certification / adoption workgroup

Larry Wolf, chairMarc Probst, co-chair

Certification / Adoption Workgroup

January 24, 201410:00 am ET

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Agenda

• Review of Agenda• HITPC Charge: Step Two

– Background Regarding Behavioral Health (BH) Providers ⁻ Who are BH providers?⁻ What is the clinical utility of EHRs to BH settings? ⁻ What is known about EHR adoption by BH providers?

– 5 Factor Framework – Considerations related for BH• Next Steps

– Virtual Hearing – ONC EHR Certification for BH, 01/28/14• Public Comment

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Call Schedule

Date Call Schedule 10/25/2013 Overview of new charge11/4/2013, 11/18/2013 Develop a framework for certification12/2/2013, 12/12/20131/10/2014, 1/17/2014, 1/21/2014

LTPAC EHR background presentation, virtual hearing, draft recommendations

1/24/2013, 1/28/2014,2/7/2014, 2/14/2014

BH EHR background presentation, virtual hearing, draft recommendations

2/21/2014, TBD Workgroup review and finalization of recommendations

3/11/2014 Recommendations to HITPC3/26/2014 Recommendations to HITSC

*Dates in red are changes from previous call schedule.

Presenters

Maureen Boyle, HHS/SAMHSA

Sue Mitchell, RTI International

Mike Lardieri, National Council for Community Behavioral Health

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SAMHSA’S STRATEGIC INITIATIVES

To reduce the impact of substance abuse and mental illness on America's communities

AIM: Improving the Nation’s Behavioral Health (1-4)AIM: Transforming Health Care in America (5-6)AIM: Achieving Excellence in Operations (7-8)

1. Prevention

2. Trauma and Justice

3. Military Families

4. Recovery Support

5. Health Reform

6. Health Information Technology

7. Data, Outcomes & Quality

8. Public Awareness & Support

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SAMHSA’s Strategic Initiative - Health IT

• Goal: Widespread Implementation of HIT Systems that Support Quality Integrated Behavioral Health Care for All Americans

– Ensure that behavioral health providers fully participate in the adoption and effective use of Health IT

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Value of a Voluntary BH EHR Certification

• Interoperability with broader healthcare system

• Confidence in the vendor and in a base level of functionality

• Promotion of data standards– Minimize data re-entry – Improve data quality for reporting– Support secondary uses such as research

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Value of a Voluntary BH EHR Certification

• Some providers are delaying adoption for fear that existing systems may become obsolete in this rapidly changing HIT environment.

• Behavioral health providers often exist at a near subsistence level and would not recover from the loss of such a large capital investment.

• SAMHSA would like to encourage BH providers to adopt EHRs that are interoperable with those being adopted by the broader healthcare system, without requiring BH providers or technology vendors to commit resources to develop functionality that is not required for their scope of practice.

• A voluntary certification program would provide a mechanism for us to verify that the EHRs purchased using federal funds meet a core set of standards.

Behavioral Health Providers

• Eligible providers: – Psychiatrists– Psychiatric nurse practitioners (only under Medicaid)

• Ineligible providers:Inpatient Ambulatory

Psychiatric hospital/unit (including substance abuse)Residential treatment centers for mental health and/or substance abuse

Clinical psychologistClinical social workerLicensed therapists and counselorsCommunity mental health center (CMHC)Opioid treatment programsMarriage and Family TherapistsSubstance use counselors

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Considerations for structure of a voluntary certification program for BH

• Diverse provider types with diverse workflows– Prescribers- psychiatrists, psychiatric nurse

practitioners– Therapy or counseling focused practice– Opioid treatment programs– Residential mental health or substance abuse

programs– Social work- integration with social services, housing,

criminal justice, etc.– Integrated care settings

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Privacy and Confidentiality Requirement

• 42 CFR Part 2: The purpose of the statute and regulations prohibiting disclosure of records relating to substance abuse treatment, except with the patient's consent or a court order after good cause is shown, is to encourage patients to seek substance abuse treatment without fear that by doing so their privacy will be compromised

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• Patient consent must be obtained before sharing information from a substance abuse treatment facility that is subject to 42 CFR Part 2 or Title 38 (VA) with limited exceptions such as medical emergencies

• Consent must include purpose of use• Prohibition on re-disclosure without consent

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Other Federal and State Laws

• 42 CFR Part 2 sets a minimum standard for protecting and security protected health information (PHI). If the state law is more restrictive then the state law governs.

