3 rd Meeting Date: July 8, 2010 Time: 8:30 am – 11:00 am Location: NC Hospital Association 2400...

3rd MeetingDate: July 8, 2010

Time: 8:30 am – 11:00 amLocation: NC Hospital Association

2400 Weston Parkway, Cary, NCDial-in: 1-866-922-3257; Participant Code 654

032 36#

North Carolina Health Information Exchange

Governance Workgroup

2Discussion Document – Not for Distribution

Agenda

Topic Leads Time

Roll Call and Housekeeping

Meeting Objectives and Timeline Review

Co-Chairs 8:30 – 8:45

Update on other Workgroup Discussions Co-Chairs & Manatt

8:45 – 8:55

Review of June 23, 2010 Governance Workgroup Key Decisions

Co-Chairs 8:55 – 9:05

Governing Participation in the Statewide HIE Co-Chairs & Manatt

9:05 – 10:35

Governance Domain Section of NC HIE Operational Plan

Manatt 10:35 – 10:45

Next Steps & Open Public Comment Co-Chairs 10:45 – 11:00

3Discussion Document – Not for Distribution 3

New NC Health IT Website Launched

www.healthit.nc.gov


Meeting Objectives

• To confirm decisions from June 23 Workgroup meeting for recommendation to the board.

• To develop recommendations regarding governance rules for participation in the statewide HIE.


Stakeholder

Outreach

Operational PlanStrategic Plan

NC Statewide HIE Cooperative Agreement Timeline

State HIE

Grant App.

Letter of Intent Submitted

Sept Oct Nov 09 May 2010 Jun Jul Aug Sep

Strategic Plan Submitted to HHS

Biweekly+ Workgroup Meetings with Monthly Board Meetings

• Convene Advisory Board & Workgroups

• Draft Operational Plan

• Publish Draft Operational Plan for Review

• Engage and educate stakeholders

Submit Operational Plan to HHS

Workgroups Formed & Begin Meeting

Publish Draft Operational Plan for Review/ Comment

Funding Announcemen

t

LaunchPhase 2

NC HIE

Formed


Drafting of Operation

al Plan

Operational Plan Consensus Recommendations

NC Statewide HIE Operational Plan Development Timeline

Workgroups formed

May 2010 June July Aug Sept

May 14 – initial NC HIE Board Meeting

• Compile NC HIE Board & Workgroup recommendations and decisions

• Draft Operational Plan – iterative process with WG review

• Publish Draft Operational Plan for Public Review

Aug. 31: Submit Operational Plan

to HHS

Governance WG: Confirm governance model, advise on scope of governance, craft recommendations on bylaws and board structure for new entity; develop recommendation for consumer engagement plan approach

Clinical/Technical WG: Recommendations on technical architecture approach for statewide HE, begin prioritization of core and value-added services, begin landscape assessment

Legal/Policy WG: Conduct legal scan for NC laws related to consent for treatment purposes; draft legal principles; conduct legal scan for NC laws related to health information data security; develop recommendations on approach to 4As; develop initial consent approach recommendation under existing lawFinance WG: Develop financial model assumptions; data collection to inform financial models.

Master project planning, develop WG charters and workplans; stakeholder meetings, Legal/Policy WG meetings

Governance WG: Participation policies and enforcement mechanisms for the statewide HIE; develop recommendations on roles of State in public/private partnership; processes for coordination with other ARRA funded programs in the state

Clinical/Technical WG: Development of clinical and business use cases, prioritization for core and value-added services, technical approach

Legal/Policy WG: Finalize consent approach recommendation under existing law; review emerging consent policies in neighboring states and identify barriers; develop recommendations for changes to current law to support data exchange; develop recommendations on breach policy principles and role based access principles; develop security recommendations beyond access.Finance WG: Develop 2-3 financial models based on modeling assumptions and develop process for sustainability planning.

