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How One HIE Tackled the Challenge of Improving Patient Record Matching

August 17, 2016
by Heather Landi
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SDHC, a not-for-profit HIE, officially evolved from the San Diego Beacon Community, and now connects 25 different clinics and health systems across the San Diego region.
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Six years ago, San Diego Health Connect (SDHC) began as a local health information technology project and has since grown into a regional health information exchange (HIE) that connects San Diego’s three largest health systems and enables the exchange of 3.2 million patients’ electronic medical records (EMRs).

As the HIE has expanded, SDHC leaders have worked to improve the exchange and the quality of the data that’s available through it. That work has come with its share of challenges, and through the use of third-party data quality and data integration technology tools, SDHC has been able to overcome many of these hurdles.

SDHC, a not-for-profit HIE, officially evolved from the San Diego Beacon Community, the largest of the 17 Beacon Community projects that received a total of $250 million in three-year grants from the Health and Human Services Office of the National Coordinator for Health Information Technology (ONC). In April 2010, UC San Diego received a $15.3 million Beacon cooperative agreement from ONC. The San Diego Beacon Community was tasked with building and strengthening local health information technology infrastructure and implementing new approaches for making measurable improvements in the cost and quality of healthcare.

The regional health information exchange was one of the initial projects of that Beacon community, and in 2013, UC San Diego transferred operational and oversight responsibility for the HIE to SDHC. The Beacon grant gave San Diego healthcare organizations a jumpstart for implementing HIE to improve healthcare quality and efficiency, and according to SDHC executive director Dan Chavez, the HIE is further ahead than most HIEs in its development and technological sophistication.

Dan Chavez

The community-wide HIE now  enables the exchange of electronic medical records for 3.2 million patients between 25 different clinics and hospital systems throughout San Diego and Imperial counties, including UC-San Diego Medical Center, Scripps Health, Sharp HealthCare, Kaiser Permanente, Rady Children’s Hospital-San Diego, the U.S. Department of Veteran Services and the County of San Diego Health and Human Services. San Diego is the fifth most populous county in the United States, with three military facilities, 18 federally recognized Indian reservations, 19 acute care hospitals, four non-acute, rehab hospitals, 115 clinics and 9,000 physicians.

SDHC provides healthcare providers with medical records exchange, direct secure messaging and alerts, public health reporting capabilities as well as the EMS Hub, which transmits pre-hospital data from EMS vehicles en route to the hospital.

Throughout the SDHC’s roll out and adoption, the organization’s leaders have faced a significant obstacle that is a common challenge for HIEs—accurate patient identity matching. SDHC is a federated model and does not house medical records, as the clinical data is housed at each of the participating facilities. The HIE uses a master patient index (MPI) as a record locator service to manage the identifying information for 3.2 million people across the San Diego region and to ensure that the records belong to the correct patients. The HIE facilitates 7.5 million transactions a month between the 25 provider institutions.

Using the matching capabilities in the MPI tool, when patient records do not match they end up in an “exception queue.” Due to stringent matching criteria, SDHC’s MPI matching algorithm had, by 2015, excluded 187,000 patient records because of unresolved patient identification, Chavez says. And, each new provider joining SDHC led to more backlog, due to data quality and differences in governance, he says. The HIE also was using a manual data stewardship process. So, the task of addressing the backlog of 187,000 records in the “exception queue” would take eight years for two full-time employees.

Accurate patient identification is not only a data management and data quality issue, it’s also a patient safety issue. As reported earlier this year by Healthcare Informatics, ECRI Institute ranked patient identification errors as second on its list of top 10 patient safety concerns. ECRI Institute analysts discovered that patient identification errors "were not only frequent, but serious.”

In order to develop a better patient matching progress, SDHC convened a working group of 41 HIE members from 13 organizations. As a result of that working group’s efforts, in May 2015, SDHC began a pilot project with health IT startup Verato, a Software-as-a-Service provider that developed a cloud-based patient matching solution.

Accurately identifying people, essentially matching the right record to the right record, is a pervasive problem in healthcare as well as other industries like retail, according to Brent Williams, founder and chief technology officer at Verato.

The problem, Williams says, is that identity data is a collection of attributes which often change over time. For instance, names, addresses, phone numbers, email and marital status can change over time. In addition, there’s also ambiguity with names, such as hyphenated names, nicknames and twins. There can also be spelling errors and homonym errors and data governance issues, such as formatting and data quality. So, one person can be represented by old, incorrect or incomplete data, resulting in different identities across provider systems. The matching capabilities in MPI tools typically result in a 70 percent match rate given typical error rates in identity data, Williams says, and the other 30 percent of unmatched identities must be manually resolved, as the case at SDHC. Or, the identities are falsely categorized as non-matches which prevents the information from reaching a patient’s care providers during the care visit.

