Transcript Overview of HIE/HIT National Initiatives - Cerner

From National Health IT to State
Uniform Companion Guides
Realities and Opportunities to Make
Standards Finally Work
Presented at the
HIPAA COW 2008 Fall Conference
Sheboygan, WI – September 19, 2008
Walter G. Suarez, MD, MPH
President and CEO - Institute for HIPAA/HIT Education and Research
Member, National Committee on Vital and Health Statistics (NCVHS)
Member, Board of Directors, Health Information Technology Standards Panel (HITSP)
Outline
• Why are we here today?
• Core Health IT and HIE Concepts
• Business Case for NHIN and NHIEs
• A National Coordinated Agenda
• Where Things Stand Today
• Transitioning to State Realities: The Minnesota
Statewide Uniform Companion Guide
Development Project
• Take away messages
Why are we here? Some Critical Health
Needs and the National HIT Agenda
• Avoidance of medical errors
– Up to 98,000 avoidable annual deaths due to medical errors
• Improvement of resource utilization
– Up to $300B spent annually on treatments with no health yield
• Acceleration of knowledge diffusion
– 17 years for evidence to be integrated into practice
• Reduction of variability in healthcare delivery and access
– Access to specialty care highly dependent on geography
• Empowerment of the consumer
– Capitalize on growing consumer trend of active health management
• Strengthening of data privacy and protection
– HIPAA becomes reality
• Promotion of public health and preparedness
– Surveillance is fragmented, and importance to homeland security brings
heightened awareness
Core Concepts
Health IT and HIE - Leading
Transformation Factors
• Electronic Health Records
• Personal Health Records
• Interoperable Standards
• Health Information Infrastructure
• Population Health Infrastructure
• Robust Security and Privacy
And…
• A business reason that supports doing all this!
What is “Interoperability”?
“The ability of different information technology
systems and software applications to
communicate, to exchange data accurately,
effectively and consistently, and to use the
information that has been exchanged.”
Source: National Alliance for Health Information Technology, July 2005; “Consensus
Conventions for the Use of Key HIT Terms” Project – ONC/HHS, 2008
“Record” Terms
Source: National Alliance for Health Information Technology, Report to the Office of the
National Coordinator for Health Information Technology – Defining Key Health Information
Technology Terms, April 28, 2008
“Network” Terms
Source: National Alliance for Health Information Technology, Report to the Office of the
National Coordinator for Health Information Technology – Defining Key Health Information
Technology Terms, April 28, 2008
RHIO and HIE – Distinguishing and
Common Characteristics
The Business Case for Regional and
Nationwide HIE Investment
Level of Exchange
Federal / National
Primary Interest
Support for NHIE
Clinical & Administrative
Strong interest in NHIE and
Mandatory Use of National
Standards
Referrals, Results, Pop. Health events
(Medicare, MHS/VA/IHS/SSA etc.)
Regional / Interstate
Referrals, Results,
Pop. Health events
(Nat’l Payers & Self-funded Plans, etc.)
Statewide / Intrastate
Cross-Communities / HIEs
Clinical & Administrative
(Medicaid, State Health Plan, State
BCBS, Pop. Health awareness)
Referrals, Results,
Pop. Health events
(Health Systems, Regional Payers, PH)
Strong Interest in National
Standards;
Interest in NHIE
Strong Interest in National
Standards;
Mild interest in NHIE
Interest in National Standards;
Mild interest in Intrastate or
NHIE
Intra Medical Trading
Area/Community
Referrals, Results Delivery,
Administrative
(eRx, Lab, HIPAA claims/pmts)
Interest in Standards
Avoid technical isolation;
Mild interest in Intrastate / NHIE
Enterprise
Internal Network
Low Interest in NHIE
(Internal to Practice, PH, Hospital, etc.)
