Mental Health Services Act Technology IT Workgroup Meeting
Conference Call Number 1-800-416-4956 Access Code 44021758#
May 3, 2007
MHSA Technology 1
Agenda
12:00 12:10 12:25 12:30 12:45 Welcome and Introductions One-Time IT Funding Request Status DCR Electronic Signatures Integrated Information System Plan Gary Renslo Christine Walker Bob Cutler Bob Cutler Corina Leon/Lori Hack
• •
Strategy and Timelines Questions and Answers
1:15
Technology Component – Where do
we go from here? How do we get there? • Discussion of guidelines • Local planning process Stakeholder Feedback on guidelines and process
Gary Renslo/Lori Hack
3:30
Adjourn: Next meeting TBD, Topics?
MHSA Technology 2
MHSA Funding Overview
CSS One Time IT Funds Update – Refer to handout
MHSA Technology
3
MHSA One-Time CSS System Improvement Funding
Requests to date for MHSA CSS IT Funds: • Approved through 5-1-07:
• 18 Counties’ requests for 32
projects ($11,214,396)
• Reviewing:
• 9 Counties’ requests for 10
projects ($13,298,212)
• All approvals on the website
MHSA Technology 4
Approved MHSA CSS IT Funded Projects (Already Funded)
County
Butte Del Norte Glenn Humboldt Lake Lassen Los Angeles Mendocino Merced Mono Napa
Approved Project Title
Integrated Behavioral Health Information System Integrated Behavioral Health Information System Integrated Behavioral Health Information System Imaging System Enhancement for EHRs Integrated Behavioral Health Information System Enhanced Data Accessibily for Clinical Information Integrated Behavioral Health Information System Consultants to Support the IT MHSA Inititatives Integrated Electronic Medical Records System Data Collection and Reporting System Integrated Behavioral Health Information System Integrated Behavioral Health Information System
Approved MHSA Funding
$473,984 $40,000 $89,162 $58,675 $224,677 $162,700 $3,177,000 $885,000 $125,000 $119,000 $88,216 $351,912 $58,891 $30,000 $58,891 $449,225 $263,500 $1,194,909 $124,000 $1,313,800 $62,000 $180,000 $60,000 $113,575 $40,000 $40,900 $139,100 $300,028 $189,284 $75,216 $303,125 $422,626
Date of Last qrtly status approval report received
2/9/07 8/17/06 8/28/06 7/24/06 11/29/06 3/30/07 6/29/06 1/12/07 5/1/07 9/13/06 10/11/06 7/12/06 2/14/07 8/1/06 3/20/07 3/20/07 3/20/07 3/20/07 3/20/07 8/17/06 8/17/06 8/17/06 8/17/06 8/17/06 8/17/06 9/13/06 9/13/06 9/22/06 9/22/06 9/22/06 8/28/06 8/28/06 Apr-07 Jan-07 Jan-07 Apr-07 N/A Apr-07 Apr-07
Apr-07 Jan-07 N/A Jan-07 N/A N/A N/A N/A N/A Jan-07 Jan-07 Jan-07 Jan-07 Jan-07 Jan-07 Apr-07 Apr-07
Orange Access to Electronic Medical Records Project San Benito Integrated Behavioral Health Information System San Bernardino Appointment Scheduling Software Implementation Geographic Information Systems Behavioral Health Layer Touch Screen Technology for Data Collection Data Mining for Analytical Assessment Project Infrastructure Enhancement Project (Charon/VAX) Network Infrastructure Upgrade and Workstation Procurement Management System for Client Placement Intensive Services Mgmt & Wraparound Data System Integrated School, Substance Abuse & Youth Data System Coordinated Case Management Data Supports Enhanced Most Notes Application Integrated Billing and Clinical Service System San Luis Obispo Behavioral Health Information System Analysis Infrastructure Upgrade and Workstation Deployment Shasta Integrated Behavioral Health Information System Document Imaging System Tulare Electronic Health Record & Client Scheduling System MHSA Billing and Data Collection System San Francisco
Total MHSA Approved Projects
$11,214,396
Requested MHSA CSS IT Funded Projects
County
Fresno Imperial Inyo Modoc Monterey Placer Riverside
Requested Project Title
Status
On-Hold (county's request) In DMH Approval Chain In DMH Approval Chain CSS Plan not Approved In Review In Review In Review In Review In Review In Review In Review On-Hold (county's request) In Review
Requested Funding
$1,500,000 $193,000 $30,000 $116,276 $825,922 $211,600 $3,500,000 $49,800 $315,100 $3,020,000 $5,000,000 $1,050,000 $152,790
Integrated Electronic Medical Records System MHSA Infrastructure Upgrade Integrated Behavioral Health Information System Netsmart Clinicians Workstation Electronic Medical Record Behavioral Health System w/ Electronic Medical Record Avatar Expansion and Electronic Medical Record Project Integrated Behavioral Health Information System SPSS Software Purchase and Training Sacramento Mental Health Information System Replacement Project San Bernardino Integrated Behavioral Health Information System New Mental Health MIS Implementation San Diego San Joaquin Integrated Behavioral Health Information System Tuolumne Anasazi Software Implementation Provider Expansion
