Last week, the California Health and Human Services Agency (CalHHS) released its long-awaited Data Exchange Framework, Data Sharing Agreement and initial set of policies and proceduresin accordance with Assembly Bill 133 requirements.
Along with the statutory requirement to publish the Data Sharing Framework, Data Sharing Agreement, and Policies and Procedures by July 1, the agency is using guidance from the CalHHS Data Sharing Framework Stakeholder Advisory Group to release a set of policy recommendations for the state to use as a road map for implementing a robust and efficient statewide health information exchange system. These include creating incentive programs for health organizations and strict standards for the collection and use of data on demographic and social determinants of health (SDOH).
Some key recommendations are listed below.
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Create an electronic health record (EHR) incentive program.
This incentive program would encourage the adoption of certified EHR and clinical documentation technologies among healthcare organizations, as many healthcare and human services organizations in California do not have the resources to invest in digital records systems that are necessary for effective healthcare exchange. information.
Establish an adaptation data exchange and technical assistance program
Many health and human services organizations will encounter technical, operational, and financial barriers to establishing relationships with data brokers. This program will provide funding, incentives and technical assistance to help these organizations connect with a qualified data broker.
Extend existing event notification requirements
Event notifications of changes in an individual’s condition (such as admission to, discharge from, or transfer to a health facility) to an individual’s practitioner or care team can be used to assist in the coordination and delivery of care. However, these notifications are often limited to a narrow set of participants and circumstances. CalHHS recommends that the State determine policies to expand the scope of existing event notification requirements to include additional health and human services organizations and notification types.
Upgrade California County Health Information Technology (HIT) infrastructure
California health, public health, and human services agencies have various options for electronic exchange of relevant information with other health and human service organizations. CalHHS recommends that the state expand federally funded programs to upgrade the information technology infrastructure for state and local health, public health, and human services so that these organizations can more easily participate in health information exchange.
Establish demographic and SDOH data collection and use standards, requirements and incentives
Standardized demographic and SDOH data in California remain inconsistent and often incomplete. CalHHS recommends that the State establish standards, requirements, and incentives for demographic and SDOH data to encourage the collection, exchange, and use of data among California health and human services organizations. CalHHS also recommends that the state improve the exchange of demographic and SDOH data between state agencies, as well as send recommendations to the federal government to improve national SDOH and demographic data exchange standards.
Create vendor directory and data reporting requirements
Reliable provider information, such as name, practice locations, and organizational affiliations, is not always available or accessible for all health and human services organizations across the state. CalHHS recommends that the state establish a statewide directory of providers and require signatories to the Data Sharing Agreement to provide data to promote provider-to-provider communication and health information exchange.
Establishing policies to ensure individuals have access to their longitudinal health information and policies to strengthen the trust of data sharers
Individuals often face challenges when trying to access their health and human services records in a convenient way. CalHHS recommends that the state establish policies to ensure that individuals have timely and convenient access to their health information at all health and human service organizations that are compliant with the Data Sharing Agreement. Constant access to this information will allow Californians to make informed decisions about their health care.
Create a “one-size-fits-all” data release authorization form, implement electronic consent management, and promote federal and state regulatory compliance
CalHHS is recommending that the state create a “universal” information release authorization form to enable standardized data exchange, as well as an electronic consent management service that will allow people to digitally manage their information sharing consents for their health and human services. CalHHS also says the state should make efforts to align federal and state information sharing requirements.
Use government, private and philanthropic sources of funding
Many health and human services organizations face significant financial barriers to making the necessary investments for health information exchange. CalHHS recommends that the State identify and pursue federal, state, private, and philanthropic funding opportunities to fund data sharing efforts, such as enhanced CMS Medicaid Enterprise Systems funding, CMS Medicaid matching funds, CMS Medicaid waivers, and state taxes.
CalHHS and the California Association of Counties are required to encourage as many county health, public health and social service providers as possible to participate in the data exchange framework by January 31, 2023. Multiple organizations, including gGeneral acute care hospitals, physician organizations and medical groups, skilled nursing facilities, health service plans and disability insurers, Medi-Cal managed care plans, clinical laboratories and psychiatric hospitals will also be required to implement the Data Sharing Agreement by 31 January 2023
The full implementation date is January 31, 2024, when, according to CalHHS, all participating entities will exchange health information or provide access to health information to and from any other entity in real time for treatment, payment or health operations.