The National Health IT
Strategy
Federal Government Collaborations
Among Health IT Initiatives
ONC-Coordinated
Federal Health IT
Strategic Plan
2008-2012
ONC Health IT Strategic Plan (2008-2012)
National HIT Agenda and Health
Information Exchange
Priorities
• American Health Information
Community (AHIC)
• Business needs and priorities
• Use Cases
• NHIN - network of
networks
• Architecture
specifications
Standards
• Healthcare Information
Technology Standards
Panel (HITSP)
• Recognized standards
Networking
Agenda
Policies
Certification
• Certification Commission For
Healthcare Information (CCHIT)
Technology
• Criteria development
• Testing
• State laws and regulations –
• State Alliance for e-Health
• State-level Health Information
Exchange
• Health Information Security and
Policy Collaboration (HISPC)
Setting Priorities - AHIC
• Recommendations to Secretary on overall policy
directions related to Health IT
• Definition of priority areas (breakthroughs)
• Development of Use Cases for harmonization of
standards
• Transitioning to
AHIC 2.0
http://www.ahicsuccessor.org
Networking – NHIN and the
NHIEs
• NHIN: the nationwide “Network
of Networks”… of Networks
– Framework for health information
network service providers
– Interconnecting NHIEs
– Business/Technical Issues:
Standards, Sustainability, Security
• NHIEs: Local, state, regional
HIEs interoperable with NHIN
http://www.hhs.gov/healthit/healthnetwork/background/
Networking – NHIN and the
NHIEs
• Phase 1 (2007) – Prototyping
– 4 Consortia
– Core elements of NHIN
• Phase 2 (2008) – Trial
Implementations
– 15+ sites
– Develop the NHIN HIE Specs
• Phase 3 (2009) - TBD
http://www.hhs.gov/healthit/healthnetwork/background/
Where are States with respect to HIEs?
Sources: Health Information Security and Privacy Collaborative (HISPC); State-level Health
Information Exchange (SLHIE); January, 2008
Policies - HISPC
•
Phase 1 (2006-2007)
– 34 Teams (33 State, Puerto Rico)
– 1) Assessments of privacy/security
variations; 2) Analysis of solutions; 3)
Develop implementation plans
• Phase 2 (July-Dec 2007)
– Each team to implement a
foundational component of
their implementation plans
• Phase 3 (2008-2009)
– 7 Multistate Collaboratives
developing common,
replicable multistate solutions
http://healthit.ahrq.gov/privacyandsecurity
Policies – State-level HIE
• Funded by ONC
• Develop reports and tools:
– State-level HIE Development
Workbook
– RHIO Governance roles
– Consensus model HIE policies
http://www.staterhio.org
Policies – State Alliance for eHealth
• National Governors Association’s initiative supported by ONC
• Initial work (2006/2007) done through 3 Taskforces:
– Health Information Protection
– Health Care Practices
– Health Information
Communications and
Data Exchange
http://www.nga.org
• Reconfigured Taskforces to
focus on:
– Privacy and Security
– Public Programs Implementation
• Taskforce reports provide several
recommendations to states on
privacy, security, Public program (i.e. Medicaid) roles in HIEs, need
for harmonizing cross-state regulations on medical practice
Standards – The Health Information Technology
Standards Panel (HITSP)
HITSP Information Resources

Please take a copy of the introductory CD-ROM available
at this kiosk or visit our website (www.hitsp.org) for a
downloadable copy of the
CD’s content

Also available on www.hitsp.org
– News, organizational details and information on
upcoming meetings
– HITSP Public Document Library
– Interoperability Specifications (ISs)
and Executive Summaries
– Use Cases
– HITSP Webinars (Free!)
HITSP: Enabling interoperability across the health care enterprise
27
Standards in the National HIT Agenda
American
Health
Information
Community
Priorities
(AHIC)
Use
Cases
Healthcare
Information
Technology
Standards
Panel
(HITSP)
Secretary
Currently
“Accepted”
Interoperability
60
Specifications
(2007)
One Year Testing and
Implementation
Certification Commission for Healthcare
Information Technology (CCHIT)
(Stark and Anti-kickback)
Verified
Federal Systems and Healthcare Contracts
(Executive Order 13410)
Use
Nationwide Health
Information Network (NHIN)
Secretary
Currently
“Recognized”
52
(2006)
Certification – The Certification Commission
for Health Information Technology (CCHIT)
CCHIT – Certification Commission
for Health Information Technology
CCHIT SCOPE OF WORK
CCHIT – Certification Commission
for Health Information Technology
• Results to-date:
– A total of nine inpatient EHR products have been certified,
representing 36% of the inpatient EHR vendors in the market
• Four additional inpatient EHR product applications were received
recently, bringing total to 50% of the inpatient EHR vendor market
– Over 60 ambulatory EHR products representing more than 35%
of the outpatient EHR vendors in the market
• 14 additional ambulatory EHR product applications recently
received, bringing total to close to 50% of the inpatient EHR
– Moving into specialty areas (i.e., cardiovascular, child health),
network services
NHIN – Completing the Cycle
Transitioning to State Realities:
The Minnesota Statewide Uniform
Companion Guide Development
Project
Background
• In 2007 the MN Legislature passed a law amending the “MN
Health Care Administrative Simplification Act of 1994” (MN
