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Certification / Adoption Workgroup. Larry Wolf, chair Marc Probst , co-chair. February 21, 2014. Agenda. Review of Agenda HITPC Charge: Step Two Concluding discussion of proposed Behavioral Health IT certification criteria
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Certification / Adoption Workgroup Larry Wolf, chair Marc Probst, co-chair February 21, 2014
Agenda • Review of Agenda • HITPC Charge: Step Two • Concluding discussion of proposed Behavioral Health IT certification criteria • Principles for Certification Criteria for LTPAC and BH Settings • Begin review of LTPAC/BH EHR certification recommendations • Update from Helen Burstin, HITPC Quality Measures WG • Next Steps • Public Comment
Concluding Discussion of Behavioral Health EHR Certification Draft Recommendations Proposed LTPAC EHR
BH Setting Specific CriteriaPatient Assessments Standards to Support BH Hearing Testimony Proposed Areas for BH Certification “Regarding BH clients, different code sets and assessments are required.” “There are current challenges with comparative data elements.. The “average” number of data elements collected during the intake to treatment planning process is 1,750 to 2,100. In one state alone, 1800 different diagnostic assessment forms styles or versions are in use.” “States have differing requirements for collecting and reporting standardized assessments for BH.” HL7 Implementation Guide for CDA® Release 2: Patient Assessments, Release 1 http://www.hl7.org/implement/standards/product_brief.cfm?product_id=21 HL7 Version 3 Domain Analysis Model: Summary Behavioral Health Record, Release 1 – US Realm https://www.hl7.org/implement/standards/product_brief.cfm?product_id=307 • Support the ability to create, maintain, and transmit (in accordance with federal and state requirements) assessment instruments and data sets for Behavioral Health. (e.g. ASAM Patient Placement Criteria (PPC), Child and adolescent functional assessment scale (CAFAS)) FUTURE WORK- Expand upon the existing standards to develop relevant certification criteria for this purpose.
Vital Signs ONC Certification Criteria to Support BH Hearing Testimony Proposed Areas for BH Certification ONC 2014 ed. CC: § 170.314(a)(4) - Vital signs, BMI, & (optional) growth charts “One of the Meaningful Use functions least relevant to psychiatry include are vital signs...” “We support the requirement to capture vital signs by BH organizations because many are focusing on integrated care due to co-occurring physical health issues. Being able to share data between BH and physical health IT systems will drive positive clinical outcomes.” • Support the ability to electronically record, change, and access, at a minimum, a patient’s height/length, weight, and blood pressure; and automatically calculate and display body mass index.
Advance Care Planning ONC Certification Criteria to Support BH Hearing Testimony Proposed Areas for BH Certification • Psychiatric advanced directives differ from medical advanced directives. • They allow a patient to document their preferences in the event they become incapable or involuntarily commitment. • Allows patients to indicate preferences for what types of confinement or treatment they do or do not want (medications, ECT, etc.). • Appoint a representative who can make mental health care decisions for the patient. ONC 2014 ed. CC: § 170.314(a)(14) – Advance directives • Indicate that advance directives exists for the patient. • Support the ability to store an advance directive document in the record or provide a link to the advance directive in a repository or other location. (Should be included in LTPAC/BH certification if also included in the MU3 regulation)
Final Review of LTPAC and BH EHR Certification Recommendations (Part 1) Proposed LTPAC EHR
Certification Criteria Principles • Harmonize with existing certification program • Voluntary & Modular • Focus on “All Provider” Criteria • Interoperability (exchange and use across organizations) • Confidentiality (Consent, Privacy, Security) • Use of “All Provider” functions within settings • Setting-specific needs (assessments, code sets, group documentation) • Alignment across state and federal programs • Minimum burden
Goal: All Provider Criteria Goal: All Provider Criteria Current State
Final Review of LTPAC and BH EHR Certification Recommendations • Final Recommendations to be reviewed TODAY • Transitions of Care • Clinical Reconciliation • Privacy & Security • Enhanced Privacy & Security • Labs/Imaging • Medication-Related • Clinical Health Information • CDS • Quality Measures • Final Recommendations to be reviewed on March 4th, 2014 • CPOE • Patient Engagement • Advanced Care Planning • Public Health Reporting to Registries • LTPAC Setting Specific Criteria • BH Setting Specific Criteria • \\ Final Review of LTPAC and BH EHR
Organizing Principle for Recommendations • LTPAC Setting Specific • Patient Assessments • Survey and Certification • BH Setting Specific • Patient Assessments Relevant to ALL Providers • Transition of Care • Privacy and Security • Enhancements to Privacy and Security • Relevant to some LTPAC and BH Providers • Clinical Reconciliation • Labs/Imaging • Medication-related • Clinical Health Information • Clinical Decision Support • Quality Measures • CPOE • Patient Engagement • Advanced Care Planning • Data Portability • Public Health - Transmission to Immunization Registries (LTPAC only)
Recommendation: Transitions of Care Background Information Proposed Areas for LTPAC/ BH Certification • Support the ability to receive, display, incorporate, create and transmit summary care records with a common data set in accordance with the Consolidated Clinical Document Architecture (CCDA) standard and using ONC specified transport specifications. WG members noted support for the following criteria, if approved in MU3: Support the inclusion of emerging TOC and care planning standards being reconciled as part of Aug. HL7 CCDA ballot. [MUWG-identified MU 3 criteria].