• Mental health records may be treated as ultra-sensitive in many jurisdictions.

• Each state approaches the confidentiality of mental health records from their own perspective

• Systems have to recognize this variability in state statutes and regulations.

• HIPAA self-pay rule

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• Standards for communicating privacy policies and obligations– Developed through DS4P Initiative– Just balloted at HL7– http://

www.hl7.org/ballots/recirculation/info.cfm?recirc_id=783

• All EHRs need to be able to control the re-disclosure of protected information

http://www.hl7.org/ballots/recirculation/info.cfm?recirc_id=783



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Considerations for structure of a voluntary certification program for BH

• Flexible program to meet the needs of diverse provider types– Modular (provider organizations can make

recommendations related to which functional modules are core for specific provider types)

• Or, a program focused on the needs that are core to all– Core BH functionality (core to all BH provider types)– Core for all healthcare providers (interoperability,

privacy and security, etc.)

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Example of Modular Certification Program

• Psychologists- A, C, D, E• Psychiatrists- A, B, C, D, E, F

• Housing and Urban Development- A, C

AINTEROPERABILITY

SECURITYDEMOGRAPHICS

D PATIENT

COMMUNICATION

E CLINICAL QUALITY MEASUREMENT

FLABS AND IMAGING

CASSESSMENTS

BPRESCRIBING

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History of efforts to develop a BH Certification

• In early 2013 SAMHSA began working with ONC to develop sub-regulatory guidance to support a voluntary BH certification program

• Based on core Meaningful Use certification criteria that apply across all behavioral health provider types

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Elements of a BH Core

• Criteria from MU2– Interoperability– Documentation– Integration of care– Privacy and Security– Healthcare quality improvement– Patient communication– Software Quality Assurance

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Core MU2 criteria for BH

Behavioral Health Relevant EHR Certification CriteriaClinical quality measures § 170.314(c)(1) – (2) End-user device encryption § 170.314(d)(7)Demographics § 170.314(a)(3) Integrity § 170.314(d)(8)Problem list § 170.314(a)(5) Electronic notes § 170.314(a)(9)Medication list § 170.314(a)(6) Smoking status § 170.314(a)(11)Medication allergy list § 170.314(a)(7) Family health history § 170.314(a)(13)Clinical decision support § 170.314(a)(8) Patient list creation § 170.314(a)(14)Transitions of care § 170.314(b)(1) & (2) Patient-specific education resources § 170.314(a)

(15)Data portability § 170.314(b)(7) Clinical information reconciliation § 170.314(b)(4)Authentication, access control, & authorization § 170.314(d)(1)

View, download, & transmit to 3rd party § 170.314(e)(1)

Auditable events & tamper resistance § 170.314(d)(2)

Clinical summary § 170.314(e)(2)

Audit report(s) § 170.314(d)(3) Secure messaging § 170.314(e)(3)Amendments § 170.314(d)(4) Safety-enhanced design § 170.314(g)(3)Automatic log-off § 170.314(d)(5) Quality management system § 170.314(g)(4)Emergency access § 170.314(d)(6)

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MU Criteria not core to BH

• Criteria were excluded that support functions that are not core for a majority of ineligible behavioral health providers. These include core functions and associated criteria:

• Prescribing: The majority of ineligible behavioral health providers do not have prescribing authority therefore these criteria were not included:– Computerized provider order entry § 170.314(a)(1)– Drug-drug, drug-allergy interaction checks § 170.314(a)(2)– Drug-formulary checks § 170.314(a)(10) – Electronic medication administration record (eMAR) § 170.314(a)(16)– Electronic prescribing § 170.314(b)(3)– Safety-enhanced design § 170.314(g)(3)

• Labs and imaging: Ineligible BH providers typically do not rely on labs test or radiology. There are ineligible BH providers who capture lab tests for urinalysis and other purposes however we are focused on the core set that apply to the vast majority of ineligibles.– Image results § 170.314(a)(12)– Incorporate lab tests & values/results § 170.314(b)(5)– Transmission of electronic lab tests & values/results to ambulatory providers §

170.314(b)(6)– Transmission of reportable lab tests & values/results §170.314(f)(4