Total Requested MHSA Funds currently being Reviewed
$15,964,488
Last updated: 5/2/2007
DCR
Online pilot status Online production availability Batch/XML development status Batch/XML pilot Batch/XML production availability
MHSA Technology
5
E Signatures
E Signatures – refer to handout
MHSA Technology
6
1600 9th Street, Sacramento, CA 95814 (916) 654-2309
April 27, 2007 DRAFT INFORMATION NOTICE FOR DISCUSSION PURPOSES ONLY TO: LOCAL MENTAL HEALTH DIRECTORS LOCAL MENTAL HEALTH PROGRAM CHIEFS LOCAL MENTAL HEALTH ADMINISTRATORS COUNTY ADMINISTRATIVE OFFICERS CHAIRPERSONS, LOCAL MENTAL HEALTH BOARDS SUBJECT: REFERENCE: EXPIRES: ELECTRONIC SIGNATURES IN ELECTRONIC MENTAL HEALTH RECORDS DRAFT FOR DISCUSSION PURPOSES ONLY DRAFT FOR DISCUSSION PURPOSES ONLY
The increased use of electronic health records and electronic methods of signing electronic health records has prompted the State of California Department of Mental Health (DMH) to issue proposed standards regarding the use of electronic signatures in electronic mental health records. The Department is currently working on draft regulations to further define this issue. In addition to the addressees, this letter should be reviewed by all appropriate county staff in areas including, but not limited to, compliance, audit, clinical, quality improvement, fiscal, and information technology. Topics covered in this letter include: • • • • Electronic signature and electronic health record definitions Proposed standards for an acceptable electronic signature used in an electronic health record Capturing consumer signatures Health Insurance Portability and Accountability Act (HIPAA) compliance
DRAFT FOR DISCUSSION PURPOSES ONLY Electronic Signatures in Electronic Mental Health Records Page 2
Electronic Signature – Definition
Federal law 1 defines an electronic signature as “an electronic sound, symbol, or process, attached to or logically associated with a contract or other record and executed or adopted by a person with the intent to sign the record.” Under California law 2 , a digital signature is defined as "an electronic identifier, created by computer, intended by the party using it to have the same force and effect as the use of a manual signature.”
Electronic Health Record – Definition
Division 1 Section 1000 of the California Health and Safety Code, as amended by SB 320, states that an electronic health record means “a secure, real-time, point-ofcare, patient-specific information resource that assists a health care provider in making a decision by providing access to the patient's health information, including a personal health record, when needed, and that incorporates evidence-based decision support.”
Proposed Standards for Acceptable Electronic Signatures in Electronic Health Records
DMH proposes to approve the use of electronic signatures in mental health records as equivalent to a manual signature affixed by hand for financial, program, and medical records audit purposes. This approval would apply to all electronic health records requiring signatures under the California Code of Regulations, Title 9, Division 1, when the electronic signature meets the following criteria: 1. The electronic signature mechanism is a) unique to the signer, b) under the signer’s sole control, c) capable of being verified, and d) linked to the data so that, if the data are changed, the signature is invalidated 3 . These criteria would serve to authenticate the validity of an electronic signature regardless of the technology used to produce the signature. 2. Computer systems that utilize electronic signatures comply with the following Certification Commission for Healthcare Information Technology (CCHIT) certification criteria 4 or equivalent: Security: Access Control, Security: Audit, and Security: Authentication. 3. Anyone who is empowered to electronically sign an electronic health record submits a signed Electronic Signature Agreement to the county mental health director agreeing to the terms of use for his/her electronic signature, the signed Agreement or copies thereof to be made available to the DMH auditor at the time of an audit.
