Life as a Healthcare CIO and member of the policy committee, wrote about the committee’s first meeting on May 12, 2009.

The committee will focus on 6 priority areas:

  • Meaningful Use
  • Certification
  • Infrastructure
  • Privacy and Security
  • Health Information Exchange
  • Public Health

Of note, Blumenthal stated:

“This is the first time in history that Congress has acted to correct some of the market errors in the healthcare information technology industry.”

Blumenthal is referring to the fact that most people agree health IT can improve quality, but adoption remains low in part due to market failure. The major payers in healthcare, insurers, stand to save a lot of money but providers have to pay for the implementation of EHR, CPOE, etc.

The million dollar question is “What is meaningful use?” Under the ARRA, the federal government will increase Medicare/Medicaid reimbursement for providers with EHR implementations that meat meaningful use criteria. The National Committee on Vital and Health Statistics (NCVHS) convened a Hearing on Meaningful Use of HIT on April 28.  Entire agenda, transcript and slides are available online, including Dr. Blumenthal’s opening remarks. Blumenthal outlined 5 action points for the HIT Policy Committee to follow the NCVHS hearing:

  1. Define meaningful use. This is an unprecedented task. The HIT Policy Committee will need to pick-up where NCVHS left off. ONC also has an internal group working on this.
  2. Review certification, which is tied to meaningful use.
  3. Infrastructure. Congress has allocated billions to accelerate industry adoption including extension centers, money to support information exchanges, training workers, training health professionals who will use these technologies and funding to states to help providers not eligible for Medicare/Medicaid payments.
  4. Privacy and security. ONC will appoint a privacy officer
  5. Public health and disease surveillance

The HIT Standards Committee also met on May 15. Whereas the Policy committee’s role is to define what standards are needed and how those standards will be implemented, the Standards Committee will actually cover certification criteria and specifications for information exchange and use of health information. The committee’s “8 guiding principles”:

  • Technologies that protect the privacy of health information
  • A nationwide health information technology infrastructure
  • The utilization of a certified electronic record for each person in the US by 2014
  • Technologies that support accounting of disclosures made by a covered entity
  • The use of electronic records to improve quality
  • Technologies that enable identifiable health information to be rendered unusable/unreadable
  • Demographic data collection including race, ethnicity, primary language, and gender
  • Technologies that address the needs of children and other vulnerable populations

Dr. John Halamka is the vice-chair of the HIT Standards Committee and posted an excellent summary of the meeting in his blog post: The First Meeting of the HIT Standards Committee.

Official HHS communication of committee posts is below.

——————————————————————————-

FOR IMMEDIATE RELEASE
Contact:  HHS Press Office
Friday, May 8, 2009
(202) 690-6343

HHS Announces Members of Committees That Will Advise on Implementation of Health IT Policy and Standards Committees Will Meet Next Week

The Department of Health and Human Services today announced the appointment of three members to the Health Information Technology (HIT) Policy Committee as well as members of the HIT Standards Committee. The two new federal advisory committees were established by the American Recovery & Reinvestment Act of 2009. The first meeting of the Health IT Policy Committee will be held on Monday, May 11 in Washington, D. C.

“The Policy and Standards committees bring together a wide diversity of key stakeholders to help guide the advancement of health IT as an integral part of health reform,” stated Dr. David Blumenthal, National Coordinator for Health Information Technology at HHS and Chairman of the Policy Committee.  “It is an honor to lead one of these committees, and I am confident that these committees will provide valuable insight to help develop important health IT policy in the next few years.”

The HIT Policy Committee will make recommendations to the National Coordinator for Health Information Technology on a policy framework for the development and adoption of a nationwide interoperable health information infrastructure, including standards for the secure and private exchange of patient medical information.

The HHS appointees to the Policy Committee are:

David Blumenthal, MD, MPP,
National Coordinator for Health Information Technology, U.S. Department of Health and Human Services.

