1. Enterprise Consent Model for use with the MassHIway
Deborah Adair
Director Enterprise Health Information Management
November 1, 2016

2. Agenda PHS Enterprise Consent Model Planning Stage
Implementation: Staff and Patient Education Materials
Sensitive Information Strategy
Consent Metrics
Challenges

3. PHS Enterprise Consent Model
PHS eCare – One Patient, One Record
Enterprise Electronic PHS Mass HIway Consent
Collect Once From the Patient
Apply Patient Choice Throughout Partners Healthcare including our EHR affiliates

4. Current State
Collecting signed PHS MassHIway consent in registration system
Integrated with registration staff workflow
Interfaced with EMPI Consent Flag
Uses e-form and signature pads
Sites not on e-Care built or used existing flags in their local registration systems and interfaced with EMPI

5. Current State Collect consent in Patient Portal: Patient Gateway
Message on PG homepage for patients who have not opted in or out
Patients may change HIway status at anytime by logging into their PG account

6. Planning Stage
HIway Consent Implementation Workgroup created and met weekly:
Health Information Management
Information Systems
Patient Access (registration)
PeCare
Care Everywhere (Epic’s HIE)
Patient Gateway (patient portal)
Chief Information Medical Officers
MU project managers
Compliance Officers
Office of General Council
Workgroup reported to HIE Steering Committee

7. Implementation: Staff Education (toolkit)

8. Implementation: Staff Education (toolkit)

9. Implementation: Staff Education (Procedure)

10. Implementation: Staff Education (system)

11. Implementation: Patient Education

12. Sensitive Information
Initial roll-out, rules logic suppressed CCDAs with sensitive data
Epic 2015 version implemented functionality to apply rules logic to expire HIway Consent
For patients with sensitive data who sign HIway Consent, it is active for that encounter, then expires
Patient prompted to sign again next time
For Inpatient Psych admissions, 42 CFR programs, Ambulatory Psych visits and other highly sensitive departments:
CCDAs are not auto-sent upon discharge or referral workflows and encounters level data and notes are always suppressed

13. Mass HIway Metrics Cummulative Summary as of 10/1/16
Opt-In Total: 522,832
Opt-Out Total: 96,985

14. Greatest Challenges
Patient Education (patients have no idea what this is and are weary of signing)
Staff Education (registration staff don’t have time to explain it and also don’t have enough knowledge, even with training, to answer patients’ questions)
ED environment (patients’ conditions make obtaining HIE consent extremely difficult and a voluntary consent falls to the bottom of the priority list)
Sensitive data (requires resources to build logic and systems that can support suppression and/or expiration)
State-wide education campaign is needed (People are not seeing the benefits or hearing success stories)

15. HIway Regulations: Opt-In & Opt-Out Mechanism
M.G.L. Chapter 118I describes that there shall be a mechanism for patients to opt-in and opt-out of the HIway.
EHS is proposing to clarify and focus the opt-in/opt-out mechanism based on specific HIE functions:
Opt-in mechanism: Provider Organizations give patients public notice
Public notice may include, but is not limited to: visible posters, handouts, inclusion in the privacy notice, banner on a web portal, letteror to the patient
The HIway will provide a sample public notice that Provider Organizations may adapt and use
Opt-out mechanism: A centralized opt-out mechanism
Provider Organizations also have the option of an additional local opt-in/opt-out mechanism
EOHHS would accompany the regulations with state-wide education for both patients and Provider Organizations