Verato launched its technology in 2012 to try to solve this problem and the core of the technology is a specially programmed reference database, Carbon, that’s provided as a service to hospitals and government agencies to reconcile identities faster.

During the pilot project, SDHC employed Verato’s technology and was able to resolve 75 percent of the 187,000 mismatched records, thereby eliminating 75 percent of the manual effort that would have been required to match the 187,000 records in the exception queue. Of the 45,000 in the exception queue not matched, 95 percent were pediatrics patients. In addition, during the pilot project, SDHC was able to boost its patient match rates as the technology platform identified an additional 126,000 patient matches that the MPI algorithms had originally missed. In total, SDHC increased the number of patient record matches in its MPI by 110 percent, Williams says.

Of new matches that were identified during the pilot, 20 percent had at least one critical error, either conflicting birthdates, a difference in last name or a different address. According to Williams, the software utilizes a referential matching engine. “MPI matching, or probabilistic matching, can’t see through different or bad identity data. Referential matching works despite different or bad identify data,” he says.

Due to the success of the pilot program, SDHC has implemented the technology platform, and according to Chavez, it will be used to augment the MPI database through an automated data management feature aimed at detecting matches missed by the standard MPI process.

The combination of high quality data and stringent patient matching standards enables SDHC member providers to have access to a complete picture of a patient’s health information, Chavez says.

“SDHC’s mission is to facilitate the exchange of medical records throughout our region so doctors can provide better patient care, decrease the number of duplicate tests and procedures, and decrease costs,” he says. “Foundational to exchanging records is the ability to match various records that belong to the same patient, and this technology can increase our match rates without sacrificing SDHC’s stringent data governance standards.”

Chavez says the value of the HIE to San Diego health systems includes improving care coordination, improving Meaningful Use compliance and reducing preventable admissions. For physicians, the HIE helps to strengthen provider engagement and reduce costs, and for community clinics, it improves access to relevant patient information and speeds up the referral process. At the same time, the HIE also enables automated real-time public health reporting.

Moving forward, SDHC continues to expand its services and capabilities. California Healthcare Foundation recently awarded SDHC a grant to pilot, implement and maintain a Physician Orders for Life-Sustaining Treatment (POLST) eRegistry in San Diego. San Diego will be the pilot geography to work with a group of diverse local providers to make the POLST forms accessible by a wide variety of disparate organizations and functions, Chavez says. POLST is a standardized medical order form that indicates which specific treatments, such as a ventilator or feeding tube, a seriously ill patient does or does not want. Unlike a health care directive, a POLST form is signed by the patient and physician and is intended to serve as medical orders that move with the patient across settings of care. 




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Vermont HIE Eyes Switch to Opt-Out Consent Model

January 23, 2019
by David Raths, Contributing Editor
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Opt-in model seen as administratively burdensome

Despite years of development work on the Vermont Health Information Exchange (VHIE), in 2017 the health records of only 19 percent of Vermonters were accessible in the VHIE. One potential obstacle identified is the HIE’s opt-in consent policy, which is now under review.

In 2017, the Legislature required the state to conduct a comprehensive review of the VHIE, which is run by the nonprofit Vermont Information Technology Leaders (VITL). The state engaged HealthTech Solutions (HTS) to conduct an evaluation. Among the issues it studied was whether the opt-in consent policy is too administratively burdensome and whether individual consent should be on an opt-in or opt-out basis.

“Opt-in” presumes that consent is withheld unless stated otherwise. “Opt-out” presumes that consent is granted unless stated otherwise.

HTS’s survey of other states revealed that the vast majority of states have opt-out consent models (only three states besides Vermont use opt-in). All nine “Successful HIE Models” identified by HTS in its report to the state used some form of opt-out.

A majority of Vermont stakeholders surveyed by the researchers support change to opt-out. However, some stakeholders opposing change voiced concern that privacy and autonomy may be degraded by opt-out. The report notes that there is no Vermont statute that governs the issue of whether or what kind of patient consent may be required.

The report’s preliminary recommendation is that the consent policy should be changed to provide for an opt-out consent model, while taking into account the perspectives of those who remain concerned by making it easy to opt-out and implementing the change with care to ensure that all who want out, are out.