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MU Criteria not core to BH

• Collecting vital signs– Vital signs, BMI, & growth charts § 170.314(a)(4)

• Reporting to immune and cancer registries– Immunization information § 170.314(f)(1)– Transmission to immunization registries § 170.314(f)(2)– Cancer case information § 170.314(f)(5)– Transmission to cancer registries § 170.314(f)(6)

• Syndromic surveillance– Transmission to public health agencies – syndromic surveillance § 170.314(f)(3)

• Implementing advanced directives– Advance directives § 170.314(a)(17)

• Other criteria were excluded that support functionality specific to the Meaningful Use EHR program including:

• Reporting to CMS– Clinical quality measures § 170.314(c)(3)

• Calculation of MU objectives– Automated measure calculation § 170.314(g)(2)

HIT/HER Adoption Rates

HIT/EHR Adoption Rates for BH Providers

Ineligible Provider Use an EHR?

Adoption Rates of Basic(non-certified) EHRs for

Some Clinical ProcessesBehavioral Health Clinical Social Workers Yes UnknownCommunity Mental Health Centers

Yes 21% adopted some form of EHRs at all sites, 65% adopted some form of EHRs at some sites, 2% report adopting a base EHR that can meet Meaningful Used

Psychiatric Hospitals/Units 2%b

Clinical Psychologists Yes UnknownResidential Treatment Centers (Mental Health and/or Substance Abuse)

Yes Unknown

HIT/EHR Adoption Rates for Behavioral Health Providers

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Patients Served by Ineligible Providers/Hospitals

• Inpatient Psychiatric Hospital including substance abuse: 1,909,238;

• Residential Treatment Centers including subtance abuse: 314,393;

• Clinical Psychologist/Social Worker: 9,929,900; • Community Mental Health Clinic: 6,000,000 • Total: 18,152,631

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Behavioral Health Provider Use of EHRs in Practice

Behavioral Health EHR Use

Use in practice - ADT- Appointments- Clinical notes- Assessments- Care plan- Condition-specific

documentation- Medication and

treatment records

- Patient portals- Patient eligibility

determinations- Billing- Staffing, payroll, and

Human Resources

• Significant variability across provider types

From Other Provider Study:

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HIT Adoption in Community BH

• In 2012 the National Council for Community Behavioral Healthcare conducted a survey of HIT Adoption and Meaningful Use Readiness in Community Behavioral Health settings

• Survey was completed by more than 500 community mental health and addictions treatment organizations

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5 Factor Framework

• Advance a National Priority or Legislative Mandate: Is there a compelling reason, such as a National Quality Strategy Priority, that the proposed ONC certification program would advance?

• Align with Existing Federal/State Programs: Would the proposed ONC certification program align with federal/state programs?

• Utilize the existing technology pipeline: Are there industry-developed health IT standards and/or functionalities in existence that would support the proposed ONC certification program?

• Build on existing stakeholder support: Does stakeholder buy-in exist to support the proposed ONC certification program?

• Appropriately balance the costs and benefits of a certification program: Is certification the best available option? Considerations should include financial and non-financial costs and benefits.

When evaluating whether to establish a new certification program, ONC should consider whether the proposed certification program would:

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Advances National Priority

• Advance a National Priority or Legislative Mandate: Is there a compelling reason, such as a National Quality Strategy Priority, that the proposed ONC certification program would advance?

Factor #1

• National Quality Strategy• National Behavioral Health Quality Framework• Health Reform

– Integration of care– Shared savings programs

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NBHQF and NQS

• 3 Aims: Better Care, Healthy People/Healthy Communities, Affordable Care.

• 6 Priorities – – Evidence-based practices– Person-centered care– Coordinated care– Healthy living for communities– Reduction of adverse event– Cost reductions

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Prevalence of BH Disorders

http://www.samhsa.gov/data/2012BehavioralHealthUS/2012-BHUS.pdf


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Need for HIE in Behavioral Health

• On average, Americans with major mental illness die 14 to 32 years earlier than the general population.

• Average life expectancy ranged from 49 to 60 years of age in the states they examined compared to 77.9 years for the general population

• Due to physical health problems— cancer, heart disease, stroke, pulmonary disease, and diabetes

• More likely to suffer chronic diseases associated with addiction (especially nicotine), obesity, and poverty

• People with a mental illness are more than twice as likely to smoke cigarettes and more than 50 percent more likely to be obese compared to the rest of the population

• Study suggested that implementing a collaborative care approach for depression in the Medicare system would result in cost savings of approximately $15 billion annually.