Updates from Other Workgroups


Technical/Clinical Operations Workgroup – June 23, 2010 Meeting

Discussion • Statewide HIE Approaches• Clinical Functions• HIE Service Analysis

Key Decisions

• The Workgroup advanced a recommendation to pursue a Hosted, Shared Services Approach with the following considerations:

o Ensure the approach aligns with the agreed-upon clinical and technical principles.o Conduct a thorough analysis of each service and the NC HIE landscape to ascertain 1) at what level a HIE service should occur and 2) the value of various services to particular stakeholder groups.

This analysis should reveal which services are best left to the local and regional levels and which services would be ideally hosted for utilization statewide, as well as demonstrate the value proposition for various stakeholder groups for each potential statewide service.

• The Workgroup agreed to define clinical functions then explain how the technical components for HIE support the clinical functions. • The Workgroup agreed to develop an implementation sequence by assessing and prioritizing each HIE service along its clinical and operational dimensions. • The Workgroup recommended that the expanded list of candidate HIE services consider meaningful use implications.


Finance Workgroup - June 23, 2010 Meeting

Discussion •Review HIE financial modeling approach and come to consensus on key assumptions/drivers

•Discuss characteristics specific to North Carolina that may impact financial modeling

Key Decisions

The Workgroup approved the following key assumptions that will be built into the financial modeling approach: o Governance and operations cost inputs will focus on the State-level HIE and not the governance and operations costs of any Regional Health Information Organizations (RHIOs) or local HIEs.

• This assumption is subject to revision based on the decisions made by the other Workgroups, particularly the Governance and Technical/Clinical Operations Workgroups regarding the recommended model for the statewide HIE structure and related role of regional/local HIEs.

o Costs for participants’ connectivity to the HIE will be based on adoption curves by participant type. o The financial model will exclude participant costs to implement new EHRs or remediate existing EHRs and clinical information systems (CIS), with the exception of Medicaid system implementation/remediation required for HIE and the estimated cost for portion of providers that will connect to the HIE using an HIE-provided EHR Lite. o The financial model will identify additional value-added products/services that can help drive revenue, and will include potential added costs for incremental development and delivery.


Legal/Policy Workgroup – July 2, 2010 Meeting

Discussion Develop recommendation on Opt-In vs. Opt-Out patient consent framework that assumes the following:

The framework is compliant with current NC law (i.e., Pathway 1) The framework addresses only disclosure of clinical data for treatment purposes

Key Decisions

For Pathway 1 (assuming no change to the existing law), The Policy Subcommittee recommended that the NC HIE adopt an Opt-In Consent Policy for disclosure of clinical data for treatment purposes

The Subcommittee weighed the following considerations:

An Opt-In Model is preferable to a Mixed Model because it does not require that information be filtered out of the patient record.

An Opt-In Model is preferable to a Mixed Model because it allows for one consent policy for all participants, thereby streamlining the consent process and reducing confusion.

An Opt-In Model has the disadvantage of potentially restricting the free flow of patient information to the detriment of patient care.

The full Workgroup stipulated that further discussion is needed around whether the consent is “all or none” and if some data types should be excluded from the exchange to protect privacy.

Review of Key Decisions from June 23 Governance Workgroup Meeting


Governance Workgroup - June 23, 2010 Meeting

Discussion • NC HIE Strategic Plan Verification• Recommendations on Bylaws• Components of Consumer Communications and Engagement Plan

Key Decisions

• Workgroup confirmed, modified, or rejected key governance decisions included in the NC HIE Strategic Plan.

• Workgroup recommended that the following requirements be written into the NC HIE bylaws:

o The Board must be composed of 15-21 members, not including ex-officio members. o Board members will be selected based on merit-based characteristics, but at all times the following groups must be represented on the Board: Hospital/Health Systems, Providers, Consumers, Employers, and Payers.o Board members will serve three-year terms, terms will be staggered, and no member may serve more than two consecutive terms.o The Board will have the authority to establish advisory groups/committees as it deems necessary. o The Board will comply with 501(c)(3) requirements, including those related to conflicts of interest policy and transparency.