Statutes §62J.50 -§62J.61) and requiring the development,
adoption and use of state uniform companion guides
• Part of Minnesota’s commitment to the increased use of health
IT for both administrative and clinical activities
• Initial set of transactions subject to the new law includes Claims
(837P, 837I, 837D, NCPDP), Claim Payment (835), and
Eligibility (270/271)
• State law covers all health care providers and group purchasers
(health plans, Medicaid, employers and others) doing business
in the state; the law requires them to conduct these transactions
electronically and use the standard companion guides
Background
• Commissioner of Health, in consultation with the MN
Administrative Uniformity Committee, is charged with
developing state uniform companion guides
• Companion guides are to be based on billing and coding
rules from the Medicare program, but can depart from them
based on state health care industry’s consensus
• Companion guides will be required to be used, along with
the HIPAA Implementation Guides, when conducting any of
the transactions they cover
The Minnesota Uniform Companion Guide Development Project
Summary of State Law
Summary of State Law
(MN Statutes § 62J.536)
• Part 1 - Requirements for all health care providers and
group purchasers to implement uniform electronic
transactions
– All group purchasers and health care providers in MN must
exchange claims and eligibility information electronically, using
the transaction standards prescribed by HIPAA and the
companion guides and timelines established by the state law
– Group purchasers may not impose any fee on providers for the
use of the transactions prescribed in this legislation
– Direct data entry, web-based methodology allowed, so long as
it is consistent with data content component of HIPAA
implementation guides and MN uniform companion guides
Summary of State Law
(MN Statutes § 62J.536)
• By January 15, 2009, ALL health care providers and group
purchasers in MN must submit/accept the HIPAA electronic eligibility
transaction (270/271)
• By July 15, 2009, ALL health care providers and group purchasers in
MN must submit/accept the HIPAA electronic health care
claim/encounter information transaction prescribed by HIPAA (837s,
NCPDP)
• By December 15, 2009, ALL health care providers and group
purchasers in MN must submit/accept the electronic health care
payment/RA transaction prescribed by HIPAA (835)
Summary of State Law
(MN Statutes § 62J.536)
• Part 2 - Requirement for the development and use of
single, uniform, statewide companion guides for the
identified transactions:
– Each named transaction must use a single, uniform companion
guide to the HIPAA implementation guides statewide
– Companion guides to be developed as follows:
• Commissioner of Health, in consultation with MN-ACU develops
companion guides at least 12 months prior to the timelines
required for transaction
• Commissioner of Health issues a Notice of Proposed Rulemaking
requesting industry comments on ‘draft’ companion guides
• Commissioner of Health promulgates rules establishing and
requiring group purchasers and health care providers in MN to use
the uniform companion guides
Summary of State Law
(MN Statutes § 62J.536)
• No group purchaser or health care provider may add or
modify the companion guides through their own
companion guides or other requirements
• Commissioner shall not require data content that is not
essential to accomplishing the purpose of the
transaction
• Health care providers also includes dentists,
chiropractors, nursing homes, boarding care homes
and home care providers
• Other ‘group purchasers’ subject to law includes
Workers Compensation and medical component of
Auto Insurance
What are the MN Uniform
Companion Guides Doing?
• Eliminate proprietary companion guides
• Reduce/eliminate Situational Variability of loops, segments
and data elements in the HIPAA Implementation Guides
• Reduce/eliminate Interpretative Ambiguity of loops, segment
and data elements in the HIPAA implementation Guides
• Reduce and standardize the codes used in data elements,
within a code set
• Identity and define loops, segments and data elements that
are not considered for processing by entities in Minnesota
What the MN Uniform Companion
Guides are NOT Doing?
• Replace HIPAA IGs
• Make implementation inconsistent and incompatible
with, or in violation of the HIPAA Implementation Guides
– What is Required by HIPAA IG is Required by MN CG
– What is Not Used in HIPAA IG is Not Used in MN CG
– What is Situational in HIPAA IG is further defined in MN CG
• Disclaimer from the Guide: “… the [companion guide] supplements,
but does not contradict, disagree, oppose, or otherwise modify the
HIPAA Implementation Guide in a manner that will make its
implementation by users to be out of compliance.”
Why is this Project Important?
• Multiplicity of companion guides and payer-specific
requirements
• Providers need to customize transactions on a payerby-payer basis
• Inconsistencies in transaction requirements
significantly increases administrative burden
• Quality of care delivered to consumers is being
affected
The Minnesota Uniform Companion Guide Development Project
Understanding Companion Guides
What are Companion Guides?
