Transcript Document
May 14, 2014 PAeHI’s 10th Annual HEALTHCARE IT SUMMIT ‘Connecting Pennsylvanians for Better Health’ Aaron Seib, NATE CEO 1. About NATE • • History Member States 2. Legal Barriers • Model Modular Participants Agreement • Open Library for Health Information Exchange 3. Policy Barriers • Consent • Patient Mediated Exchange 4. Technology Barriers • CONNECT: Open Source Community About this talk …and NATE The mission of NATE is to assist state HIE officials, individually and collectively, in serving the public interest and achieving the following fundamental HIE goals in a responsive, efficient and cost effective manner, consistent with the wishes of its members: • Protect the public interest; • Develop a roadmap that addresses and eliminates the legal, policy and technical barriers that inhibit HIE between entities in a state and across state borders; • Facilitate HIE Governance as the path to trusted exchange through the convergence of disparate trust models, policies and processes; • Collaborate with all interested participants to initiate and/or participate in the development of HIE national standards and best practices; • Promote the reliability and sustainability of the HIE industry; and • Support and improve state regulation of HIE. About me…and this talk and some coincidences • Born and raised in Pennsylvania • Went to college at University Park where I got a degree in Management Science and Information Systems. • 20 years Professional Experience in Health information Technology. • Worked for HealthAmerica and Synertech here in Harrisburg back in the mid-90s; then in Disease Management and Clinical Research for the NCI; • It was while I was at the NCI in 2004 --- 10 years ago that President Bush signed Executive Order 13335: Incentives for the Use of Health Information Technology and Establishing the Position of the National Health Information Technology Coordinator Ten years ago my son Tyler was Diagnosed with Autism • About the time Bush signed 13335 we got a definitive Dx of Autism for Tyler • Over the ensuing years I was stunned to learn that the state of art for treating Autism amounts to trial and error. • Made a commitment to work on anything I could to further the vision of what has come to be known as the learning health system. Motivated • Had the tinniest of footholds on the Phase 1 Prototype Architectures of the NHIN back in 2005 …and did everything I could to be involved in related work since, including: • Worked with the ONC as the Trial Implementation Manager for the NHIN; • Was the interim CEO for the National eHealth Collaborative; • Worked for the State of California (starting in 2011) as the state’s HIE Policy SME leading a number of initiatives including what became NATE. History of NATE • In the Spring of 2011, State Leaders on the West Coast began to interact – eventually forming an affinity group that sought to leverage the ONC’s State HIE Grantee Cooperative Agreement • One of the Program Information Notices (PINs) required State Grantees to allocate resources to “enabling interstate HIE” • This affinity group of states collaborated on a proposal to pilot mechanisms for multi-state trusted exchange – resulting in a multi-state grant award known as the Western States Consortium. 7 The Western States Consortium ONC State Health Policy Consortium Project focused on the governance needed to facilitate and support Interstate HIE, using Direct Secure Messaging Resolve policy issues, especially those related to privacy, security and data use Develop standards and requirements for trusted services, beginning with Direct Secure Messaging Core States: Alaska, Arizona, California, Hawaii, Nevada, New Mexico, Oregon and Utah Pilot States: California and Oregon Affiliate States: Colorado, Florida, Georgia, Idaho, Michigan, Ohio and Washington 8 Success! • At the end of March in 2013 we had satisfied the requirements of our grant. • We had established a ‘trust community’ that enabled each State to independently govern HIE within its state while facilitating crossboarder exchange when appropriate. • Further we had established mechanisms to enable discovery of providers associated with this ‘trust community’ in the nations first Federated Provider Directory. • At the end of the grant, we asked ourselves if we should continue to support the programs we had started. • I think the best way to sum up the conclusion of the members at the time was the image that was conjured up when we asked ourselves “What if the State’s didn’t Collaborate on establishing HIE?” 9 Incorporation Independent non-profit organization established in Washington DC, May 2013 Bylaws, governance body, and organizational structure developed Vision: HIE Governance is the path to trusted exchange Mission: Initiate and/or participate in the development of national standards that support ongoing HIE State Level Membership Member States: Alaska, Arkansas, California, Colorado, Florida, Hawaii, Michigan, Nevada, North Dakota, Oregon and Utah Interested States: Arizona, Georgia, Idaho, New Mexico, Washington and Ohio Current Funding Streams Member State’s Pay population based annual fee Grant awards In-kind participation and volunteer activities Nation’s First Trust Bundle for DIRECT Each state knows how to query each other state. Complexity within a state is hidden. Nation’s First multi-state Federated Provider Directory Pilots State HISP AK State Directory State HISP CA State Directory Regional HISP OR State Directory Regional HISP Regional HISP Completed Phase 1 PHR related Pilot Provider HISP Current Bundle Provider HISP New Bundle: Provider-to-consumer exchange Directenabled PHR New Bundle: Consumer-to-provider exchange NATE’s current activities at 1 years old • Legal Barriers: The Model Modular Participants Agreement and OLHIE • Policy Barriers: Trust framework for bidirectional exchange between patients and providers; as well as initial real world piloting of SAMHSA’s Consent2Share software for HIE • Technical Barriers: Leadership roles related to the OHT CONNECT Community and participating roles in relation to NSTIC pilots; Addressing Legal Barriers Model Modular Participants Agreement • During my tenure in California one of the tools that we developed, which is migrating to the open source environment I will be describing in a moment, is the Model Modular Participants Agreement • I understand that Legal Agreements are a hot topic of discussion here in Pennsylvania so I thought I would talk a little bit about what we developed and then tell you what we are doing to make it more readily available What is a Participants Agreements? • What are Participant Agreements and why are they important to the eHealth Vision? • Participants Agreement – the contract between an HIO and its Participants, the purchaser of the HIOs service offerings. • Participants Agreements describe the obligations of both parties and are essential to describing the rules of the road. • Since the service offerings of each HIO is different and how those service offerings are delivered differ there is no one size fits all contract that can be proposed. 18 Frequently cited as a barrier to exchange • Pain Point –Why? • For emerging HIOs these contracts are costly to develop and finalize • For Participants the variance between Agreements increases the difficulty in evaluating them and ultimately executing them. • Significant elapsed time lost to legal review When I was at CalOHII we heard from all types of Stakeholders that the participant’s agreement was an area where the community could benefit from a tool – perhaps a Model Participants Agreement? 19 But why is this so hard? • If you have seen one HIO, you’ve seen one HIO • There are many mechanisms to enable appropriate health information exchange • Many HIOs offer multiple mechanisms to enable health information exchange depending on the use case and customer needs • These compounded differences and the complexity of the learning curve makes it difficult for any single organization to support the resource requirements to readily master all of the details. • To produce results our task force had to make some simplifying assumptions… 20 All models are wrong and only some are useful. ~ D. Edwards Deming 21 HIOs support many different modes of exchange • The Task Force recognized that there are many methods of exchange being offered today • Ranging from a Conduit offering all the way to Offerings that provide Patient Centric Longitudinal Views made up of data from many Participants • Yet, the Pareto rule does apply and many terms and conditions are common regardless of the mode(s) of exchange being considered …yet many of the principles are the same – such as ensuring security and preserving privacy. Give me a fruitful error anytime, full of seeds, bursting with its own corrections. ~ Vilfredo Pareto 23 Iterative Development • MMPA Release 1.1 • Formed Task Force in July 2012 • Drafted straw-man and iterated numerous times • 30 day comment period ; input incorporated • Presented Candidate version to CalOHII • Released by CalOHII in September 2012 • MMPA Release 2.0 • Following same pattern of development • Incorporated updates result of Omnibus Rule • Formally released by CalOHII in August 2013 • MMPA Release 2.2.1 • Addendum with corresponding DURSA provisions for ease of incorporation by HIOs using the MMPA as part of multi-party trust agreement. MMPA R2 Task Group Members Included Allen Briskin (Co-Chair) Pillsbury, Winthrop, Shaw, Pittman, LLP Jana Aagaard Of Counsel to Dignity Health Law Office of Jana Aagaard Sergio Bautista CFO\COO Community Health Alliance of Pasadena Paul Budilo Executive Director OCPRHIO Martin Love Chief Executive Officer North Coast Health Information Network John R. Christiansen Christiansen IT Law James Killeen, MD University of San Diego Dept. of Emergency