1 2
15 USC § 7006 California Government Code Section 16.5 (d) 3 California Government Code Section 16.5 (a) and California Code of Regulations Title 2 Section 2002 4 http://www.cchit.org/files/Ambulatory_Domain/CCHIT_Ambulatory_SECURITY_Criteria_2007_Final__16Mar07.pdf
DRAFT FOR DISCUSSION PURPOSES ONLY Electronic Signatures in Electronic Mental Health Records Page 3 The proposed standards listed in the preceding paragraphs do not require encryption of the data in the electronic health record for compliance. However, counties would still responsible for taking appropriate security measures to safeguard the contents of electronic health records. It is proposed that county/local Mental Health Programs (MHPs) may set additional restrictions or requirements beyond what is presented in this information notice, provided those restrictions or requirements meet the minimum requirements stated above and are consistent with applicable state and federal laws and regulations. MHPs are responsible for identifying applicable laws and regulations that may apply to restrictions or requirements they set. County/local Mental Health directors must complete an Electronic Signature Certification form, certifying that their electronic system or any systems used by their providers meets the proposed standards. The signed agreement or a copy of it must be made available to the DMH auditor at the time of an audit.
Consumer Signatures
In many situations, the mental health consumer must acknowledge their willingness to participate in and acceptance of the treatment plan. In paper-based systems, the consumer physically signs a document to that effect. As an alternative to paper, it is proposed that MHPs use any of the following electronic capture approaches: 1) scanning paper consent documents, 2) capturing signature images from a signature pad, 3) capturing biometric information, such as a fingerprint using a fingerprint scanner, or 4) entering authenticating information known only to the consumer or authorized representative, such as a password or personal identification number (PIN). If a signature is unavailable, an electronically signed explanation must be provided.
Health Insurance Portability and Accountability Act (HIPAA) Compliance
In addition to the standards proposed in this letter for electronic signatures and electronic mental health records, MHPs and providers that manage consumer mental health information should be in full compliance with all applicable HIPAA security standards 5 . Upon future publication of HIPAA electronic signature regulations, MHPs will be required to be in full compliance within the timelines established by the federal government. If you have questions or need additional information regarding electronic signature criteria please contact Corina Leon-Walters at 916-654-5432. Sincerely,
5
http://www.cms.hhs.gov/SecurityStandard/02_Regulations.asp
ELECTRONIC SIGNATURE CERTIFICATION I certify that the electronic signatures affixed to the electronic mental health records on the computer systems employed by or on behalf of ___________________________ County meet or exceed all of the standards and regulations applicable to them.
Signed
Date
Print Name
Title
ELECTRONIC SIGNATURE AGREEMENT This Agreement governs the rights, duties, and responsibilities in the use of an electronic signature in __________________ County. The undersigned (I) understands that this agreement describes my obligations to protect my electronic signature, and to notify appropriate authorities if it is stolen, lost, compromised, unaccounted for, or destroyed. I agree to the following terms and conditions: I agree that my electronic signature will be valid for one year from date of issuance. I will be notified and given the opportunity to renew my electronic signature each year prior to its expiration. The terms of this Agreement shall apply to each such renewal. I will use my electronic signature to establish my identity and sign electronic documents and forms. I am solely responsible for protecting my electronic signature. If I suspect or discover that my electronic signature has been stolen, lost, used by an unauthorized party, or otherwise compromised, then I will immediately notify ________________ and request that my electronic signature be revoked. I will then immediately cease all use of my electronic signature. I agree to keep my electronic signature secret and secure by taking reasonable security measures to prevent unauthorized access to, or disclosure, loss, modification, compromise, or use of it or any media on which information about it is stored. I will immediately request that my electronic signature be revoked if I discover or suspect that it has been or is in danger of being lost, disclosed, compromised or subjected to unauthorized use in any way. I understand that I may also request revocation at any time for any other reason. I will immediately cease using my electronic signature if I suspect or discover that it has been or may be compromised or subjected to unauthorized use in any way, after I have requested, or been notified that someone has requested, that it be suspended or revoked, or upon termination of this Agreement. I further agree that, for the purposes of authorizing and authenticating electronic health records, my electronic signature has the full force and effect of a signature affixed by hand to a paper document.