Michael J. Klag, MD, MPH
Dean, Johns Hopkins Bloomberg School of Public Health.

Deven C. McGraw, JD, MPH, Director
Health Privacy Project, Center for Democracy & Technology.

An additional 13 members were appointed by the Acting Comptroller General of the United States, and four members appointed by the Majority and Minority Leaders of the Senate and the Speaker and Minority Leader of the House of Representatives. A complete list of the Policy Committee members and information about the May 11th meeting can be found at http://healthit.hhs.gov/. The Presidential appointments from relevant federal agencies are expected to be announced prior to the HIT Policy Committee’s second meeting in June.

In addition, appointments were made to the HIT Standards Committee, also a federal advisory body, which is charged with making recommendations to the National Coordinator on standards, implementation specifications, and certification criteria for the electronic exchange and use of health information.  The first meeting of this committee is scheduled for Friday, May 15, 2009.

Members appointed by HHS are:

Jonathan Perlin, MD, Chair
Healthcare Corporation of America

John Halamka, MD. Co-Chair
Harvard Medical School

Dixie Baker, PhD
Science Applications International Corporation

Anne Castro
BlueCross BlueShield of South Carolina

Christopher Chute, MD
Mayo Clinic College of Medicine

Janet Corrigan, PhD
National Quality Forum

John Derr, R.Ph.
Golden Living, LLC

Linda Dillman
Wal-Mart Stores, Inc.

James Ferguson
Kaiser Permanente

Steven Findlay, MPH
Consumers Union

Douglas Fridsma, MD, PhD
Arizona Biomedical Collaborataive 1

C. Martin Harris, MD, MBA
Cleveland Clinic Foundation

Stanley M. Huff, MD
Intermountain Healthcare

Kevin Hutchinson
Prematics, Inc.

Elizabeth O. Johnson, RN
Tenet Health

John Klimek, R.Ph.
National Council for Prescription Drug Programs

David McCallie, Jr., MD
Cerner Corporation

Judy Murphy, RN
Aurora Health Care

J. Marc Overhage, MD, PhD
Regenstrief Institute

Gina Perez, MPA
Delaware Health Information Network

Wes Rishel
Gartner, Inc.

Sharon Terry, MA
Genetic Alliance

James Walker, MD
Geisinger Health System

Representatives from relevant federal agencies will be named separately.
For more information about these committees, meeting dates and preliminary agendas please visit http://healthit.hhs.gov

HIT/Privacy Timeline from Stimulus Bill

From Dr. John Halamka, CIO of CareGroup Health System in Boston, MA (original post here: The Timeline for ARRA Privacy Provisions), a bookmarked PDF-version of the American Recovery & Reinvestment Act that highlights sections relevant to HIT & privacy: http://ecommons.med.harvard.edu/ec_res/nt/A3B4A28D-987B-4271-B003-5A877B4F4E38/arrabookmarks.pdf

The rough timeline is below:

Upon enactment (February 16, 2009)

  • Application of new tiered civil penalties based on the nature of HIPAA violations, up to $50,000 per violation and an annual maximum of $1.5 million (Section 13410)
  • Enforcement by State Attorney Generals for offenses occurring post enactment (Section 13410e)

Within 45 days of enactment (April 3, 2009)

  • Appointment of HIT Policy Committee members (Section 3002b)

Within 60 days of enactment (April 18, 2009)

  • HHS Secretary will issue guidance on methodologies and technologies that render information unreadable (Section 13402)

Within 180 ays of enactment (August 16, 2009)

  • HHS and the Federal Trade Commission will promulgate interim final regulations on notification of breaches. The FTC rules will apply to breach notification by PHRs that are not covered by HIPAA or Business Associate agreements (Section 13402, 13407)

By December 31, 2009

  • HHS must adopt through rulemaking the initial prioritized set of standards which should include the accounting for disclosures (Section 3002b)

Due within one year post enactment (February 17, 2010)