Medicine Cassie McTaggart Cal OHII Division Chief Health Information and Policy Standards Austin O’Flynn (Co-chair) Senior Counsel, Dignity Health Alice Leiter Policy Counsel, Center for Democracy and Technology Bill Beighe Chief Information Officer Santa Cruz Health Information Exchange Richard Swafford, PhD Executive Director Inland Empire Health Information Exchange Michael Smith Director of Operations HealthShare Bay Area Dr. Lisa Scott Deputy Compliance Officer Sacramento County Hugo Von Bernath Healthcare Information Resource Center Office of Statewide Health Planning and Development (OSHPD) Kerry Cataline Cal OHII Branch Chief Health Information and Policy Standards Intended use • The MMPA is a tool to aid you. It does not eliminate the need to work with legal counsel. • For those of you who are currently developing Participants Agreements we hope this is helpful in accelerating the process. • For those of you who are potential Participants, we hope this tool helps you evaluate the agreements of HIOs you’re working with. • As we move toward enabling inter-HIO exchange we hope that the MMPA facilitates the process of verifying alignment of any HIO’s Terms and Conditions to this common baseline in order to minimize the need for point-to-point agreements between HIOs. • The theory is that having a reference point we can Index Participants Agreements and ultimately simplify the comparison of terms and conditions and enable the acceleration of HIE Adoption at the participant level and across HIOs. 26 80/20 Rule – Common Sections • • • • • • • • • • • • • • • • • • • Section 1 - INTRODUCTORY AND GENERAL PROVISIONS Section 2 - DEVELOPMENT AND ADMINISTRATION OF PARTICIPATION AGREEMENTS Section 3 - TERM AND TERMINATION OF PARTICIPATION AGREEMENTS Section 4 - AUTHORIZED USERS Section 5 - GENERAL OBLIGATIONS OF PARTICIPANTS Section 6 - DATA RECIPIENT’S USE OF SYSTEM AND SERVICES Section 7 - DATA PROVIDERS’ USE OF SYSTEM AND SERVICES Section 8 - ASSOCIATED HARDWARE AND SOFTWARE TO BE PROVIDED BY HIO Section 9 - PRIVACY AND SECURITY OF PATIENT DATA Section 10 - BUSINESS ASSOCIATE AGREEMENT Section 11 - HIO’S OPERATIONS AND RESPONSIBILITIES Section 12 - GOVERNANCE Section 13 - FEES AND CHARGES Section 14 - PROPRIETARY AND CONFIDENTIAL INFORMATION Section 15 - DISCLAIMERS, EXCLUSIONS OF WARRANTIES, LIMITATIONS OF LIABILITY, AND INDEMNIFICATION Section 16 - INSURANCE AND INDEMNIFICATION Section 17 - TRANSPARENCY, OVERSIGHT, ENFORCEMENT AND ACCOUNTABILITY Section 18 - MISCELLANEOUS PROVISIONS Exhibit X – Business Associates Agreement Using the MMPA • The MMPA is a starting point. • Take from it what you can and leave what you can’t. • We have tried to identify the key sections that should be considered and suggested alternative language that may inform development of specific language for your Organization. • Your specific situation may require more sections or fewer depending on your specific offerings and relationships. • If the MMPA improves the community’s ability to communicate about these agreements it will have been a success. 28 What does Modular mean? Several things… • Given the spectrum represented by the different modes of exchange we would tend to expect that those modes on the higher end of the spectrum would have more Terms and Conditions relative to those on the lower end of the spectrum. • So the current framework attempts to be incremental in that it includes sections that may be unnecessary for some modes of exchange while for others it may be incomplete and additional terms and conditions specific to the HIO are warranted. • By including the word modular we intended to connote a vision of future releases of the MMPA with separate modules specific to service offerings or capabilities of HIOs that are currently undefined or still emergent. • We also expect the modular aspect of the MMPA to increase in the future as additional Participant Types are considered (Patients, Secondary Use, others) 29 Model Modular Participants Agreement • What is it for? • It is a reference point for HIOs that can be leveraged to draft or update existing Participant’s Agreements; and • A reference point for Participants use when they are presented with an agreement by an HIO; ultimately • It is a starting point to build from with your inputs • What is it not? • It is not a replacement for your own legal counsel nor is it to be construed as legal advice. It is a good example of the kinds of assets you should be able to find in OHLIE. Addressing Legal Barriers The Open Library of HIE (OLHIE) • OLHIE was a project originally funded by the ONC fostered leveraging Open Health Tools open source community processes • OLHIE is a repository of reusable HIE Assets such as interfaces, adaptors, use cases, tool-kits, policy artifacts and model contract language • OLHIE is currently migrating to live under NATE’s wing and will soon be the home of the MMPA among similar assets. The