Geographies Meeting 2010-06-04

Notes from Implementation Geographies Workgroup
Date: June 4, 2010
Time: 2pm-3pm
Attendees: Jackie Key, Rick Tomilson, Douglas Arnold, Matt Koehler, John Theisen, Frank Clark, Umesh Madan, Gary Christensen, Jason Wolfton, Arien Malec, Lee Jones, Kim Long, Andy Heeren, Jeff Cunningham
Actions for this Week
n/a
Actions from last Week

#	Date	Action	Status	Owner	Due Date
19	5/28/10	Response to question from Frank Clark: In the case of the NHIN Direct Pilots, will the Physicians sign DRSA agreements and go through the on-boarding process required for the connect-gateway entities?	Open	Paul	N/A
20	5/28/10	Identify which Implementation Geography you are representing, if any, on the main page: http://nhindirect.org/Implementation+Geographies	Open	WG	N/A

Agenda

• Review action items from last week
• Discussion
  • Proposed participation timelines -- feedback from workgroup
  • Methods for promoting/forming/participating in pilots -- suggestions / discussion
  • Need for shared, centralized HISP(s) to support implementation geographies -- discussion / volunteers
  • Legal frameworks (if any, especially Federal) required to participate in NHIN Direct pilot(s)
• Next Steps
  • Identify who's (workgroup members) representing which pilot(s) / implementation geographies

Notes
Comment from Arien Malec

• There are constraints on ONC being able to create a policy framework for NHIN Direct
• Updated charter for Implementation Geographies WG reflects the voluntary nature of participation in NHIN Direct and voluntary adherence to policy
• Federal agencies may require contracts between each organization and a particular federal agency
• There is value in the WG working with the HITSC to come up with policies that organizations can voluntarily agree to for their participation in NHIN Direct

Continued Feedback on Voluntary Basis for NHIN Direct Participation

Name	Feedback/Comment
Rick Tomilson	No comment
Douglas Arnold	Do you foresee any problems with a for-profit organization participating? Arien Malec – There are no preconditions for participation
Matt Koehler	No comment
John Theisen	No comment
Umesh Madan	If I have an implementation geography and a federal agency wanted to participate, how would the contractual agreement work? Arien Malec – There would have to be an organization that could legally sign a contract with the federal agency For small practices that don’t have an affiliation with a medical group or IPA, they may need to sign individually or not participate (more detailed discussion continued below)

Comment from Umesh Madan

• If a participant in an implementation geography has not signed a contract with a federal partner, would they simply not be able to exchange with the federal partner but be able to exchange with other participants in the geography?
• For ex: If someone develops a HISP, is it possible for the HISP and the VA to sign an agreement and have all participants under HISP be covered?
• Arien Malec – Look to DURSA for an example of how this might work
  • There is a one-to-one relationship with signatory and a provider
• Umesh Madan - If we are defining a policy framework for participation, what would be included?
• Arien Malec – We are defining a set of recommended best practices, which would include data handling, data reuse, provider identification
  • Organizations can voluntarily adhere to these best practices

Feedback on Voluntary Basis for NHIN Direct Participation

Name	Feedback/Comment
Gary Christensen	As long as you’re not connecting with a federal agency, sounds like these contractual concerns will be less relevant. Are there are other policy restrictions that might apply? Arien Malec – Outside of existing law, there are no constraints that ONC can provide beyond individual contractual exchanges There is value in testing out a policy framework to see how applicable/usable this policy framework might be Gary Christensen - We have existing data sharing agreements Arien Malec – Organizations that have already done governance legwork will likely be able to do this quickly
Jason Wolfton	Do you have current plans to create these best practices? Arien Malec –HITPC is exploring key policy issues and this WG should also look at these as part of the operating guidelines for NHIN Direct participants
Lee Jones	No comment
Kim Long	No comment
Andy Heeren	No comment
Jeff Cunningham	No comment