The Board should establish a standing Consumer Advisory Council, tasked with developing a consumer engagement plan among other activities.

The current Workgroups (Governance, Finance, Clinical/Technical Operations, Legal/Policy) should stay intact and continue their work for at least a year.


Implied Decisions in NC HIE Strategic Plan – Oct. 2009

Approaches from Existing Strategic Plans Accept Modify/Needs Further Consideration

Reject

4. CCNC – “As part of North Carolina’s implementation strategy, this network of providers will be leveraged to convene and organize early community-based HIEs.”Workgroup decided that the issue needed more discussion and recommended that a decision on the principle be tabled and considered again in future Workgroup discussions.

X

5. From Implementation Roadmap section: “Special attention will be given to underserved, small and rural communities to facilitate meaningful use throughout the state, regardless of geographic location.”Workgroup recommended that the statement be modified to show support of participants in underserved and rural communities and recognition that they may face more significant barriers to participation in statewide HIE than other participants in the state.

Suggested Revision: “The NC HIE is committed to developing a system that is accessible to all providers of health care services, including those in rural and under-served communities. The NC HIE recognizes that lack of resources may cause significant barriers to participation and will work to develop multiple pathways for participation.”

X



Approaches from Existing Strategic Plans Accept Modify/Needs Further Consideration

Reject

1. Public/Private Partnership Model to Govern Statewide HIE

X

2.Identify geographic regions to support “Community Health Information Organizations” (or “CHIOs”)Recommended that the statement be modified to reflect NC HIE’s support for those existing regional networks or initiatives that align with statewide and national efforts, and to eliminate reference to geographic regions.

X

3. Under governance model outlined in the Strategic Plan, a representative from each CHIO would hold a seat on the governance bodyRecommended that current board is a self-perpetuating board including representation from Hospital/Health Systems, Providers, Consumers, Employers, and Payers.

X



Roles and Responsibilities of Governance Entity from Existing Strategic Plan

Accept Modify/Needs Further Consideration

Reject

1. Convening, educating and engaging key constituencies, including healthcare and health It leaders across the state.

X

2. Facilitating a two-tiered governance structure for interoperable health information exchange that includes: at the state level setting health information policies, standards and technical approaches, and at the community level implementing such policies by CHIOs.Workgroup decided that the issue needed more discussion and recommended that a decision on the principle be tabled and considered again in future Workgroup discussions.

X

3. Evaluating and establishing accountability measures for North Carolina’s HIT strategy.

X

Governing Participation in the Statewide HIE


Strategic Approaches for North Carolina Statewide HIE Structure

Range of “qualified organizations” pursuing regional or localized exchange are core structure

Statewide HIE provides statewide policy guidance, core services to enable interoperability

Statewide HIE may provide value-added services that benefit a range of participants to support sustainability.

Statewide Network Comprised of Diverse

Qualified Organizations

Abandon core services focus, leaving the private market to address interoperability

Provide backfills where market fails to assure ‘No provider left behind’

Focus on education, convening, and statewide policy guidance

Clinical/Technical Operations Workgroup advised against this option

Market Determines Structure – Statewide

HIE Backfills

Statewide HIE is primary vehicle for HIE

Statewide HIE builds infrastructure, consolidates HIEs for economies of scale

NC HIEs focus on local governance, adoption

Clinical/Technical Operations Workgroup advised against this option

Statewide HIE is the Market

Divide North Carolina into markets/territories assigned to existing HIEs, new HIEs or the Statewide HIE

Statewide HIE provides governance, manages monopolies for public good

Statewide HIE works with regional HIEs to develop service matrix to avoid duplication and to support joint sustainability.

Regional HIEs given Exclusive Territories –

Statewide HIE Provides Governance, Outreach


Considerations for Qualified Organization and Territory-Based HIE Models

Allows for a greater level of flexibility – wider range of entities can participate / serve as “on-ramps.”