Signed
Date
Print Name
Accepted
Date
Title
Integrated Information Systems Plan
MHSA Technology
7
Integrated Information System Plan
Mental Health Technology Goal
To transform the county mental health technology systems into an accessible, interoperable, comprehensive information network (Integrated Information System Infrastructure) that can:
• •
Modernize and transform clinical and administrative information systems to improve quality of care, operational efficiency and cost effectiveness Increase consumer and family empowerment by providing the tools for secure consumer and family access to health information within a wide variety of public and private settings
MHSA Technology
8
MHSA Funding Overview Funding Distribution
FY 04/05 45% 45% 5% 5%
Education and Training Capital Facilities & Technology Local Planning
FY 05/06-08/09 55% 20% 10% 10% 5%
MHSA Technology
Community Services and Supports (CSS) - Including 5% for Innovation Prevention and Early Intervention (5% for Innovation) Education and Training Capital Facilities & Technology State Admin
9
State Admin
MHSA Funding Distribution
• Total estimated Capital Facilities and Technological funding is $597 million. • Distribution made on cash collections, not estimates
MHSA Technology
10
Roadmap to Integrated Information System
Baseline assessment conducted prior to plan implementation
2007 2008 2009 EHR “Lite” Document Imaging, or Clinical Notes Module, or EHR “lite” 2010 Ordering 2012 Full EHR Full EHR interface from external Providers EHR and PHR
Practice Management
ture
Electronic registration, scheduling and billing interface to contract providers
Infra struc
CPOE (Lab, RX) ordering, reporting
MHSA Technology
11
State of the County Analysis to be conducted by DMH
Level 1: Review:
•
What the counties have in place:
• •
• • • • • • • •
Technology Planning Scope Funding Current capabilities, installation plans, phases,
What are the counties planning on doing:
Level 2: Stakeholder Participation
Who is involved:
How many clinics? How many providers? What technologies do the providers have? What planning is in place to include providers?
MHSA Technology
12
MHSA Technology Plan Draft Proposed Guidelines
•
Technology Plan Guidelines: June 2007
• DMH will develop the first draft for stakeholder input by May •
2007 DMH will hold stakeholder input call on May 10, 2007
• DMH will update the draft with comments from CMHDA, each •
sub-group in Technology and all other stakeholders in May 2007 DMH will revise draft and make the final plan requirements available in June 2007
•
Final input needed by May 25, 2007
• •
Earliest Local Plans Submitted: September 2007 Earliest Plan Review and Approval: November 2007
MHSA Technology
13
Current Efforts Requests for Information (RFIs) The EHR System RFI
• • •
To assist the Counties in understanding the technologies available from various vendors to support consumers in achieving their goals, as well as administrative process improvements To share the results of the vendor responses for functionality and the benefits of EHR implementations for planning purposes To determine vendors capable of providing EHR systems that meet the California minimum requirements (includes national standards) as outlined in the three year plan and local needs
MHSA Technology
14
Integrated Information System Plan
• EHR RFI Results: October 2007
• Stakeholder Process to develop RFI: July 2007 • Post RFI: August 2007 • Vendor Demonstrations: August 2007 • Vendor Information Submissions: August 2007 • Develop Vendor Evaluation Sheet: October 2007
• Develop EHR/HIE Technical Standards Document
to be updated periodically: November 2007
MHSA Technology 15
Current Efforts Requests for Information (RFIs)
The Health Information Exchange (HIE) RFI
Determine vendors capable of providing interoperability between counties, state departments and other entities based on:
• • • •
Continuity of Care Record / Clinical Document Architecture Master Patient Index / Record Locator Service Personal Health Record – “My Health Folder” Required Administrative Functions
MHSA Technology
16
Current Efforts HIE Implementation Timeline
• HIE RFI Results: May 2008
• Stakeholder Process to develop RFI: October 2007 • Post RFI: December 2007 • Vendor Discussions: January 2008 • Vendor Information Submissions: February 2008 • Develop Vendor Evaluation: May 2008
• Develop HIE Implementation Plan: July 2008
MHSA Technology
17
MHSA Draft Proposed Guidelines Technology Component
MHSA Technology
18
MHSA Technology Plan Proposed Guidelines: Technology Goals
Modernize and Transform Information Systems that:
• • • •
Include a standards based Integrated Information Systems Infrastructure Counties can securely access and exchange information Clients and Families can securely access information Account for current and future technology readiness and workflow analysis assessment
19
MHSA Technology
MHSA Technology Plan Proposed Guidelines
The Electronic Health Record (EHR) System is the foundation for an Integrated Information Systems Infrastructure.