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Co-morbidities of Chronic Conditions

National Comorbidity Survey Replication, 2001-2003 as Reported in Druss and Walker, 2011

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Exhibit 7

http://www.chcs.org/publications3960/publications_show.htm?doc_id=1058416

http://www.chcs.org/publications3960/publications_show.htm?doc_id=1058416

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Costs Associated with Comorbid Chronic Physical and Behavioral Health Disorders

Center for Health Care Strategies, Inc., Dec 2010, www.chcs.org/usr_doc/clarifying_multimorbidity_patterns.pdf

http://www.chcs.org/usr_doc/clarifying_multimorbidity_patterns.pdf

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Figure 3.3



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30-Day Readmissions by Major Diagnostic Category (MDC)

Among 15 states, behavioral health discharges ranked among the top 5 diagnostic categories for 30-day readmissions.

Agency for Healthcare Research and Quality (AHRQ) Health Care Utilization Project Statistical Brief #89, 2010

Medicaid recipients Age 21-64, 2007

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Potentially Preventable ReadmissionsNew York State Medicaid Program, 2007

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Need for HIE in Behavioral Health

• Multiple studies have shown that readmission rates can be reduced with care coordination

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Prevalence of BH Conditions among MedicaidExpansion Population

CI = Confidence Interval Sources: 2008 – 2010 National Survey of Drug Use and Health 2010 American Community Survey

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Prevalence of BH Conditions among Exchange Population

CI = Confidence Interval Sources: 2008 – 2010 National Survey of Drug Use and Health 2010 American Community Survey

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Potential Benefits of HIT/HIE in Behavioral Health Settings

• Efficiencies• Patient safety• Patient and family engagement• Data analytics (e.g., population management,

resource requirements, etc.)• Quality, coordination, and cost improvements• Data re-use• Competitive in marketplace

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Factor 1 Conclusions

• Use of CEHRT by BH providers has the potential to improve HIE, improve quality, continuity, and coordination of care, and enhance safety in BH settings.

• HIT is a critical tool to support many elements of health reform and new service delivery models .

• Success will depend on:– Adopting criteria that supports critical functionality– Alignment with existing health IT standards– Extent of use within BH EHR products– BH provider acquisition and use of certified products that

supports the needed functionality

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Align Fed/State Programs

• Align with Existing Federal/State Programs: Would the proposed ONC certification program align with federal/state programs?

Factor #2

• Standardized screening and assessment tools• Foundation for using the EHR transport

standards for federal and state reporting• Quality measurement program standards

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Behavioral Health – Federal and State Mandated Assessments

• Assessments support multiple purposes: screening, assessment and care planning, outcome tracking, payment, quality monitoring/reporting, and/or survey and certification activities.

• Generally, data elements, while similar, are not equivalent across instruments

• State reporting- Each state has specific reporting requirements– E.g. Child and adolescent functional assessment scale (CAFAS) in

Michigan, Alaska Screening Tool (AST); Client Status Review (CSR) in Alaska

– Also county specific requirements

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Behavioral Health – Federal and State Mandated Assessments

• HL7 Implementation Guide for CDA : Patient Assessments– http://www.hl7.org/implement/standards/product_br

ief.cfm?product_id=21

• Foundation for using the EHR transport standards for federal and state reporting– SAMHSA grants– CMS– HUD– CJ

http://www.hl7.org/implement/standards/product_brief.cfm?product_id=21

http://www.hl7.org/implement/standards/product_brief.cfm?product_id=21

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Quality and Performance Measure Reporting

• Quality measurement programs– Inpatient Psychiatric Facility Quality Reporting (IPFQR)– The Joint Commission’s Hospital-Based Inpatient

Psychiatric Services (HBIPS)– The Joint Commission’s Substance Abuse Measure set– ACO Data Reporting Requirements

• SAMHSA government performance reporting (GPRA)• State Medicaid reporting• Push to use of electronic quality and performance

measures– Reduce re-entry– Improve quality of data

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Programs Supporting HIT/HIE Behavioral HealthNew service delivery models• ACOs • Bundled payment models• Balancing Incentive Programs (LTSS & HCBS)• Medicaid Health Home State Plan Option (Patient-Centered