Recommendation: Clinical Reconciliation Background Information Proposed Areas for LTPAC/ BH Certification • Support the ability of a user to electronically reconcile the data that represent a patient’s active medication, problem, and medication allergy list. • Recommended for modular certification.
Recommendation: Privacy and Security Background Information Proposed Areas for LTPAC/ BH Certification Support existing ONC-certified Privacy and Security requirements: § 170.314(d)(1) - Authentication, Access Control, and Authorization § 170.314(d)(2) - Auditable Events and Tamper-Resistance § 170.314(d)(3) - Audit Report(s) § 170.314(d)(4) - Amendments § 170.314(d)(5) - Automatic Log-Off § 170.314(d)(6) - Emergency Access § 170.314(d)(7) - End-User Device Encryption § 170.314(d)(8) - Integrity § 170.314(d)(9) – Optional: Accounting of Disclosures WG members commented: It is important to be clear to LTPAC/BH providers, certifying to the privacy and security criteria does not make a provider HIPAA compliant. Providers need to be aware HIPAA compliance includes policy considerations beyond the technology.
Recommendation: Enhancements to Privacy and Security Background Information Proposed Areas for LTPAC/ BH Certification C/A WG could recommend P&S TT examine the following as part of their 2014 work plan: • Support inclusion of standards for communicating privacy policies (HL7 Privacy and Security classification system) and controlling re-disclosure of protected data. • ONC should consider supporting equivalent functionality in MU 3 for standards for communicating privacy policies and controlling re-disclosure of protected data. • Incorporate granular data segmentation when ready. • Use of the HL7 privacy and security classification system to tag records to communicate privacy related obligations with the receiver. • Develop consensus on standards for consent management functionality needed by BH providers to comply with diverse federal and state confidentiality laws , including the Data Segmentation for Privacy Standard • P&S TT has submitted their recommendations on patient consent for MU3 and will provide an update on a future call.
Recommendation: Labs/Imaging Background Information Proposed Areas for LTPAC/ BH Certification • Support the ability for an ambulatory setting to be capable of electronically receiving, incorporating, and displaying clinical lab tests and values/results. • Support the ability for an inpatient setting to be able to generate lab test reports for e-transmission to ambulatory provider’s EHR systems. • Support the ability to electronically indicate to a user the availability of a patient’s images and narrative interpretations (relating to the radiographic or other diagnostic test(s)) and enable electronic access to such images and narrative interpretations. Note: The WG did not provide feedback on the second recommendation. Feedback requested. • While ‘electronic access to imaging results’ would be valuable to many providers, WG members noted that ‘electronic access to images’ may not be needed by others, and the inclusion of this component could add burden and cost. • Currently both components are included in one certification criteria. ONC could consider splitting these components into discrete criteria.
Recommendation: Medication-related Background Information Proposed Areas for LTPAC/ BH Certification • Support the ability for a user to electronically create and transmit prescriptions/rx-related information. • Support ability to automatically and electronically check whether a drug formulary exists for a given patient or med. • Support ability to enable drug-drug and drug-allergy interaction checks. • Support electronic medication administration record. • Some WG members noted that prescribers are likely already using a system that has an e-Prescribing module. • WG recommended inclusion of medication related certification criteria as modules .
Recommendation: Clinical Health Information Background Information Proposed Areas for LTPAC/ BH Certification • Support the ability to record, change, and access the following data using ONC specified standards: • Demographics • Problem list • Medication list • Medication allergy list • Family health history ** • Smoking status ** • Support the ability for a user to electronically record, change, access, and search electronic notes. • Support ability to electronically and dynamically select, sort, access, and create patient lists. ** • FUTURE WORK: ONC should consider including DSM-5 standards. • NOTE: Criteria with **were not considered on LTPAC calls but could be appropriate. Feedback is requested on modular inclusion. • Some WG members commented that ‘patient history’ is not part of the MU certification criteria but noted that this information can be important, particularly in LTPAC/BH.
Recommendation: Clinical Decision Support Background Information Proposed Areas for LTPAC/ BH Certification Support the ability to have: • Evidence-based decision support • Linked referential clinical decision support • Clinical decision support configuration • Automatically and electronically interact • Source attributes • WG members noted this criteria is very important to some LTPAC/BH providers but not others. • There was not unanimity on this criteria; a range of views were voiced. • Recommended for modular certification.
Recommendation: Quality Measures Background Information Proposed Areas for LTPAC/ BH Certification C/A Workgroup requests that HITPC Quality Measures WG discuss clinical quality measures further and provide recommendations to C/A WG on potential LTPAC CQM opportunities for LTPAC EHR certification. Update from Helen Burstin, HITPC Quality Measures WG • WG members have noted QMs should not interfere with provider workflow.
