HARRIS CORPORATION HEALTHCARE SOLUTIONS Privacy & Security Technical Adoption & Outreach Legal Finance & Sustainability Policy Florida FHIE HIE Florida Health Information Exchange Direct Secure Messaging Readiness Questionnaire for Health Information Service Providers 12/07/2012 Florida HIE Readiness Questionnaire for Health Information Service Providers Table of Contents Introduction.................................................................................................................................................... 3 Health Information Service Provider (HISP) Network General Information .................................................. 4 Primary Points of Contact Information ................................................................................................... 4 Organization Information ....................................................................................................................... 5 Logistics Information .............................................................................................................................. 6 Florida HIE Direct Secure Messaging Readiness Questionnaire ................................................................. 7 Health Information Exchange (HIE) System Questions ............................................................................ 7 Security Implementation Questions ........................................................................................................... 9 Privacy Implementation Questions .......................................................................................................... 10 General System Implementation Questions ............................................................................................ 11 Attachment A ............................................................................................................................................... 13 Estimated Implementation Work Effort ................................................................................................ 13 Attachment B ............................................................................................................................................... 14 HISP Implementation Steps ................................................................................................................. 14 December 7, 2012 Page 2 Florida HIE Readiness Questionnaire for Health Information Service Providers Introduction The Harris Team is currently in the process of identifying health information service provider (HISP) networks to be early participants in the Florida Health Information Exchange (HIE) Direct Secure Messaging (DSM) service. The DSM service enables an authorized health care provider and other authorized participants to send messages about a patient’s clinical data to other network participants for treatment, payment, and other permitted purposes. There are other HIE services that are offered through the Florida HIE (e.g., patient look-up), however, this Readiness Questionnaire is focused on prospective HISP networks who wish to participate in the Florida HIE DSM service. Examples of HISP networks include operational Regional Health Information Organizations (RHIOs), integrated delivery networks (IDNs) or other health systems, clinical HIEs, electronic health records and personal (patientcontrolled) health records (PHRs). The Harris Team recognizes that provider networks and healthcare organizations are at varying levels of adoption and use of health information technology. Therefore, the Florida HIE is designed to be flexible to accommodate and leverage existing healthcare information systems and processes. The Florida HIE deploys a model consistent with the Direct project protocols of the Nationwide Health Information Network (NwHIN). The Florida model provides a centralized messaging service which includes a participant vetting and agreements establishing the responsibilities of DSM users. It offers participants a Participant Directory to search for DSM email addresses. It uses a common DSM organizational certificate to establish trust when data is transmitted over the Internet. Participation in the Florida HIE includes a commitment from your organization to provide the resources for enabling a HISP to HISP connection with the Florida HIE, to understand and agree to meet the terms of an agreement (i.e. SERCH (Southeast Regional HIT-HIE Collaborative)/Florida agreement) establishing the responsibilities of uses sending or receiving messages from DSM users, and to conduct other key implementation activities. It is important that prospective participants demonstrate both technical readiness and a willingness and ability to commit resources to the implementation process. To assist the Harris Team in assessing your organization’s readiness and willingness to connect and enable mutual exchange of messages among participants, please complete and submit this Florida HIE DSM Readiness Questionnaire and e-mail it to FloridaHIE@harris.com. A Harris Team representative will then contact you for follow-up information. Please note that this questionnaire is not intended to imply minimum criteria for HISP connecting to the Florida HIE DSM service. The responses received will be used to help assess current and/or future readiness of your organization. Answers to this questionnaire are subject to Florida public records law. If your organization will be disclosing trade secret information, you will need to designate which sections are considered trade secrets by marking each page “Trade Secret as defined in Section 812.081, Florida Statutes” upon which such information appears. Information specifically identified as a trade secret under Section 812.081, Florida Statutes, will be kept confidential to the extent provided by law. Designating material simply as “proprietary” will not necessarily protect it from disclosure under Chapter 119, Florida Statutes. December 7, 2012 Page 3 Florida HIE Readiness Questionnaire for Health Information Service Providers Health Information Service Provider (HISP) Network General Information Organization Name: Click here to enter name ______________________________________________ Address: Click here to enter address. ____________________________________________________ Primary Points of Contact Information 1. Who is your Program Management Point of Contact? (This person will be responsible for ensuring agreements are signed and determining implementation vision.) Name: Click here to enter name Title: Click here to enter title. Phone Numbers (office and cell): Click here to enter phone. Email: Click here to enter e-mail. Mailing address: Click here to enter address. 