• A Companion Guide is a document that clarifies,
supplements and further defines specific data content
requirements contained in the Implementation Guides
established for each of the HIPAA transactions
• Generally, companion guides cover four core areas:
– Define transaction instructions (EDI information) between
trading partners
– Further define requirement of loops, segments, data elements
– Further define data element content
– Further define data coding used in transaction
1000s of Companion Guides…
While there is ONE HIPAA Implementation Guide, there are 1000s of
companion guides developed by each payer in the market….
The Minnesota Uniform Companion Guide Development Project
Process for Developing
MN Uniform Companion Guides
Process for Developing
MN Uniform Companion Guides
• Use MN-AUC Committee and Workgroup Structure
• Establish Companion Guide Development Teams
• Develop Principles and Guidance Document
• Develop Consensus Building Approach and Decision
Making Process Document
• Develop Standard Master Template Companion Guide
Document
• Establish Project Workplan and Timeline
Cycle for Companion Guide
Development
• Draft of Companion Guide is prepared
• Notice proposing adoption published - 30-day comment period
• Comments are addressed, changes made to guide
• Notice adopting guide is published
• A one-year period of transition for compliance starts
• Six-month into process, technical review is done
– Revisions to adopted companion guide are published for public
comments
– Notice adopting final revised companion guide for compliance is
published
• Compliance starts
• Annual review and update…
www.health.state.mn.us/auc
Minnesota Department of Health
Minnesota Administrative Uniformity Committee
MN Companion Guide Project Plan
Major Milestones/Task Timelines
2007-2008
All Companion Guides
May
Jun
01 08 15 22 29
Jul
Aug
11 18 25
01 08 15 22 29
Oct
05 12 19 26
Nov
03 10 17 24 31
Address Parking
Lot Issues
Collect Base
Info
Create
Tables
Collect Base
Info
Create
Table
First Meeting
Establish
Workgroup
Establish
Workgroup
Establish
Workgroup
EOB Workgroup
Established
Send
CG to
AUC
Ops
Create/Review CG Doc
837D
837I/837P
835
Merge
Table and
CG, add
Appendices
First Meeting
Establish
Workgroup
Identify
Parking Lot
Issues
Collect Base
Info
Jan
02 09 16 23 30
Mar
06 13 22 29
05 12 19 26 31
Companion Guide (CG) Development
Review/Discuss, Reach Consensus
Create
Table
05 12 19 26
2008
Feb
Phase II
Develop Principles/Guidance/Templates
Collect
Base
Info
Dec
07 14 21 28
Phase I
NCPDP
270/271
Proj
Mgt
13 23
2007
Sep
Last Update:
January, 2008
Collect Base Info
Send
CG
to
AUC
Ops
Notice of
Adoption
Published
12/10
Effective
Date of
Notice:
30 days
post
publication
Review/Discuss, Reach Consensus
Address Parking
Lot Issues
Create CG Docs
Review Front Matter
Review/Discuss, Reach Consensus
Identify Parking
Lot Issues
Address Parking
Lot Issues
Create CG Doc
Identify Parking
Lot Issues
Create CG Docs
Create Tables
CG Group meets to
review comments,
update CG as needed
Identify Parking
Lot Issues
Review/Discuss, Reach Consensus (Round 1)
Create
Tables
Notice Published;
Comments due
10/30
Form
“Parking
Lot Issues
Groups”
(100 to
500 Work
Groups)
Review Front Matter
Merge
Tables and
CGs, add
Appendices
Merge
Table and CG,
add
Appendices
Address
Coding Issues
Deadline for Implementation of CG
by industry: 01/15/2009
Send
draft
CGs
to
AUC
Ops
Notice
(30-day
Public
Comment)
Published
3/31
Send
draft
CG to
Coordinate Parking AUC
Lot Issues with
Ops
837P/837I Group
Notice
(30-day
Public
Comment)
Published
3/31
Complete Drafting
and Review of
CGs
Complete Drafting
and Review of CG
Review/Discuss, Reach Consensus (Round 2)
Complete 100-500 Review Process
Address Coding Issues
Review CG Front Matter
Merge
Tables and CGs,
add Appendices
Address Parking Lot Issues from 837D
Complete the
development of
CGs, and Code
set Appendices
Send
draft
CG to
AUC
Ops
Notice
(30-day
Public
Comment)
Published
3/31
Review/Discuss, Reach Consensus (Round 1)
Identify, Discuss, Address Parking Lot Issues
Identify, Discuss, Address Coding Issues
Create CG Doc
Review/Discuss CG Front Matter
Merge
Table and CG
create/add
Appendices
Minnesota Department of Health
Minnesota Administrative Uniformity Committee
MN Companion Guide Project Plan
Major Milestones/Task Timelines
2007-2008
All Companion Guides
Apr
May
Jun
01 07 14 21 28
05 12 19 26
02 09 16 23
Aug
Sep
Oct
Nov
Proj