Medical Homes (PCMHs)• Community-Based Care Transitions Program • State Innovations Models (SIMs)• SAMHSA/HRSA PBHCI• Hospital Readmission Reduction Program• Parity• Medicaid expansion (% with BH disorders)• Medicare Physician Fee Schedule Enhancements

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ONC Certification & Alignment with BH QM Requirements

• ONC Certification program will not (on its own) address/resolve:– The lack of policy alignment between CMS and

ONC submission/transmission requirements– The lack of alignment in reporting requirements

between federal and state programs– The proliferation of non-aligned QMs across the

care continuum

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• Identification and inclusion of key EHR certification criteria and functions in a voluntary BH EHR certification program could provide a foundation for alignment of Federal/State Programs

• Implementation of a voluntary EHR certification program in BH could create efficiency gains, permit re-use of data, and enable/support quality improvement and care coordination activities/efforts at Federal, State, and provider levels

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UtilizePipeline

• Utilize the existing technology pipeline: Are there industry-developed health IT standards and/or functionalities in existence that would support the proposed ONC certification program?

Factor #3

• Use of existing certification processes• Re-use of and alignment with current MU

certification criteria

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BH Standards & Certification Efforts

SAMHSA, with contractor RTI International, has undertaken a comparative analysis of existing BH EHR requirements and ONC 2014 EHR Certification requirements• Source documents include:

– HL7 EHR-S Behavioral Health Functional Profile (Dec. 2008)– CCHIT EHR Certification 2011 – Behavioral Health– APA EHR Functionality Requirements document

• Comparative spreadsheet provides detailed mapping of BH EHR requirements from HL7, CCHIT and APA to the ONC 2014 EHR Certification requirements– File is posted with meeting materials

• BH SMEs provided input on EHR requirement mapping and high priority functionality for BH providers

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HL7 EHR-System BH Functional Profile (EHR-S BH FP), Release 1 (December 2008)• Based on 2007 HL7 EHR-System Functional Model

(EHR-S FM), Release 1 – EHR-S FM is a reference list of functions that may be

present in an EHR system• EHR-S BH FP identifies a subset of functions from the

EHR-S FM that reflects the unique aspects and needs for an EHR-S in the BH setting

• Both the EHR-S BH FP and EHR-S FM are ANSI approved standards

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Certification Commission for Healthcare Information Technology EHR Certification 2011 – BH (CCHIT Certified 2011 BH)• Private sector EHR certification program for BH products

created in response to BH stakeholder community• Offered beginning July 2010, BH certification programs were

new for the CCHIT 2011 testing cycle– Two BH certification programs:

• Certify standalone BH EHRs used in outpatient setting• Optional BH certification for CCHIT certified Ambulatory EHRs

(addresses the BH specialty in the ambulatory setting)– Applied criteria from the HL7 EHR-S BH FP– Contains core BH requirements for functionality, interoperability and

security

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American Psychiatric Association (APA) EHR Requirements Document (October 2012)• Developed by APA EHR Committee• Contains requirements for:

– EHR User (functions psychiatrist or staff would access in the normal course of daily work)

– EHR System (aspects of the EHR which operate behind the scenes to ensure its ongoing integrity)

• Includes an “Overall Components Setting/Priority” that indicates settings where the component is applicable, along with its associated priority for those settings

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Differences in Functional RequirementsWithin Behavioral Health ArtifactsAttributes of Functional

RequirementsHL7 Behavioral Health

Functional ProfileCCHIT Certification Criteria APA Functional

RequirementsApproximate number of functional requirements

Approx. 186 functions with roughly 1087 criteria

Approx. 43 categories of functionality with roughly 300 criteria

7 major functions each for user requirements & system requirements, with approx. 54 subfunctions

Functional requirement expressed as

Conformance criteria Certification criteria User requirement or system requirement

Functional requirement is testable

Yes Yes No

Level of optionality of functional requirements

Required (SHALL) and optional (SHOULD or MAY)

Required (SHALL) only Required/optionality concept not present; requirements are prioritized as Essential, Important, or Nice to Have

Example of a functional requirement for Family History

The system SHALL provide the ability to capture, update and present current patient history including pertinent positive and negative elements.