2. Who is your Technical Point of Contact? (This person will be responsible for setting up the servers.) Name: Click here to enter name. Title: Click here to enter title Phone Numbers (office and cell): Click here to enter phone. Email: Click here to enter e-mail. Mailing address: Click here to enter address. 3. Who is your Computer Security/Chief Security Officer Point of Contact? Name: Click here to enter name. Title: Click here to enter title. Phone Numbers (office and cell): Click here to enter phone. Email: Click here to enter e-mail. Mailing address: Click here to enter address. December 7, 2012 Page 4 Florida HIE Readiness Questionnaire for Health Information Service Providers Organization Information 1. Please indicate your Legal Entity type (C corporation, S corporation, LLC, limited partnership, general partnership)? Click here to enter type. ___________________________________________________________ 2. Please describe what type of industry organization you are (e.g., clinical HIE, electronic health record, health system, regional health information organization, or personally controlled health record): Click here to enter type. ___________________________________________________________ 3. Is your organization licensed by the Florida Department of Health or the Agency for Health Care Administration? Yes/No. 4. Are you considered a covered entity under HIPAA? Yes/No. 5. Are you considered a business associate of one or more covered entities under HIPAA and have written business associate agreements with those covered entities? Yes/No. 6. Are you a state designated entity under the federal State Health Information Exchange Cooperative Agreement Program? Yes/No. Note: The SERCH/Florida agreement is optional for state designated entities during the period of the Cooperative Agreement Program. December 7, 2012 Page 5 Florida HIE Readiness Questionnaire for Health Information Service Providers Click here to enter Page Marking (optional). Logistics Information 1. When would you prefer the Harris Team to target your organization’s connection to the Florida HIE DSM service? (e.g., As soon as possible, within 6 months, within 1 year, within 18 months, or within 2 years) Click here to enter timeframe. 2. Are you willing to dedicate time and resources to enable interfacing between your organization’s information system and the Florida HIE? This will likely include a system administrator and a clinical analyst (please see Estimated Implementation Work Effort checklist in Attachment A and Implementation Steps in Attachment B of this Readiness Questionnaire for a list of the tasks that are expected to be accomplished by your organization). Please explain any constraints. Click here to enter constraints. ______________________________________________________ _______________________________________________________________________________ 3. Do you have any upcoming relevant system migrations or upgrades that the Florida HIE should be aware of? Yes/No. If yes, please detail: Click here to enter text. ____________________________________________ _______________________________________________________________________________ 4. Please identify the individual or position who will be signing the SERCH/Florida agreement for your organization. The agreement is posted at: https://www.florida-hie.net/. Please detail possible options if TBD: Click here to enter text. ______________________________ _______________________________________________________________________________ Click here to enter Page Marking (optional). December 7, 2012 Page 6 Florida HIE Readiness Questionnaire for Health Information Service Providers Florida HIE Direct Secure Messaging Readiness Questionnaire The Florida HIE DSM Readiness Questionnaire is used to help assess an organization’s overall readiness to connect to the Florida HIE for the DSM service. Areas covered in the Readiness Questionnaire include information about your Direct implementation and current status as well as privacy and security policies and implementation. Please answer the following questions to the best of your ability. If a specific section or question is not applicable to your organization, please leave it blank. Health Information Exchange (HIE) System Questions Item Information Systems Question Please identify what HISP system you are using. Please include vendor, the 1. version/release of the system application, and specific vendor contact information. Is your HISP network currently Direct project compliant? Please indicate the 2. version and detail if there are any exceptions. Are the certificates used within your HISP compliant with the DirectTrust Ecosystem Community X.509 Certificate Policy? 3. (http://wiki.directproject.org/Direct+Ecos ystem+Community+X.509+Certificate+Poli cy) Response and Discussion Enter response here. Please indicate what type or certificate structure you have implemented. Do you 4. use one common organizational security certificate, multiple organizational certificates or individual certificates? Please indicate the method your HISP uses to publish your certificate(s) – DNS or 5. LDAP (See section 5.0 of the Direct Applicability Statement for Secure Health Transport version 1.1). December 7, 2012 Page 7 Florida HIE Readiness Questionnaire for Health Information Service Providers Item Information Systems Question How many physicians have a Direct email address within your network? Response and Discussion Enter response here. 6. Note: DSM registration and utilization information is available on the Florida HIE dashboard. Please visit, http://floridahieeval.fiu.edu 7. How many participants have a Direct email address within your network? 