Tuesday, May 15, 2012

The NwHIN Governance RFI

Last week ONC released the Nationwide Health Information Network: Conditions for Trusted Exchange Request for Information that will be published in the Federal Register today

Steve Posnack, Director of the Federal Policy Division, ONC presented this webinar using these slides

The work is part of the HITECH mandate that requires the National Coordinator to establish a governance mechanism for the nationwide health information network.

Key concepts in the presentation include a few new acronyms that we'll all be using over the next few years, so it's a good idea to memorize them now.

CTE - Conditions for Trusted healthcare information Exchange, the  “rules of the road” for participation

NVE - a nationwide health information Network Validated Entity, the organizations that adhere to operational and financial practice preconditions for participation in trusted exchange.

Of interest, the proposed conditions for trusted exchange include

Safeguards CTEs
[S-1]: An NVE must comply with sections 164.308, 164.310, 164.312, and 164.316 of title 45 of the Code of Federal Regulations as if it were a covered entity, and must treat all implementation specifications included within sections 164.308, 164.310, and 164.312 as “required.”
[S-2]: An NVE must only facilitate electronic health information exchange for parties it has authenticated and authorized, either directly or indirectly.
[S-3]: An NVE must ensure that individuals are provided with a meaningful choice regarding whether their IIHI may be exchanged by the NVE.
[S-4]: An NVE must only exchange encrypted IIHI.
[S-5]: An NVE must make publicly available a notice of its data practices describing why IIHI is collected, how it is used, and to whom and for what reason it is disclosed.
[S-6]: An NVE must not use or disclose de-identified health information to which it has access for any commercial purpose.
[S-7]: An NVE must operate its services with high availability.
[S-8]: If an NVE assembles or aggregates health information that results in a unique set of IIHI, then it must provide individuals with electronic access to their unique set of IIHI.
[S-9]: If an NVE assembles or aggregates health information which results in a unique set of IIHI, then it must provide individuals with the right to request a correction and/or annotation to this unique set of IIHI.
[S-10]: An NVE must have the means to verify that a provider requesting an individual’s health information through a query and response model has or is in the process of establishing a treatment relationship with that individual.

[I-1]: An NVE must be able to facilitate secure electronic health information exchange in two circumstances: 1) when the sender and receiver are known; and 2) when the exchange occurs at the patient’s direction.
[I-2]: An NVE must follow required standards for establishing and discovering digital certificates.
[I-3]: An NVE must have the ability to verify and match the subject of a message, including the ability to locate a potential source of available information for a specific subject.

Business Practices
[BP-1]: An NVE must send and receive any planned electronic exchange message from another NVE without imposing financial preconditions on any other NVE.
[BP-2]: An NVE must provide open access to the directory services it provides to enable planned electronic exchange.
[BP-3]: An NVE must report on users and transaction volume for validated services.

Reflecting on our Massachusetts Health Information Exchange strategic and operational plan, the stakeholders of the Commonwealth have outlined policies and technologies to address each one of these conditions.   It's my hope that Massachusetts will be an early adopter of this framework and will be one of the first NVE's to be certified.

As I've said in my lectures on the topic, our generation will be the one that solves the trust fabric problem, so that our grandchildren will grow up in a connected healthcare system.    The NWHIN Governance RFI provides the policies necessary to create and maintain the network of networks that will result in nationwide exchange.

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