As you may know, there has been a lot of activity lately related to the growth and development of RHIOs and the expansion of their mission from one where they are focused on hospital and medical data to a more central role in the administration of Health Homes and other multi-disciplinary networks. In New York, there are lots of RHIOs already in existence and at least some Health Home projects (or at least the funding applications for those Health Homes) envision repurposing the RHIO’s infrastructure for the data exchange requirements of the Health Home. Other Health Home projects appear to be looking to establish their own infrastructure and information exchange system separate from any RHIO. Of course, RHIOs are just one way a Health Home or other data sharing project can come into existence. Providers can also apply to be Health Homes and there are many Health Information Exchanges (HIEs or HIXs) that can serve that purpose. This flexibility in the Health Home model is important only because RHIOs are freestanding organizations and can and do go out of business. However, they are also clearly the easiest route to go because they are already there and this is what they were made for; and the National Health Information Network (a kind of national RHIO) is pushing their use for this purpose.
Few Health Home projects or RHIOs that we have spoken to have offered a final specification on what a data set would look like. In New York, some RHIOs appear to be closing in on the HEAL 17 data set as a starting point (using HL7 messaging to communicate), while others are looking to the CCD structure (using web services). However, this is quickly changing as NY State, at least, is ready to launch several Health Homes in October.
Additionally, the consent process thus far is quite varied from project to project. RHIOs we have spoken to have suggested a two-pronged process – consent to export and consent to access. Exporting data, in this scenario, is really not a “consent-able” event in that the Behavioral Health organization will export all clinical data into the RHIO or Health Home whether or not that data will ever be shared with anyone else. As a result, the RHIO (or whatever system the Health Home uses) can be thought of as a kind of data warehouse that is just storing copies of clients’ clinical records and no one else can see the data. When talking about actually sharing that data with other organizations, (which is the point, after all) consent will have to be obtained from the person consuming the services. To date, the only consent protocols we have heard about are blanket consents wherein the person consuming services either allows or denies access to his/her records by other organizations in the RHIO or Health Home. Our concern is only that this process be in compliance with 42 CFR part 2, as described by our association, SATVA.
Lastly, because all of this can be quite confusing for providers (and vendors!) there are many places to go and get help. In New York, one of those places is the Fund for Public Health, which has issued an RFI for software vendors in an effort to be able to guide service providers in the implementation of interoperable electronic health records. While this effort seems mostly focused on helping providers access Meaningful Use incentive funds, it can certainly be a resource moving forward.
In any event, Foothold is, as ever, on top of all the changes taking place in our little corner of the world and if you are a current client of ours, you can rest assured that whatever project you decide to participate in, be it a RHIO, or Health Home, or just an informal Health Information Exchange (HIE), Foothold will be there to make your participation as painless as possible.