8. How many transactions do you process monthly within your network? Does your HISP exchange or have the 9. capability to generate structured CCD that can be read by the recipient? What other types of data formats do you support that could potentially be used to 10. generate a payload (e.g., PDF, .doc, .rtf, TIFF, JPEG, ebXML, HL7, etc.)? Do you currently interface with third party 11. EHRs? If yes, what are the products and what tool do you use to interface? December 7, 2012 Enter response here. Enter response here. Enter response here. Enter response here. Page 8 Florida HIE Readiness Questionnaire for Health Information Service Providers Click here to enter Page Marking (optional). Security Implementation Questions Item 1. Information Systems Question Do you fully comply with the HIPAA Security Rule? Have you performed a thorough assessment of the current potential security risks and vulnerabilities to the 2. confidentiality, integrity, and availability of Electronic Protected Health Information (EPHI) held by your organization and your business associates? 3. Please describe your system controls for user authentication? 4. 3 Do you monitor your security logs? . Do you have a documented computer 5. 4 security incident response plan? If yes, has . it been tested in the last 12 months? Have you had any security breaches in the last 5 years? If so, please describe the 6. cause of the breach and what steps were taken to address any issues. What mechanisms are in place such as contracts and employee policies to control 7. access to mobile devices and ensure mobile device security is maintained? 8. Additional comments? December 7, 2012 Response and Discussion Enter response here. Enter response here. Enter response here. Enter response here. Enter response here. Enter response here. Enter response here. Page 9 Florida HIE Readiness Questionnaire for Health Information Service Providers Click here to enter Page Marking (optional). Privacy Implementation Questions Item Information Systems Question Response and Discussion Do you comply with NIST Level 3 (or above) guideline for identity verification? Enter response here. Fully describe any privacy policies you have at your HISP system level and any 2. policies at the user level (if any additional policies exist). Do you have written contracts with technology partners? Do they include 3. HIPAA business associate language, when applicable? Enter response here. 1. 4. Additional comments? December 7, 2012 Enter response here. Enter response here. Page 10 Florida HIE Readiness Questionnaire for Health Information Service Providers Click here to enter Page Marking (optional). General System Implementation Questions Item Information Systems Question Response and Discussion 1. What is your current message size limit, including attachments, for your HISP? Enter response here. 2. Please describe the use of Read Receipts and whether always on or optional. Enter response here. 3. Additional comments? December 7, 2012 Enter response here. Page 11 Florida HIE Readiness Questionnaire for Health Information Service Providers Thank you for completing the Florida HIE Direct Secure Messaging Readiness Questionnaire for Health Information Service Providers. Please e-mail your responses to FloridaHIE@harris.com (e.g., use the “send” option within Microsoft Word). A Harris Team representative may contact you for follow-up information, as needed. December 7, 2012 Page 12 Attachments – Implementation Requirements Attachment A Estimated Implementation Work Effort To connect with the Florida HIE DSM service, your organization will be required to commit resources and personnel to work alongside the Harris Team. Deployment activities will span over approximately a five (5) day period, where various levels of support will be required from your technical personnel. The table below identifies the tasks that will need to be accomplished by your organization’s staff in support of the Harris deployment team activities. Tasks Organizational Staff Test Data and Review Test Data – your organization identifies and provides sample de-identified data to the Harris Team. Clinical Analyst Test Receipt – the Harris Team and your organization sends a test message for review by the Harris Team and your organization. Clinical Analyst Deployment Support Integration Support – as appropriate, provide access to and documentation for existing system necessary for HISP implementation activities. Includes providing support for deployment testing. System Administrator Direct Certificates Exchange –your organization and the Harris team will need to integrate certificate discovery, verification and exchange. This would include error handling as appropriate. System Administrator QA and Test Support Error Detection and Reporting – the Harris Team identifies errors preventing messages from being delivered and works with your organization to resolve. System Administrator Production QA review – process production results for final review before making data available to physicians and other participants. Your organization should run a QA test using live data that spans one to two days. Clinical Analyst December 7, 2012 Page 13 Attachments – Implementation Requirements Attachment B HISP Implementation Steps Typical step-by step HISP implementation activities to connect with the DSM HISP are listed below. It is assumed that steps one and two are completed prior to initiation of HISP connection activities. 1. Instantiate Direct services 2. Publish public keys of HIE trust anchors in Domain Name System (DNS) or Lightweight Directory Access Protocol (LDAP). 3. HISPs execute agreement, as applicable. 4. Add trust anchors of other HISP to test system (optional) or to production system 5. Validate access of public keys from other HISP 6. Validate access of public keys of participant users from other HISP, if applicable 7. Create test accounts to exchange messages 8. Create test message (digitally sign and encrypt) per Direct and send to other HISP for verification 9. Receive messages from other HISP and verify decryption and digital signature of the external HISP 10. If test system used in step 4, add trust anchors of other HISP to production and repeat steps 5 through 9 on the production system. December 7, 2012 Page 14