A Vermont publication called VTDigger published an account of an early January meeting of the Green Mountain Care Board, which works to improve health care quality and moderate cost for Vermonters by regulation, innovation and evaluation. It quoted Mike Smith, who took over as VITL’s top administrator last year. He noted that the organization has boosted the portion of Vermonters who have records in the exchange to nearly 39 percent since 2017. But he said that progress will “plateau” without a change in the way Vermonters agree or don’t agree to participate in the exchange.

“Currently, medical providers can only access a minority of Vermonters’ records,” Smith is quoted as saying. “Changing the policy would mean that they’d be able to access a majority of patient records in Vermont, with all the safeguards that are in place.”

VTDigger noted that several care board members expressed general support for the policy change, but the board took no action, and Department of Vermont Health Access officials said they would incorporate feedback from the meeting into their final report to the Legislature this month.

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Manifest MedEx CEO on the Path Forward for HIEs, and Connecting Healthcare in California

January 14, 2019
by Heather Landi, Associate Editor
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Williams projects that every hospital and health system in the state will be connected to an HIE in the next 18 months
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In the past two years, Manifest MedEx (MX), now the largest nonprofit health data exchange in California, has rapidly grown after being formed as the result of a merger between San Francisco-based California Integrated Data Exchange (Cal INDEX) and the San Bernardino-based Inland Empire Health Information Exchange (IEHIE) back in 2017.

With offices in Northern and Southern California, the HIE facilitates the secure exchange of 11 million patient claims records and 5 million patient clinical records, and is on a mission to connect healthcare in California.

At the time of Manifest MedEx’s launch in 2017, and as reported by Healthcare Innovation Editor-in-Chief Mark Hagland, the merger combined the 11.7 million claims records from Cal INDEX founding members Blue Shield of California and Anthem Blue Cross with the 5 million clinical patient records of IEHIE and its 150 participating partners.

At the same time, it was announced that Claudia Williams, former White House technology senior advisor, was tapped to lead the new organization as CEO. At the time of the announcement, Mark Savage, chairman of the Cal INDEX Board of Directors and director of health information technology policy and programs for the National Partnership for Women & Families, said of Williams: “Claudia is the ideal candidate to lead this new entity. She is a strategic and transformational leader with national experience managing and scaling health information exchanges. With Claudia, California’s statewide HIE gets the rare combination of breadth and depth.”

The HIE has grown, and the network now has participation from more than 200 healthcare organizations, including more than 80 California hospitals, and five of the largest health plans in the state—including Blue Shield of California and Anthem Blue Cross of California. Just in the past year, Manifest MedEx has added San Diego-based Scripps Health, Stanford Health Care and AHMC Healthcare, a network of seven affiliated hospitals in the greater San Gabriel Valley, to its network, as well as Heritage California and Hill Physicians, two of the largest medical groups in the state.

In an interview with Healthcare Innovation Managing Editor Rajiv Leventhal back in March 2018, Chris Jaeger, M.D., vice president of accountable care innovation and clinical transformation at Blue Shield of California, called Manifest MedEx “a key foundational effort” leading to value-based care. “Creating an infrastructure that can be this HIE 2.0, if you will, [could be] the foundation for value-based care that can support population health efforts and drill down to the personal level as patients migrate through their life. That’s critically important,” Jaeger said.

In another recent development, the California Department of Health Care Services secured $45 million in federal funding and $5 million in state funding to invest in HIEs throughout the state and the funding will be used to help onboard providers to California information exchanges.

Recently, Williams spoke with Healthcare Innovation Associate Editor Heather Landi about the HIE’s growth in the past two years, the organization’s strategy to provide value to network participants and the path forward for HIEs.

How would characterize the growth and progress of the HIE in the past two years?

We’ve seen incredible progress on several fronts; the first is delivering valuable products and services to our participants that will help them succeed in value-based care. Over the past year we have transitioned to a new modular technology platform, integrating best of breed components from InterSystems, NextGate, Audacious Inquiry and others. We are delivering three value-added services—one is real-time notification alerts (MX Notify); second, the longitudinal health record of patients (MX Access), and in Q1 2019 we will include not just clinical data but also claims data; and third, this quarter we will be rolling out an analytics platform (MX Analyze) that will provide a tool to risk stratify patients and identify care gaps. That delivery of robust, scalable products on a solid technology base has also led to real success in growing our network. We’ve added Stanford, Scripps, Heritage, and AHMC. Those systems are leaning heavily into new forms of care and population health, and I think getting a robust stream of data, reflecting clinical as well as claims data, is incredibly appealing to them.

