Massachusetts Medical Society: Coming Soon: Sharing More Health Data via the Mass HIway

Coming Soon: Sharing More Health Data via the Mass HIway

Coming Soon: Mass HIway Interoperability Mandate

This summer, the Massachusetts Executive Office of Health and Human Services (EOHHS) will implement the attestation process for a 2012 legislative mandate regarding the interoperability of electronic health records (EHRs). Practices affected by this mandate will be required to attest by July 1st, 2018.

Background on the Mandate and the Mass HIway

This mandate was passed by the Massachusetts legislature as part of a comprehensive health care cost reform in 2012. Regulations were promulgated by the Executive Office of Health and Human Services in 2017, and are now being implemented. The MMS opposes the mandate, and staff will continue our advocacy efforts to minimize the burdens on physicians. The mandate, as interpreted via regulations, places an emphasis on interoperability through connection to the state Health Information Exchange (HIE), often referred to as the Mass HIway.

The Mass HIway is a statewide secure health information exchange that is accessible to all healthcare systems statewide, regardless of affiliation, location, or differences in technology. The Mass HIway allows for several options for connection to the exchange, including a secure email system available to medical professionals (MD, NP, PA) to exchange information, as well as direct connection to the Mass HIway which can interface directly with the participant’s EHR.

Provider organizations that have required dates for connecting to the Mass HIway must annually submit information regarding: 1) whether or not they have an EHR; 2) how their EHR, if any, connects to the Mass HIway; and 3) information regarding their use of the Mass HIway in order to comply with the annual connection requirement.

   

Is My Practice Affected?

Please note that the mandate does not apply to individual physicians, but rather to physician practices.

At the strong urging of the MMS, the requirements for interoperability have been tailored by practice size; small ambulatory practices are presently excluded.

Small ambulatory practices are defined as employing fewer than 10 physicians,  nurses, and/or PAs. Please note that this determination does not take FTE into account: a practice employing two physicians who each work 0.5 FTE must count those physicians as 2 licensed care providers, not 1.

 

What Do I Need to Do to Comply?

As of July 1, 2018, practices with 10 or more licensed professionals (MD, PA, NP), are required to attest to having achieved interoperability via the Mass HIway in a regular, meaningful way. The regulations define sufficient use as: regularly fulfilling at least one “use case” using connection to the Mass HIway.

A medium or small physician practice must therefore establish a process for their organization to regularly fulfill a use case via connection to Mass HIway, by taking the following steps:

  1. A practice must determine a method of connection to the Mass HIway. For example, some electronic health records may already connect to the Mass HIway, or may have the functionality to connect. For most practices that do not have EHRs compatible with the Mass HIway, stablishing the WebMail access to the Mass HIway will be preferable.
  2. A practice should then review the use cases detailed in Section 5.4 of the Mass HIway Policies and Procedures, such as provider-to-provider communication and public health reporting, to determine what type of usage of the Mass HIway will be optimal  for their practice. Physician practices must then incorporate policies to incorporate  the use cases into the ongoing workflow of the practice. The requirements for the use cases are as follows.

    • Year 1: The provider organization shall send or receive HIway Direct Messages for at least one use case. The use case may be within any category of use cases.
    • Year 2: The provider organization shall send or receive HIway Direct Messages for at least one use case that is within the provider-to-provider communications category of use cases.
    • Year 3: The provider organization shall send HIway Direct Messages for at least one use case that is within the provider-to-provider communications category of use cases. The provider organization shall also receive HIway Direct Messages for at least one use case that is within the provider-to-provider communications category of use cases. One of these two use cases may be the use case that was used to meet the Year 2 requirement.

  3. A practice should then complete the attestation of compliance with this mandate, as detailed in the section below.


How and when do I attest?

Update to the Attestation Forms: The Attestation Forms have been updated and are available in PDF format ( Year 1 Attestation Form , Year 2 Attestation Form). These updated versions are dated April 2018, and replace the prior versions that were dated December 2017. 

The Mass HIway prefers the onlinemethod of submitting the Year 1 and Year 2 Attestation Forms via their website, instead of emailing completed PDF versions of the Attestation Forms. The online method should be available on http://www.masshiway.net/HPP/index.htm  in late April 2018, and organizations that are required to complete an Attestation Form by July 1, 2018 are encouraged to use the updated PDF versions of the forms for planning purposes, and then complete the Attestation Form when the online versions are available in late April 2018. The Mass HIway will send a notification as soon as the online versions of the forms are available.

     

Additional FAQs:

EOHHS has released an extensive list of frequently asked questions, available here .

Does the HIway collect clinical information?
No, the HIway, itself is uniquely a communications platform. There is no central repository of patient records.

Does use of the HIway require an EHR/EMR?
Although workflow is easier when tightly integrated with the clinical inbox of an EHR, a simple web browser and HIway account is all that is required to communicate with other medical professionals. All of the available connection types can be found here .

Who can I communicate with over the HIway?
A current list of HIway participants can be found
here .

Is my medical license at risk if I am not in compliance?
The fine is monetary, not potential risk to relicensure.

Next Steps:

The MMS will continue to work with the EOHHS and other stakeholders as we near the implementation date. We expect communications from the EOHHS to go out to physicians this summer.

We will also work with you to answer questions regarding compliance as this mandate is implemented.

 

Further Questions?

We welcome you to contact our MMS liaison:
Leon Barzin ( lbarzin@nejm.org)

To contact Mass HIway directly:
 1-855-MA-HIWAY (1.855.624.4929)    
MassHIway@state.ma.us

 

Resources:

MA HIE Website

Requirements, Forms and Steps for Enrolling in the MA HIE


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