Comment from Frank Clark

• Does the DURSA only come into play when you’re exchanging with a federal agency?
• Arien Malec – The DURSA comes into play if you want to join the NHIN Exchange
• Frank Clark – So for our implementations, we would not be joining the NHIN Exchange?
• Arien Malec – NHIN Exchange has a strong set of policies associated with it
• Frank Clark – So if you exchange data with a federal partner and are on the NHIN Exchange, you will need to sign the DURSA
• Arien Malec –To the extent that you can cover small providers under the DURSA, that would be helpful
  • The mechanics of how an independent business would federate under a DURSA signatory is a complex legal matter that I’m not qualified to answer

Comment from Arien Malec

• Believe that the intent of discussion item “Need for shared, centralized HISP(s) to support implementation geographies” is that it would be useful for some non-geographic bounded HISPs to support implementation geographies

Comment from Jason Wolfton

• Some people seem assume that some of these HISP services would be available to implementation geography participants
• Visionshare would be happy to provide some of these services across implementation geographies

Comment from Gary Christensen

• Have been advocating for this

Comment from Arien Malec

• Assuming that there is value in having trans-geographic HISPs, what organizations represented on the call could provide these services and what other organizations could be recommended to provide these services?
• Gary Christensen – Seems that in order to pilot the NHIN Direct architecture, we need these HISPs
• Arien Malec – Abstract model allows for a combined source HISP, you don’t need to separate roles
  • Justification to allow for separation of roles comes from small practices. In this case EHR would also have to perform a routing function

Comment from Gary Christensen

• The function of a HISP has to exist, but this function doesn’t need to be performed by a separate organization
• Is there a need for a separation of HISPs by geography?
• Arien Malec – There are some geographically limited HISPs

Feedback on Ability to Provide Trans-Geographic HISP Services

Name	Feedback/Comment
Rick Tomilson	No comment
Douglas Arnold	Need for clarification around HISP role with respect to State HIEs. Do regional HISPs refer to state HIEs? Arien Malec - Not all states are alike, there are different business models. Some state HIEs may have an interest in providing the HISP services Gary Christensen – Agree, for example lower level transport services are not part of our organization’s business model. This type of service would be addressed by other means. Arien Malec - There are some states that rely on simple transport
Matt Koehler	No comment
John Theisen	No comment
Frank Clark	What are the HISP services? Arien Malec - The main HISP service is when there is a separation between the EHR and the HISP, establishing connectivity between these. The second key service is negotiating the transaction to the destination. Frank Clark – Our organization would be willing to provide these services within our geography, but can’t commit to nationwide Arien Malec - Many EHR vendors would be interested in supplying services
Umesh Madan	Microsoft is willing to provide these services with HealthVault for any provider to patient interaction
Gary Christensen	Not willing to do this, but Quest may be. My understanding is that technology is unrelated to geography. Arien Malec - Geography would come into play in the mechanics of supporting providers Gary Christensen – Are these services only for the purpose of pilot? Arien Malec - Yes, but providers will really be using them
Jason Wolfton	Visionshare is willing to provide a nationwide HISP. Our nationwide architecture is already built for this. Specification appears to be geography agnostic. Are there specifications in the trust framework that would enable a HISP provider to supply services to a limited group of individuals? Arien Malec - Each of the concrete implementations call for the ability sub-segment communities of trust
Lee Jones	Medallies would be willing to be a nationwide HISP Are there assumptions regarding eventual business relationships? Arien Malec - There are no assumptions in that regard *
Kim Long	Medplus/Quest is willing to be a provider of nationwide HISP services
Andy Heeren	Cerner is willing to provide nationwide HISP services
Jeff Cunningham	We are looking at providing HISP services to the geographies we serve and are willing to look at providing nationwide services
Rich Elmore	Allscripts is willing to provide nationwide HISP services

Comment from Jason Wolfton

• Is the scope of the pilots to also test HISP-HISP communication?
• Arien Malec - Yes, this is key to NHIN Direct