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From the Desk of Shreya Patel – TEFCA Update from MiHIN

The Sequoia Project, the entity charged with operationalizing the framework for national interoperability titled the Trusted Exchange Framework and Common Agreement (TEFCA), has released a Standard Operating Procedure (SOP) on how Individual Access Service Providers (IAS) and actors under the framework will have to respond to Individual requests for information. 

MiHIN was able to read through this SOP, which predominantly revolves around identity verification and the best practices IAS Providers must use when they receive requests from individuals. IAS Providers must have a credential service provider (CSP) that is approved by Sequoia Project as the RCE and the identity proofing must meet NIST IAL2 (Identity Assurance Level 2), which is defined under NIST SP800-63A. Additionally, the SOP delves into minimum and additional demographic categories IAS Providers are required and should use respectively.

What is perhaps most noteworthy about this SOP, however, is the guidance they have given on if Qualified Health Information Networks, Participants, and Sub participants are required to respond to all IAS requests. As an HIE or HIN, most entities have not been directly responsible for IAS requests due to the lack of direct relationships with individuals and identity verification concerns. Most requests are coordinated with the Providers or other entities connected to HIEs and HINs, who direct them to share the information for the individual. This would all change under TEFCA because the SOP states, if an actor under the framework receives a QHIN query that meets the demographic/ technical requirements above and has an acceptable patient match, they are required to respond with the Required Information per the Common Agreement, QTF, and Exchange Purposes SOP. The SOP also states, a responder’s patient match shall not require more than the demographic items listed above unless required by law. 

Under this new guidance, it will be imperative that entities participating in TEFCA, particularly those without the infrastructure to handle IAS requests, work with an IAS provider to meet these requests. 

For more information about TEFCA and this SOP please contact help@mihin.org Attn: Shreya Patel. 

Source: https://rce.sequoiaproject.org/wp-content/uploads/2022/09/Final-SOP-IAS-Exchange-Purpose-Implementation.pdf

MiHIN Can Help You Meet the HIE Objective!

On August 1, CMS issued the final 2023 Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) Rule, which MiHIN had provided extensive comments for earlier this summer.

 For those who are unaware of what the IPPS and LTCH PPS rules are, they are the way Inpatient and Long Term Care hospitals set prospective rates for hospital stays dependent on services provided. These rules are pertinent for our stakeholders because compliance with them dictates if they will be able to receive federal funding, which most organizations are heavily reliant on.

This year changes to the rule included the incorporation of measures on maternal health and adverse events during childbirth, dedicated measures on how an entity furthers Health Equity, Social Determinants of Health and Health Related Social Needs, a mandatory measure on queries to the Prescription Drug Monitoring Program (PDMP), and requests for information on incentives for participation in the Trusted Exchange Framework and Common Agreement (TEFCA).

While we would be happy to provide our comment letter and summary on the content of the rule itself, there is one area where we can directly help our stakeholders: The HIE Objective measure, worth 30 points of a hospitals score. There are three ways an entity care meet this score. The first option is to report on Sending and Receiving Health Information through Support of Electronic Referral Loops. The second option is to report on the HIE Bi-Directional Exchange measure. Most of our stakeholders used this measure last year, as it changed to a simple yes/ no response. MiHIN is able to supplement that response with an attestation letter stating they are connected to our HIE Network and engaged in bi-directional exchange. The third option is to report on the Enabling Exchange Under TEFCA measure, which again is a simple yes or no, but states the entity is a signatory under the TEFCA framework. This last option, although new, may be complicated without QHINs established to connect to but they do have requirements for what this would mean if stakeholders are interested in more information.

We urge our MiHIN stakeholders to reach out to us at help@mihin.org (Attn: Shreya Patel) if they require an attestation letter on the second option for the HIE Objective and if they have any additional questions on changes to the IPPS and LTCH PPS.

From the Desk of Shreya Patel – Privacy & Policy Updates from MiHIN

In the public policy space, two federal changes will affect the way health information is shared across different stakeholders.

In a landmark bill titled, the American Data Privacy and Protection Act, an emphasis is placed on a concept called “privacy by design.” This bill’s objective is to shift the burden of privacy onto entities who collect data as opposed to the patients themselves. It does this by prioritizing patient protections such as data minimization, ability to edit and correct information, the right to collect information on oneself, and prohibitions on advertising. While ADPPA would not preempt HIPAA, it would supplement it and apply to those organizations who may not be subject to HIPAA. MiHIN will be creating a brief for MiHIN Participant Organizations, which will be distributed in July 2022.

Also noteworthy is the continued emphasis on behavioral and mental health. In President Biden’s gun safety bill, healthcare was also emphasized through funding. This included increased funding for school health centers, behavioral health clinics, Pediatric Mental Health Care Access, screening, and treatment. The Senate Finance Committee intends to further work in the healthcare space with the introduction of bipartisan legislation. MiHIN will be tracking with these activities to ensure our products and services are adapted to the evolving behavioral health landscape.