The system shall provide the ability to capture, store, display, and manage patient history. CCHIT Comments: Examples include past medical/surgical problems, diagnoses, procedures, family history and social history.

Ability to save draft and re‐edit prior to electronically signing.

Conceptual View of the Gap Analysis Map(Family History Example)

MU2 - Menu Objectives HL7 Behavioral Health Functional Profile

CCHIT Certification Criteria APA Functional RequirementsEP - §495.6(k)(2)(i); EH/CAH - §495.6(m)(3)(i)

Requirements That Are Aligned with ONC 2014 Certification CriteriaEHR Certification Criteria - Complete EHR§ 170.314(a)(13)Family health history. Enable a user to electronically record, change, and access a patient’s family health history

The system SHALL provide the ability to capture, update and present current patient history including pertinent positive and negative elements.

The system shall provide the ability to capture, store, display, and manage patient history. CCHIT Comments: Examples include past medical/surgical problems, diagnoses, procedures, family history and social history.

Ability to save draft and re edit prior to ‐electronically signing.

The system MAY provide the ability to capture the relationship between the patient and others.

The system shall provide the ability to capture patient history as both a presence and absence of conditions, i.e., the specification of the absence of a personal or family history of a specific diagnosis, procedure or health risk behavior.CCHIT Comments: Methods of capturing data as defined in BH.024.

No changes after electronically signed.

The system MAY provide the ability to present external patient histories that resided originally outside the EHR-S.

Ability to print hardcopy or send electronically.

The system SHALL capture the complaint, presenting problem or other reason(s) for the visit or encounter.

The system SHOULD capture the reason for visit/encounter from the patient's perspective.

Requirements That Are NOT Aligned with 2014 Meaningful Use Certification Criteria Statement 1 Statement 1

Statement 2 Statement 3 Statement 1

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HL7 BH EHR-S Functional Profile and CCHIT Certified 2011 BH - Issues and Themes

#1: Health IT Standards Identified in ONC 2014 EHR Certification Criteria are not found in BH EHR-S criteria• BH EHR-S criteria (HL7, CCHIT, APA) generally do not identify

specific health IT standards (e.g., vocabulary standards, content exchange standards, transport standards)– Often when standards are referenced, they are named as examples

rather than being specifically required thru conformance criteria.• The few BH EHR-S criteria requiring specific health IT

standards are out of sync with ONC requirements– Some BH criteria require summaries to be formatted using the HITSP

C32 standard whereas ONC 2014 criteria require summaries to be formatted using the HL7 Consolidated CDA standard

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HL7 BH EHR-S Functional Profile and CCHIT Certified 2011 BH - Issues and Themes

#2: Bi-directional gaps in requirements• ONC 2014 EHR certification requirements not found in BH

EHR-S criteria, including:– BH EHR-S criteria do not include key criteria related to recording the

encryption status of end-user devices (e.g., USB flash drive)– BH EHR-S criteria do not specify transport standards for transmitting

summary care records• BH EHR-S requirements not found in ONC 2014 EHR

certification criteria, including:– Create and manage patient assessments– Support coding with DSM (Diagnostic and Statistical Manual –

classification system for mental disorders)– Explicit access and disclosure safeguards required for patient

information related to substance abuse

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BH EHR Products

• SAMHSA evaluated the BH EHR market in early 2012 and identified approximately 100 EHRs marketed to BH providers

• Of those approximately 20% were meaningful use stage 1 certified

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New Health IT Standards that Support HIE in and with BH

• HL7 Version 3 Domain Analysis Model: Summary Behavioral Health Record, Release 1 – US Realm.

• HL7 Version 3 Standard: Privacy, Access and Security Services; Security Labeling Service, Release 1

• HL7 Implementation Guide: Data Segmentation for Privacy (DS4P), Release 1

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• Private sector efforts regarding BH EHR functional requirements and certification have not been updated and are not aligned with requirements in the 2014 ONC Ed.

• Private sector efforts typically do not identify specific HIT standards in their conformance criteria

• HL7 CCHIT BH Program contain requirements tailored to the BH environment that are not found in the ONC 2014 Ed. (e.g., assessments, DSM coding)


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Stakeholder Support

• Build on existing stakeholder support: Does stakeholder buy-in exist to support the proposed ONC certification program?