Claudia Williams

As a result, the network is driving measurable results reducing readmissions and ER usage. As one example, we are working with a large ACO in the Inland Empire, and they have posted measurable changes in seven-day visits after discharge, readmissions reductions, and ED visits, using our HIE services. This is an example of MX products supporting a concrete, effective workflow that succeeds in reducing ED, reducing readmissions and getting patients into care more quickly once they get back in their homes.

In building out your organization’s value proposition, what is Manifest MedEx’s strategy?

We are keeping our attention very trained on the health systems, medical groups and plans that are building out new value-based models because there is a lot of demand for information sharing in those models. Within that, we’ve evolved to focus on who the most intense users of HIEs are going to be, and in our view, it’s the senior VP of population health. On a more daily basis, it’s the care managers, care coordinators and discharge planners who are trying to build connective tissue between their clinical entity and others that are caring for that same patient. I think the average clinician in practice finds value in what we do, but it’s really in those intersections, where a group of people are trying to be accountable for that patient population where we see the deepest and most valuable use.

In March 2018, Blue Shield of California announced it would require network providers to participate in the Manifest MedEx network. What levers do you see health plans using to expand health information sharing?

I’ll cite an example in the Inland Empire, we work closely with Inland Empire Health Plan, which is a leading California health plan and the biggest Medi-Cal health plan in that area. As they look at the key challenges that they are having internally, which includes reducing readmissions, increasing care coordination, increasing their HEDIS scores, as well as doing things like improving the prior authorization experience for both patients and providers, they realize that the data that MedEx is providing is incredible and crucial to that. And, we all recognize that it’s a lift to connect to an HIE, it takes time and energy of your technology team, and your project management team, and they have many tech priorities that they are trying to juggle at once. What Inland Empire Health Plan did was they said, our pay for performance program for hospitals, we’re going to portion a piece of that to incentivizing hospitals to connect to MedEx. [Editor’s note: Inland Empire Health Plan pledged $6 million in incentives to regional hospitals that participate with MedEx and use its services in 2018.] There are actual data sharing requirements built into that incentive program, and as each hospital hooks up their system with ours and sends various types of data and results, such as ADT alerts (admit, discharge, transfer), they are eligible for a substantial financial incentive to do that. We found that helps to move the project up the list. And that’s my hope for the approach the state will take in its $50 million effort, which is really to recognize the effort and time taken, especially by hospitals, and make sure that there is money on the table for them to connect to HIEs.

I’m excited by the kind of collaboration and partnerships we’re seeing, bringing together not just the clinical side of things, the providers, but also the health plans. We’re seeing those partnerships really gaining steam across the country for successful HIEs. And for me, it’s not just a question of what health plans can get from an HIE, but frankly what they’ll also give. In our case, they are providing substantial financial support and also claims data. Many HIEs have struggled with bringing in ambulatory data into the network, because it’s very time consuming and expensive to work with every single provider. So, when we have claims data that provides information—what were all the visits the patient had, what were all the hospital encounters the patient had, what medications are they on, what’s the full list of diagnoses for that patient—that provides a critical complement to the hospital clinical data that HIEs can get. The health plans being at the table, contributing financially and also contributing in terms of data, is going to be a real marker of our success and other HIEs’ success moving forward.

What makes California a unique market when it comes to HIE and interoperability efforts?

I actually think that we’re behind. It’s not surprising, given the size and the complexity of this market, but we estimate about half of all hospitals in the state participate in HIE efforts, and that compares to Maryland, where every single hospital, except the NIH clinical center, is a participant in their state effort, CRISP (the Chesapeake Regional Information System for our Patients, a regional HIE). I’m excited that the funding from the state will really set up a process and an expectation that every single hospital should come on board in 2019. Whether it’s with us or another HIE effort.

Let’s shift to policy and strategy, as you previously served as White House technology senior advisor. What does your previous experience bring to your current role at Manifest MedEx?

We really laid the policy track and the expectation track for technology to deliver on its promise of better care at lower cost. The work that I did that really dug into EHR (electronic health record) adoption, HIE programs across the country, funding, policy expectations, were the precursor tracks that were laid for our success in California.