Mgt
Dec
Jan
Feb
2009
Mar Apr May
Jun
Jul
01 07 14 21 28
Phase III
Phase II
Industry Transition, Guide Refinement
Industry Preparedness and Transition
270/271
Deadline for
Implementation
of CG by
industry:
01/15/2009
AUC CG Group
review comments
and update CGs
as needed
Complete Drafting and
Review of CG
MDH Review Publish Notice of
Adoption
Industry Preparedness and Transition
Send
Modify
draft
CG as
CG to Needed
AUC
From
Ops AUC Ops
Input
Send
Notice
final
(30-day
CG to
Public
AUC Comment)
Ops Published
7/15
Public Comment
Period
AUC CG Group
review comments
and update CG
as needed
MDH Review Publish Notice of
Adoption
Public Comment
Period
Industry Preparedness and Transition
Submission to
AUC Ops
AUC CG Group
review comments
and update CGs
as needed
MDH Review Publish Notice of
Adoption
Public Comment
Period
CG
Periodic
Maintenance
Industry Preparedness and Transition
MDH Review Publish Notice of
Adoption
AUC CG Group
review comments
and update CGs
as needed
Submission to
AUC Ops
Public Comment
Period
Submission to
AUC Ops
Process for Identification, Review and
Adoption of Technical Corrections
Submission to
AUC Ops
NCPDP
837D
837I/837P
835
2008
Jul
Last Update:
October 15, 2007
Process for Identification, Review and
Adoption of Technical Corrections
Deadline for
Implementation
of CG by
industry:
07/15/2009
Process for Identification, Review and
Adoption of Technical Corrections
Deadline for
Implementation
of CG by
industry:
07/15/2009
Process for Identification, Review and
Adoption of Technical Corrections
Deadline for
Implementation
of CG by
industry:
07/15/2009
Industry Preparedness and Transition
Process for
Identification,
Review/Adoption
of Technical
Corrections
Deadline for
Implementation
of CG by
industry:
12/01/2009
Status of Project Deliverables
•
•
•
•
Eligibility (270/271) Companion Guide:
–
Completed and adopted by state - December 10, 2007
–
Technical revision completed in May 15, 2007
–
Implementation date: January 15, 2009 (early voluntary adoption permitted)
Claim (837P/I/D, NCPDP) Companion Guides:
–
Completed and published for comment in March, 2008
–
Published notice adopting companion guides in June, 2008
–
Technical changes expected to be completed in March, 2009
–
Implementation date: July 15, 2009 (early voluntary adoption permitted)
Claim Payment/RA (835) Companion Guide:
–
Under development – expected completion and publication for comment: June, 2008
–
Published a Notice of Proposal to Adopt in July, 2008 – Comment Period ended August, 2008
–
Currently reviewing and addressing comments, revising companion guide
–
Notice adopting final companion guide expected to be published October, 2008
–
Six-month technical amendment in April, 2009
–
Implementation date: December 1, 2009
All final guides will be available from the MN AUC website (www.health.state.mn.us/auc)
Take Away Message….
So, why is all this important to
me?
•
National and local initiatives are affecting how you do business in health
care
– Increased dependency on electronic health information, connectivity and
interoperability
•
HIPAA still a very important implementation issue
– Upcoming Claim Attachments, 5010, NCPDP D.0 and ICD10 standards
•
Industry moving into the adoption and use of clinical information exchanges
– Electronic health records, lab information systems, e-Prescribing
•
New and emerging areas in health information
– Personal Health Records – will they become mainstream?
– Clinical decision support systems – increasing dependency on standard, codified
electronic health information
So, why is all this important to
me?
• Informed consumers with shifting expectations
– Bringing better and more relevant health information to the fingertips of
consumers and improving efficiency of consumer controls over their
health information
– Consumers bringing higher expectations on a practice’s ability to
maintain and exchange their health information securely and efficiently
– Can my Doctor and I communicate electronically via email and web
services?
• Alignment of incentives to adopt health IT
– NOW: Pay for Performance – including the adoption of health IT
components such as CPOE
– NEXT: Pay for Conformance – including adopting interoperable, certified
health IT products and networks
Thank You
Walter G. Suarez, MD, MPH
President and CEO
Institute for HIPAA/HIT Education and Research
Alexandria, VA
Phone: (952) 221-3841
Email: [email protected]