  • The Secretary will appoint a Chief Privacy Officer (Section 3001)
  • The Office of Civil Rights and HHS will launch an education initiative to improve public transparency on the use of health information (Section 13403)
  • The Government Accountability Office will report on best practices for disclosures for treatment and use of electronic informed consent (Section 13424)
  • HHS will report on and provide guidance on de-identification (section 13424c)
  • Covered entities must enter into Business Associate Agreements with PHRs, HIEs, and other services that handle projected health information (Section 13405e)
  • HHS will issue rules on opting out of fundraising solicitations (Section 13406)
  • HHS will report on guidance on the effective technical safeguards for carrying out the HIPAA security rule (Section 13401c)
  • HHS and the Federal Trade Commission will report on privacy and security requirements for PHR vendors and applications

One year post enactment (February 17, 2010)

  • HHS and the Office of Civil Rights clarify application of criminal penalties for non-covered entities (Section 13409)
  • HHS to issue rules on which entities are required to be business associates (Section 13401)
  • Right to restrict disclosures to health plans for services paid for out of pocket (Section 13405a)
  • HHS Secretary required to conduct periodic audits of entities covered by HIPAA (Section 13411)
  • Right of electronic access of records by patients takes effect (Section 13405e)

Within 18 months of enactment (August 17, 2010)

  • HHS guidance on minimum necessary data (Section 13405c)
  • Regulations regarding sale of data prohibition which take effect 6 months post promulgation (Section 13405a)

By 2011

  • Initial deadline for complying with new accounting and disclosure rules for information kept in EHRs acquired after January 1, 2009 (Section 13405c)

24 months post enactment (February 17, 2011)

  • Clarification of ability to pursue civil penalties when criminal penalties are not pursued (Section 13405)

By 2012

  • Regulations for methodology for distributing penalties or settlement money to harmed individuals (Section 13410)

By 2013

  • Extended deadline for complying with new accounting and disclosure rules for information kept in EHRs acquired after January 1, 2009 (Section 13405c)

By 2014

  • GAO will report on the impact of ARRA (Section 13424)
  • Initial deadline for complying with new accounting and disclosure rules for information kept in EHRs acquired before January 1, 2009 (Section 13405c)

By 2016

  • Extended deadline for complying with new accounting and disclosure rules for information kept in EHRs acquired before January 1, 2009 (Section 13405c)

US Behind in HIT Spending – Stimulus Insufficient

Despite the fact that the US spends nearly twice as much on healthcare as any other country, the US is as much as 12 years behind other OECD countries in health information technology investment. See the Commonwealth Fund’s entry on Health Care Spending and Use of Information Technology in OECD Countries.

hit-efforts-in-six-countries

The American Recovery & Reinvestment Act of 2009–the Stimulus Package–apportions $19 billion for investment into the HIT infrastructure in the US. As much as $3 billion goes to the Office of the National Coordinator (which will now be codified) and other standards creating bodies. The remaining amount will be given to providers primarily through increased Medicare reimbursement. If divided evenly, each hospital would receive approximately $11 million. A substantial sum, but hardly close to the $200 million over 3 years required in a typical implementation at a 300+ bed hospital. Only 10% of hospitals currently have full electronic health records. Another 20-30% are in planning or implementation stages. The stimulus may encourage more providers to enter the planning stages and will help along those already in the process during difficult economic times. But $11 million for the remaining 60-70% is entirely insufficient.

Evidence shows that the only providers that stand to get a return on investment in HIT are large network providers with geographically distributed practices, such as Kaiser or the VA. This makes sense, as the administrative cost of sharing information is high. The early adopters (the 10%) consist of these large networks and a few providers with well-funded, forward-thinking CIOs. The 20-30% currently planning hope to break even at best and justify the investment by improved patient care (especially through CPOE). The rest are mostly too small to realize significant cost savings and will likely need much more than $11 million to break even.