A secure, real-time, point-of-care, client centric, information resource for service providers. Aids decision-making by providing access to health record information where and when they need it and by incorporating evidence-based decision support. Automates and streamlines the service provider’s workflow, closing loops in communication and response that result in delays or gaps in care. Also supports the collection of data for uses other than direct clinical care, such as billing, quality management, outcomes reporting and resource planning.
MHSA Technology
20
MHSA Technology Plan Draft Proposed Guidelines
The ability to share timely, accurate and secure access to the client’s health and healthcare information is possible with the use of technologies that use uniform standards:
Functional CCHIT User Friendly Interface Vendor Commitment Interoperability Connectivity (XML,SAML,SOAP) Language (ICD-9, SNOMED, LOINC, CA Cost Reporting) Access and Security Access Privacy Security Auditing Authentication
MHSA Technology
21
MHSA Technology Plan Draft Proposed Guidelines
Increase Consumer and Family Empowerment by:
Providing Access to Computing Resources
• • • •
Computer resources should include computer hardware, software, and broadband internet connectivity. The placement of equipment in a convenient and secure physical environment is essential. Computer literacy training must be addressed to allow consumers the ability to utilize all available information. Timely and simple methods for consumers to get technical support and information about privacy and security.
MHSA Technology
22
MHSA Technology Plan Draft Proposed Guidelines
Project Examples:
• • •
Electronic Health Record (EHR) System Projects Consumer / Family Access to Computing Resources Projects
• • • • • •
Personal Health Record (PHR) System Projects Expansion / Leveraging Network of Care Tele-medicine and other rural / underserved service access methods Pilot projects to monitor new programs and service outcome improvement Decision Support / Data Warehousing Projects Imaging / Paper Conversion Projects
Other Technology Projects
MHSA Technology
23
MHSA Technology Plan Draft Proposed Guidelines
Counties must provide DMH with a “Roadmap” to achieving an integrated information systems infrastructure through an EHR. County Technology Plans must provide DMH with a Technology Program Assessment in sufficient level of detail to describe the underlying assumptions, current technology environment, project management plan and budget to accomplish the proposed plan. The plan will be evaluated using four (4) templates. All projects will be evaluated on a case-by-case basis.
MHSA Technology
24
MHSA Technology Plan Draft Proposed Guidelines
An assessment of current systems
“Roadmap” for Achieving an Integrated Information Systems Infrastructure through EHR
=
A work plan, schedule and approach Cost estimates Approach to meeting current minimum standards and commitment to meeting future standards
MHSA Technology
25
MHSA Technology Plan Draft Proposed Guidelines
Template #1 - Face Sheet
Signed Commitment to Goals of MHSA and DMH Technology
Template #2 - Technology Program Assessment Report
• • • • • • • •
Comprehensive Assessment of Proposed Expenditures Strategic Plan / Roadmap / California External Quality Review Organization (CAEQRO) Project management Project description / Hardware / Software Security Training Interagency considerations Hardware / Software / Consulting / Staff / Training
Template #3 - Budget based on Planned Expenditures Template #4 - Quarterly Status Reporting
MHSA Technology
26
MHSA Funding Overview
Questions
MHSA Technology
27
Technology Support
Ensure that the right data is at the right place at the right time to support the client’s wellness, recovery and resiliency.
MHSA Technology
28
DMH MHSA Technology Contacts
Stephanie Oprendek, Ph.D. Chief, Evaluation, Statistics and Support Branch Phone: 916-653-3517 Email: Stephaine.Oprendek@DMH.CA.GOV Gary Renslo Chief Information Officer Phone: 916-653-3882 Email: Gary.Renslo@DMH.CA.GOV Rebecca Skarr Chief of Applications Development Phone: 916-654-2496 Email: Rebecca.Skarr@DMH.CA.GOV Corina Leon Requirements Coordinator, EHR/HIE/PHR Phone: 916-654-5432 Email: Corina.Leon-Walters@DMH.CA.GOV Lori Hack
Project Manager, EHR/HIE/PHR
Email: Lori.Hack@DMH.CA.GOV
MHSA Technology 29