Complexity could present need for greater level of administrative and technical support.

Policies and procedures would need to be adopted by and monitored across a larger and more diverse participant body.

Potential for more variation in core and value-added service needs.

Qualified Organizations

Allows for greater level of control – limited number of “on ramps.”

Potential cost savings due to fewer “on ramps.”

Could present higher level of risk – failure of one regional entity will impact many providers.

Requires significant stakeholder education and outreach.

Requires developing geographic boundaries and potentially close collaboration among competitors.

Responsibilities for service offerings more readily defined (some owned by Statewide HIE, others by RHIOs).

Territory-Based / Regional HIEs


New York Regional HIO Model


The RHIOs Serve as “On-Ramps” for Statewide HIE


Statewide Network Comprised of Diverse Qualified Organizations and Participants

One Example: Statewide Health Information Exchange NetworkOne Example: Statewide Health Information Exchange Network

RHIO RHIO

Lab Enterprise

Providers Hospital RHCFQHC Labs

PrivateNetwork

PayersPublic Health

Clinic Clinic Labs

Long TermCare

EHR Light

Medicaid

MMIS Clinical EligibilityPaid

ClaimsHospital Lab RHC FQHC

HospitalsPhysicianGroups

Clinics

NHIN GatewayInterstate Connectivity

Hospital Lab RHC

Hospital System


Complex HIE Landscape in North Carolina

• Multiple efforts and investments made across state in electronic exchange of health information.

• NC HIE Workgroup members have expressed a commitment to leveraging existing efforts to the extent possible.

• Many entities that could serve as data aggregators, for example:– Regional HIEs (WNCHN Datalink, CCHIE, Sandhills, Southern

Piedmont)– Statewide Exchange Services (Public Health Surveillance, NCHEX)– Academic Medical Centers with Faculty Practices– Large, Complex Health Systems – Community Care of North Carolina (CCNC)– Others


Key Questions for Discussion

• What is a Qualified Organization?• What is the Value of Being Part of Statewide HIE for a

Qualified Organization?• How do Qualified Organizations Join the Statewide HIE?• What are a Qualified Organization or Participant’s

Responsibilities as a Participant in Statewide HIE?• What is the Cost for Qualified Organizations to Participate in

the Statewide HIE?• What Happens if a Qualified Organization or Participant

Withdraws from the Statewide HIE?• How do providers or organizations unaffiliated with a

Qualified Organization connect to the Statewide HIE?• What are a Qualified Organization or Participant’s

Responsibilities as a Participant in Statewide HIE?• How Should Relationships Be Governed?


What is a Qualified Organization?

• A Qualified Organization is a health care organization or aggregator of organizations that is capable of fulfilling the technical, legal, policy, and procedural obligations defined by the Statewide HIE, and willing to enter a binding contract with the Statewide HIE that specifies these requirements and the legal consequences entailed therein.

• Qualified Organizations may be, but are not limited to:

– Provider Networks• Hospitals• Health systems • Integrated delivery networks (IDNs) • Provider groups • Consortia of providers• FQHCs/RHCs• Public Health • Regional HIOs

– Private Networks• Clearinghouses • Pharmacy • Vendor • Lab enterprise

– Medicaid Network– Payors


What is the Value of Being Part of Statewide HIE for Qualified Organizations?

• Facilitate satisfaction of meaningful use requirements among Qualified Organizations and Participants

• Increase access to important data at point of care by enabling HIE with organizations outside of a Qualified Organization’s existing network infrastructure more rapidly and at lower cost

• Offer broader referral and care coordination services to its members since they can now send/receive summary clinical information from organizations external to the Qualified Organization or Participant

• Access to North Carolina state government information, possibly including Medicaid data

• Lower development cost of shared services offered through participation in statewide HIE such as MPI, consent management, lab orders and results delivery, medication reconciliation

• Possible electronic access to public health data

• Access to best practices and learnings gathered by the Statewide HIE

• Participation in multi-state/interstate HIE and the NHIN

• Other?