Open Library of HIE (OLHIE) • Streamline onboarding with NATE members • Serve as a common ground for States and Vendors to share assets and communicate ideas • Encourage contribution from the private sector • Provide community oriented, outward facing location to store and retrieve assets generated by NATE members and other HIT projects • Allow the community to vet and promote reusable assets, moving towards common practices • Encourage vendor transparency and good stewardship of the marketplace Addressing Legal Barriers The Open Library of HIE (OLHIE) • To learn more about OLHIE please visit – www.OHLIE.org • Or get in touch with NATE’s VP of Operations [email protected] To get the latest information related to the MMPA please visit: http://www.ohii.ca.gov/calohi/content.aspx?id=143 Addressing Policy Barriers Consent2Share Emerged from ONC’s Data Segmentation for Privacy (DS4P) Initiative VA-SAMHSA DS4P Pilot Consent2Share The ONC DS4P Initiative was launched in October 2011 to demonstrate, through pilot initiatives, the vision outlined by the December 2010 PCAST report on Health IT. Out of that report came the recommendation for the development of metadata tags which could be used to maintain privacy and security of patient health information throughout data exchange across organizational structures. It also advised that patients and providers be able to share portions, or segments, of records in order to maintain patient privacy. DS4P Achievements: • DS4P Implementation Guide • Pilot projects including VA-SAMHSA DS4P Pilot and this project http://wiki.siframework.org/Data+Segmentation Initiative Coordinator: Johnathan Coleman Addressing Policy Barriers Consent2Share ONC Data Segmentation for Privacy (DS4P) Initiative VA-SAMHSA DS4P Pilot Consent2Share One of the ONC DS4P pilot projects, the VA-SAMHSA DS4P Pilot, was a partnership between the Department of Veteran’s Affairs and SAMHSA which demonstrated, through a prototype implementation, the standards established in the DS4P Implementation Guide. The VA-SAMHSA DS4P Pilot prototype was demonstrated in September 2012 at HL7 and in the Interoperability Showcase at the March 2013 Annual HIMSS Conference. http://wiki.siframework.org/DS4P+VA-SAMHSA+Pilot Addressing Policy Barriers Consent2Share ONC Data Segmentation for Privacy (DS4P) Initiative VA-SAMHSA DS4P Pilot Consent2Share Building on the components and learnings from the VA-SAMHSA DS4P pilot, Consent2Share is being built as a production-grade system capable of implementing consent management, data segmentation and privacy enforcement in live environment. Consent2Share consists of two application area: Patient Consent Management and Access Control Services. C2S Patient Consent Management system is a patient-facing Consent Management User Interface which allows patients to define their privacy policy and provide informed consent. The C2S Access Control Service components are designed to integrate with Electronic Health Records systems (EHRs) and HIEs and provide privacy policy configuration, management, decision making and policy enforcement. The project is open source and source code is available at: https://github.com/OBHITA/Consent2Share Consent2Share Project Goal: Project Goal: Provide the capability for patients receiving behavioral health treatment to share their health information through the nation’s HIEs while providing meaningful choices for protection of their privacy Objectives of the Pilot: • Demonstrate the sharing of health records from a substance abuse treatment provider to a Primary Care using the Consent2Share toolset via local HIO • Demonstrate the application of patient privacy preferences with granular data segmentation options to patient medical records, through the standards developed by the ONC DS4P initiative • Demonstrate that patients can understand and manage their privacy preferences through Consent2Share • Evaluate patient and provider response to and acceptance of the Consent2Share tool • Evaluate how the Consent2Share tool can be implemented into the workflow of the provider organizations and the HIE while ensuring compliance with the broad requirements of 42 CFR Part 2 and applicable state laws, including restricting redisclosure of protected information Addressing Policy Barriers Consent2Share Consent2Share components: • Patient Consent Management – Patients enter their privacy preferences and provide consent. (front-end, patient facing) • Access Control Services – Integrates with HIE and enforces access to records and privacy policies. (back end control system) Addressing Policy Barriers Consent2Share Patient Consent Management • Consent2Share Patient Consent Management • Patient-facing Consent Management User Interface which allows patients to provide informed consent and specify a privacy policy. • Web-based, Responsive UI design allows access across devices (desktop, tablet and phone) • Key Features - Patients