Factor #4

• Stakeholder feedback• Federal Stakeholders

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Stakeholder Support

• In response to the HHS/Request for Information (RFI) on Accelerating HIE, multiple stakeholders (i.e., BH providers and associations, physician and hospital providers and associations, vendors, health information associations, standard development organizations, states and state associations, health information exchange organizations, researchers, others) expressed strong support for:– An EHR certification program for BH

• varying comments from need for basic interoperability certification to more extensive program to guide the purchase of EHR products that address the clinical processes and information needs of BH providers.

– Developing standards to address compliance with federal and state privacy requirements including 42CFR Part 2

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• Stakeholder support expressed for:– Standards for consent management– Standards for computable privacy obligation codes– Using available levers to ensure that BH providers

can be included in HIE efforts– Focus on key areas that are barriers to integration

of care– Alignment of state privacy policies to allow for

national standard for EHR functionality related to privacy and confidentiality

Stakeholder Support (cont’d)

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• The HIT Policy Committee recommended:

• Require (if possible) or facilitate (if not) voluntary certification of technology used by providers ineligible for meaningful use, in alignment with MU requirements

• ONC should harmonize the care plan requirements so that MU eligible providers are able to receive care plans from non-MU eligible providers (e.g., NFs)

• CMS-required documentation should be harmonized to the C-CDA: MDS, OASIS and Care Tool, HH PoC (CMS 485) and IRF-PAI

Stakeholder Support (cont’d)

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• Near unanimous support was expressed in response to the RFI for:– Extending the interoperable HIT/HIE infrastructure

to BH providers– Aligning the HIT/HIE infrastructure across the care

continuum– Extending the HIT/HIE infrastructure to include

standards needed for BH• Strong stakeholder support for a voluntary

EHR certification program for BH

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Cost/ Benefit

• Appropriately balance the costs and benefits of a certification program: Is certification the best available option? Considerations should include financial and non-financial costs and benefits.

Factor #5

• Cost/Benefit Considerations

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Implementing a Voluntary EHR Certification Program for BH: Considerations

Challenges: • Key Standards: Identifying the right balance for

promoting key standards and functionality while promoting innovation

• Accelerating Use of Certified EHR Products: Leveraging policies and programs to encourage the effective use of certified EHR products to achieve priorities

• Requirements within federal grant programs• Alignment of standards across programs, increase value by

reducing data collection burden (HMIS, state reporting)• Include ineligible providers in technical assistance programs

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Implementing a Voluntary EHR Certification Program for BH: Considerations

• Priorities– Interoperability– Privacy and Security

• Feasibility of a staged approach– Short term focus on interoperability, privacy and security– Medium term focus on quality measurement,

assessments, etc.– Long term focus on data standards, elimination of re-entry,

secondary uses, etc.

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Implementing a Voluntary EHR Certification Program for BH: Cost/Benefit Considerations • If a voluntary EHR Certification Program for focused on core standards for

interoperability, privacy and security: – Number of EHR products available to support interoperable HIE across the

continuum could increase– Integrity of the system and privacy and security data could be enhanced – Costs of EHR products that include needed standards and functionality could

decrease • A more extensive voluntary EHR certification program could serve as the

foundation for:– BH vendors product enhancements – the standards and functions included in a

voluntary certification program could be the base for additional information systems enhancements.

– BH provider EHR acquisition decisions – a voluntary certification program could reduce provider uncertainty and confusion regarding EHR acquisition decisions.

– Policy decisions by payers/regulators – use of certain/all functions and standards included in certified EHR technology could: (i) support several policy priorities (i.e., improve quality/coordination of care/interoperable HIE and reduce costs) and (ii) be supported through various policy decisions

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• The value proposition of implementing a voluntary EHR certification program for BH providers will be a function of:– Implementation– Utility of criteria to BH providers– Applicability of criteria across diverse BH provider types – Whether identified criteria supports policy objectives– Whether specified criteria supports continuing technology

enhancements and innovations

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Questions?

• Contact Information:[email protected]

[email protected]

[email protected]

mailto:[email protected]



certification / adoption workgroup

Documents

behavioral health bh

bh ehr background presentation

ehr adoption

medicaidineligible providers

providers ineligible

bh settings

ehr payment incentives

data quality