I think one specific way my background really helped me is that I led the $500 million grant program that was aiming to accelerate HIE efforts in every single state and territory across the country. I had a front row seat to see what works and what doesn’t work. And what I saw that works is a very keen focus on delivering value to participants, and that comes from both the richness and breadth of the data network, and it also comes from a very keen eye on who should be using the services and to do what.

Also, what we’re seeing across the country is that it’s expensive and it takes a lot of expertise to effectively run the infrastructure that I’m talking about, and make it be as dependable and high quality as we all want. We’re seeing a trend towards merging of HIEs or one infrastructure supporting many communities. Maryland is one example, as that organization is now supporting HIE efforts in West Virginia, and D.C. and Virginia. I think to do this right, you need quite a sizeable, robust organization. The model we use is to share a common infrastructure across many communities but have local health information organizations, local HIOs that rally the local community, represent local needs and support participants in that community. We have three of those organizations in three communities across the state.

What are your thoughts on federal policy efforts, such as TEFCA (ONC’s Trusted Exchange Framework and Common Agreement), to spur information exchange?

We’re seeing that the federal government can play a massive role in accelerating the adoption and use of health information exchange, and TEFCA is one way to do that. But recently, CMS (the Centers for Medicare & Medicaid Services) released an RFI (request for information) asking for comment and recommendations on what could be done to accelerate information sharing, and we joined together with 50 organizations to submit comments suggesting that every hospital in the nation should be required to let community providers know when a patient leaves their doors. This is a well prescribed and well executed use case across the country; this basic idea that a primary care provider would be alerted, in real time, when their patient is seen and is discharged. There are HIEs and technology companies that can support this effort for every hospital in the nation. We recommended that become a part of Medicare, basically a requirement of participation in the Medicare program. We don’t’ know what will happen; we expect regulations on that matter. We had a great meeting with (CMS Administrator) Seema Verma, she has been making comments suggesting that is an area of interest for her, so we’d like to see efforts that are well prescribed and well adopted just become the expectation for how we deliver good care.

Looking ahead, what will the leadership team at Manifest MedEx be focused on?

I think it’s time that California come into the digital age by accelerating participation in HIEs across the state. I’d like to see MX play a lead role in making sure every hospital and health system is hooked up to us or another HIE. We have a 50 percent gap, so we have a lot of progress to make but I think with the mandate coming from value-based care, the additional funding that will be available through the state and federal government, as well as the kinds of robust, scalable services that we’re offering and that are really in high demand, I think we’ll get there over the next year to 18 months.

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Missouri Health Connection’s CEO Defends HIEs’ Value in a Competitive HIT Landscape

January 8, 2019
by Rajiv Leventhal, Managing Editor
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One HIE leader believes that health information exchanges fill a critical interoperability gap created by large EHR vendors

In Columbia Mo., Missouri Health Connection (MHC)—the state-designated health information exchange (HIE) network—has the motto of “One Connection for a Healthier Missouri,” and the organization’s senior leaders have taken to making that dictum a reality.

MCH was started in 2011 as an executive order by former Governor Jay Nixon as part of the HITECH Act. But once federal funding dried out, as it did for many HIEs across the country, MHC’s strategy needed to shift to remain sustainable in a competitive landscape. The organization hired Angie Bass—previously a health policy research analyst for the Missouri House of Representatives and a project analyst for the Missouri Department of Mental Health—in 2012 as program manager, but Bass quickly rose the ranks to become MHC’s president and CEO.

Under Bass’s leadership, MHC has become one of the nation’s largest health information exchanges, covering a territory of more than 69 thousand square miles and more than 22 million patients in its network. Bass recently spoke with Healthcare Innovation Managing Editor Rajiv Leventhal about MHC’s journey, the biggest challenges that exist today for HIEs, how the organization is providing value for its members, and more. Below are excerpts from that discussion.

Can you give me a brief history of MHC? How was the HIE formed?

We were started in 2011 under the original ARRA/HITECH funding. We organized as a private 501(c)(3), so we used $14 million in federal [funding] to get ourselves off the ground with the initial infrastructure and onboarding [of participants], and we’ve been a self-sustaining organization and member-funded since 2014.

We waver between being the second and third largest HIE in the country based on the size of our master patient index, which is over 22 million patients, as well as based on the sheer geography that we serve. One unique thing about Missouri is that we have several large health systems that are headquartered in the state, but we also have facilities that are outside of the state, spread throughout the Midwest. We have providers in all the states that border Missouri, up to Wisconsin and down to Louisiana. So even though we predominantly serve this state, we do have a Midwestern focus as far as the geography and territory that we do and intend to serve.