will be able to: • Learn about patient privacy options. • Define which providers they want to share their records with • Define their privacy policy and sign electronic consent. • Try their privacy policy against their actual health record. (not yet complete) • Receive/Send messages from providers who have, or want to establish, a sharing connection (not yet complete) Addressing Policy Barriers Consent2Share Access Control Services (ACS) • ACS set of integrated applications which are designed to integrate with EHRs and HIEs and provide privacy policy configuration, management, decision making and policy enforcement including data segmentation. • • • • • • • Policy Enforcement Point (PEP) Integration point Policy Decision Point (PDP) XDS.b Document Registry and Repository Segmentation Service Business Rules Management System to support jurisdictional and organizational privacy policy management Sensitive data value set terminology management Integration with HIE MPIs Addressing Policy Barriers Technical Overview - Components Addressing Policy Barriers Technical Overview – Data Flows Addressing Policy Barriers Currently in real world pilot Addressing Policy Barriers Consent2Share iterative expansion Nationwide Multi-state Today State-wide County Feel free to contact me if your interested in learning more or being part of future iterations with NATE! Addressing Policy Barriers CONSUMER-MEDIATED EXCHANGE • Consumer-mediated exchange provides patients with access to their health information, allowing them to manage their health care online in a similar fashion to how they might manage their finances through online banking. When in control of their own health information, patients can actively participate in their care coordination by: • Providing other providers with their health information • Identifying and correcting wrong or missing health information • Identifying and correcting incorrect billing information • Tracking and monitoring their own health Addressing Policy Barriers Addressing Policy Barriers Script 1: Easing the administrative burden on providers SCHIE Affiliated Provider Patient (NMC) SD Health Connect Affiliated Provider NATE Members SCHIE, SD Health Connect and NoMoreClipboard While visiting Santa Cruz patient Olive Trekker receives care from Dr. Earl Grey at Santa Cruz Hospital. Dr. Grey pushes encounter data to Olive’s NMC account. Direct Message Olive accesses her data via the NMC patient portal. Olive then pushes data to her San Diego provider, Nurse Chris Care, via SD Health Connect. Direct Message Nurse Chris Care receives Olive’s encounter data. 47 Addressing Policy Barriers Script 2: Wireless science leveraging micro and macro environmental data Direct Message Dr. Killeen receives comprehensive view of Gloria’s exposure and inhaler use. Direct Message Gloria’s HealthVault account is updated. Gloria pushes data to Dr. Killeen. HealthVault SD Health Connect Affiliated Provider Asthmatic patient Gloria Gilliam receives care from Dr. James Killeen at UCSD Medical Center. Dr. Killeen provides her with two asthma sensors. Gloria’s HealthVault account is updated following final visit. San Diego Health Connect Microsoft Azure Cloud Direct Message Macro Air Quality Data (Delphi) Azure Cloud integrates Gloria’s device data and macro environmental data from the Delphi Project. Aggregate data sent to Gloria’s HealthVault account. MS Proprietary Data Transfer (Not Direct Message) Patient NATE Members UCSD Health System, CitiSense, Propeller Health, HealthVault, SD Health Connect, Delphi Gloria receives and uses her CitiSense sensor and Propeller Health sensor. Device Data Transmitted to Mobile Phone (via Bluetooth) Gloria sends sensor data from her mobile phone to SD Health Connect in Microsoft Azure Cloud. Addressing Policy Barriers Script 3: Ensuring patient safety with mobile anytime/anywhere access to health records SD Health Connect Affiliated Provider Dr. Killeen transmits UCSD Epic C-CDA to Vet’s Humetrix iBlueButton app. Vet receives care from Dr. Killeen at UCSD Medical Center. Pre-Populated Data Humetrix iBlueButton Smartphone App Direct Message SCHIE Affiliated Provider NATE Members San Diego Health Connect and Humetrix iBlueButton MyHealtheVet CCD Medicare BB Record TriCare Online CCD Direct Message Data Pulled Direct Message The iBlueButton app provides an aggregated view of all data and enables the patient to annotate his records. Device to Device Secure Transfer OR Visual Sharing Dr. Smith has access to Vet’s current medical history when Vet receives care from Dr. Smith in SC. iBlueButton App is updated by receiving CCDA from Dr. Smith. Direct Message Dr. Smith transmits CCDA to Vet’s Humetrix iBlueButton app. Addressing Policy Barriers NATE’s Phase 2 PHR Call for Participation Read the ONC Buzz Blog http://nate-trust.org/phr-community-signup/ Addressing Technical Barriers NATE Providing Leadership User Advisory Group, Co-Chair – Dr. Rim Cothren (NATE’s CTO) Project Management Council, Project Lead – Aaron Seib (NATE’s CEO) Interested in getting involved? Want to register to keep informed? Go to: http://www.openhealthtools.org/connect-project-information/ Addressing Technical Barriers Identity Proofing at Scale - CSDII Consortium Private and public sector Individuals, Relying Parties, Identity Providers, Identity Proofers, Attribute Verifiers, Attribute Providers, Credential Service Providers, and Privacy Enhancing Technology Providers to include: Architecture Relying Party PETP IdP: Commercially Available AV: Attribute Verification User Services Business Requirements Trust Framework Policy Enforcement Claim Consolidation CSP Biometric (Something you are) CSP Device (Something you have) IdP: COI Specific AP: Attribute Provider CSP KBA (Something you know) SELF-ASSERTED STRONG STRONGER Attribute / Credential Authentication & Verification Identity Proofing Consolidated Claim Set Stronger Credential Stronger Authentication Strong Authentication Evolve Trust Framework & UX Use Cases • Patient Access to Electronic Health Record • Social IDP Verified Attributes (for patient matching) Two Factor Authentication • Provider Access to Health System • • Strong identity proofed Credential Multi-Factor Authentication Patient OAuth • • CSDII Provider Health Care System EHR Login EHR Web Application EHR Core Stay Tuned • Pilot Launch in May (Period of Performance: 6 months) • • Patient Access Use Case Provider Access Use Case • Solutions to enable stronger identity proofing are on their way!!! Recap – to learn more or get involved! Legal Barriers • To learn more about the MMPA and OLHIE please contact: [email protected] Policy Barriers • To learn more about Consent2Share please contact: [email protected] • Patient Mediated Exchange http://nate-trust.org/phr-community-signup/ Technology Barriers • CONNECT: Open Source Community http://www.openhealthtools.org/connect-project-information/ • CDSII • [email protected] How do you make the Universe Laugh? How do you make the Universe Laugh? Tell it your plans. But one thing is for sure - if it helps our families in the future – its all worth it to me. Community Discussion 61 Backup Trust Communities & Trust Bundles 1) Prospective members such as HISPs and PHRs must fulfill Trust Community requirements to join. HISP Federated Trust Agreement Certification/Accreditation Trust Organization Trust Profiles Trust Organization 2) As new members are approved by the Community, they supply their trust anchors to the Trust Organization. 3) Based on new members’ conformance to the Community’s Trust Profiles, the Trust Organization adds their trust anchors to one or more Trust Bundles. HISP Trust Organization Trust Bundle 63 Trust Communities & Trust Bundles Trust Organization 4) Trust Organization publishes Trust Bundles to Community web server. 5) Community members pull down Trust Bundles periodically at regular intervals. HISP A HISP B HISP C 6) A particular Trust Bundle contains the trust anchors of all the members of the Community that conform to a specific Trust Profile. By configuring their Direct Security/Trust Agents (STAs) to trust the anchors in a Bundle, Community members can successfully communicate with all other members within that Bundle. 64 Five modes of exchange; One Modular Model Participant’s Agreement Exchange Model #1 Conduit • The HIO provides for the transport of messages only. • Each Participant in the Exchange independently encrypts the PHI • HIO does not have access to Participant’s Private Key 65 Five modes of exchange; One Modular Model Participant’s Agreement Exchange Model #2 Model 1 + HIO has access to PHI • The HIO provides for the transport of messages; and • The HIO provides for the encryption of PHI and thus has access to unencrypted PHI; but • Does not modify nor retain data. 66 Five modes of exchange; One model Participant’s Agreement Exchange Model #3 Model 2 + HIO transforms data but does not retain • The HIO provides for the transport of messages; and • The HIO provides for the encryption of PHI; and • HIO has access to unencrypted PHI; and • Modifies it but does not retain data. 67 Five modes of exchange; One Modular Model Participant’s Agreement Exchange Model #4 Model 3 + the HIO retains data to provide other services • The HIO provides for the transport of messages; and • The HIO provides for the encryption of PHI; and • HIO has access to unencrypted PHI; and • Retains the PHI to provide other services such as patient matching 68 Five modes of exchange; One Modular Model Participant’s Agreement Exchange Model #5 Model 4 + the HIO performs analysis related to clinical data The HIO provides for the transport of messages; and provides for the encryption of PHI; and has access to unencrypted PHI; and Retains the PHI to provide other services; and Performs additional analysis to inform clinical decision making. 69