How do Qualified Organizations Join the Statewide HIE?

• Part governance, part technical:

– Participation agreement/contract with the Statewide HIE, binding them to compliance with the Statewide HIE’s policy guidance and rules?

– Must integrate with and connect to the Statewide HIE


What is the Cost for Qualified Organizations to Participate in the Statewide HIE?

• Financial models are still under development. Cost considerations may include:

– Upfront connectivity costs

– Membership costs in proportion to the number of participants or the number of transactions

– Staging of costs based on which value-added services, in addition to core services, the Qualified Organization or Participant wishes to utilize

• Overall per participant costs should decrease with broader participation


What are a Qualified Organization or Participant’s Responsibilities as a Participant in Statewide HIE?

• Agree to send and receive health information to and from participants in accordance with the Statewide HIE’s rules

• Comply with all of the Statewide HIE’s policy guidance and rules

• Enforce the Statewide HIE’s rules with all of its own members and participants, including technology vendors that it employs

• Participation in governance process managed by Statewide HIE (e.g. participation in Workgroups or Advisory Bodies)

• Participation in generation and evolution of technical, legal, and other policy guidance as deemed necessary by governance process


What Happens if a Qualified Organization or Participant Withdraws from the Statewide HIE?

• Participation in statewide HIE is voluntary

• Withdrawal from participation is subject to reasonable withdrawal rules and processes


How do providers or organizations unaffiliated with a Qualified Organization connect to the Statewide HIE?

• If the NC HIE decides as policy it must fulfill a commitment to “no provider left behind” the Statewide HIE must offer every provider the opportunity to connect to the Statewide HIE network

• Options to insure every provider has access to at least one qualified organization (for example):

– Requiring that a qualified organization accept any provider that applies – with possible subsidies to the participant or the qualified organization in cases where the costs exceed the provider’s ability to pay

– Requiring that qualified organizations “bring on” a portion of providers who would otherwise lack access to statewide HIE (e.g. 10% of total provider participants)

– Offer a low-cost portal to enable participation in statewide HIE

– Coordination with the Regional Extension Center (REC) to identify small and solo practitioners for alignment with a qualified organization or connectivity via a low-cost portal


How Should Relationships Be Governed?

• The State would enter into a contract with the Statewide HIE

• The Statewide HIE would enter into a technical services contract (likely through an RFP process) to build a service offering consisting of core services and some value-added services

• The Statewide HIE would “certify” Qualified Organizations; Qualified Organizations will have a participation agreement/contract with the Statewide HIE, binding participants to compliance with the Statewide HIE’s policy guidance and rules

• Qualified Organizations (RHIOs, hospital systems, private networks, Medicaid, others) would be able to connect to the Statewide HIE to access core and value-added services

• Statewide policy guidance would include: – Privacy and security rules – Technical rules– Financial rules – Vendor contract requirements – Ongoing governance structure and participation

NC HIE Governance Domain of Operational Plan


NC HIE – Governance Domain of Operational Plan

• Combined Strategic & Operational Plan• Structure of Governance Domain in Plan:

– Overview– NC HIE Public/Private Partnership

• Articles of Incorporation• By-laws Recommendations

– Board of Directors– Committees– Workgroups– Conflicts of Interest– Transparency

• Authority and Involvement of the State in the PPP

– Governance of Participation in the NC HIE– Alignment with Other Programs


Next Steps

Upcoming Meetings– Board Meeting – July 13– Workgroup Meeting – July 22 (note location change: NC IOM)

Questions or Comments? - Contact [email protected]

3 rd Meeting Date: July 8, 2010 Time: 8:30 am – 11:00 am Location: NC Hospital Association 2400...

Documents

Transcript of 3 rd Meeting Date: July 8, 2010 Time: 8:30 am – 11:00 am Location: NC Hospital Association 2400...