We have more than 80 hospitals and hundreds of clinics, and since we have so many integrated delivery networks and health systems, that means we have all of the ambulatory clinics and facilities that go along with them. So, that’s thousands of physicians and even more practitioners that have access to our HIE services, either through an integrated query-based interfacing, our clinical portal, our push-based alerting, or through public health. We have a variety of services, and we have thousands of [participants] who can actively receive real-time information on patient data.

What kind of data is currently being exchanged via your network?

The quality of data is our highest priority. The type of data being exchanged includes everything in ADT [admission, discharge, transfer] feeds [using HL7 standards], as well as in continuity of care documents [CCDs]. And then we have some public health interfacing for meaningful use. From an HIE perspective, we can transact anything.

The limitation is not on our ability to be interoperable between disparate systems, but [rather] the limitation is the vendors being able to export the data out of their own systems, and then allowing the customers they are serving—the healthcare providers—to be interoperable.

For instance, the meaningful use certification around what should be included in a CCD is not the entire patient record; it’s just a subset of data. The meaningful use certified version doesn’t include the critical pieces of information that most every clinician wants, such as discharge summaries, notes, and H&Ps [histories and physicals]—all the things that are very relevant and necessary for good care coordination and transitions of care.

What we have been very focused on in the last 18 months is going back to each of our data contributing participants—so everyone who is giving us an ADT and everyone who is sending us CCDs—and expanding those interfaces so that we are getting the most robust data. This [involves] going back and working with them to see about how we can extract the most data out, such as going back to a raw ADT feed and adding in those notes and other content that’s necessary. Sometimes that’s challenging, not necessarily because it’s the healthcare providers pushing back, but the vendors who are pushing back.

This speaks to the HIE’s value proposition. Can you discuss that further?

One of the things we always stress is the niche that an HIE serves is doing the data normalization of disparate systems. So, being able to extract from one EHR [electronic health record] and normalize the data in a way that makes sense for another EHR vendor to ingest. Inherently, the EHR vendors are not incentivized to do that with each other on their own, though through CommonWell and Carequality, that is what [those associated vendors] are portraying as the goal of that relationship. But it isn’t happening in the real world; it’s not happening form urban to rural, from acute to ambulatory, or between behavioral health and post-acute care. That’s why an HIE is necessary.

Meaningful use [regulations and incentives] left out post-acute and behavioral health providers, meaning none of the EHR vendors [in that space] need to be meaningful use-certified, so they are playing catch-up. That has been devastating to the industry from an interoperability perspective. Where are the vendors stepping up to help serve [these providers]? But the HIEs are; they are helping these providers with transitions of care as they move onto EHR systems.

HIEs are, for the most part, vendor agnostic, not-for-profit vendors that are truly doing a community good and service for providers that need to be interoperable because not everyone will be on an Epic or Cerner EHR. There are going to be those specialty and rural practices that need all the help they can get from a health IT perspective, and that’s what an HIE is there for: to be the intermediary for state agencies to interact with HIEs, and also with the federal government.  

We are very focused at the community level, while SHIEC [the Strategic Health Information Exchange Collaborative] and other organizations are doing great work in trying to work with Congress and the state governments to bring awareness about the need for HIEs and the value they serve for the public and private sectors. We are competing against those large EHR vendors that are aligning for their own self-interest needs. And that’s kind of how the game is played, but we aren’t going anywhere. I am confident about that.

How is MHC handling issues such as patient consent?

Here in Missouri, we don’t have any state mandates on the books regarding actual patient consent for HIEs one way or the other, but we have chosen to be an “opt-in” model based on certain laws that are on the books regarding specially protected information that goes above and beyond 42 CFR Part 2 data and other HIPAA requirements. So we choose to be super conservative when it comes to patient consent. But it does need to be addressed at a federal level. We need to bring technology and consent into parity. We also need to make sure that wherever that clinician lands, wherever parity exists, that the vendors can support it.

How are federal policies such as TEFCA (ONC’s Trusted Exchange Framework and Common Agreement) playing a role in your operations?

The first draft of TEFCA did not take into consideration these vendor requirement pieces. It’s all the HIEs’ responsibility to make sure they can transact every specific piece of data, but there is no teeth in requiring the EHR vendors to be able to send that data out to an HIE, without charging their customers an obscene amount of money for an additional interface cost. So I think the intention of TEFCA is good to increase interoperability on a national scope, but I think the framework on the initial release was flawed.


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