Welcome to :
Confidentiality, Substance Use
Treatment, and Health
Information Technology
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3
Four-Part Webinar Series on…
Confidentiality, Substance Use Treatment, and Health
Information Technology (HIT)
First 3 Webinars Presented by the Legal Action
Center
4th Webinar Presented by SAMHSA
4
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Use the “Question(s)” feature on the upper right-hand
corner of your screens to type in your question(s).
We will answer questions at the end of the
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5
Today’s Power Point presentations can be downloaded
from http://www.lac.org/index.php/lac/webinararchive
Power Point presentations and materials from the
Webinar series can be downloaded from
http://www.lac.org and http://www.pfr.samhsa.gov
The recording of this series will be available soon at
the same locations.
6
SAMHSA’s Vision for Advancing
Behavioral Healthcare through
Health Information Technology
Maureen Boyle, PhD
Lead Public Health Advisor, Health Information Technology
Center for Substance Abuse Treatment
Substance Abuse and Mental Health Services Administration
May 25, 2012
President’s Vision for Health IT
Medical information will follow consumers so that
they are at the center of their own care.
Consumers will be able to choose physicians and
hospitals based on clinical performance results
made available to them.
Clinicians will have a patient's complete medical
history, computerized ordering systems, and
electronic reminders.
8
“The increased use of health
information technology is a key
focus of our reform efforts
because it will help to improve
the safety and quality of health
care generally while also cutting
waste out of the system.”
Kathleen Sebelius
Secretary
U.S. Department of Health & Human Services
September 29, 2009
9
SAMHSA’s Strategic Initiative - Health IT
 Goal: Widespread Implementation of HIT Systems
that Support High Quality Integrated Behavioral
Health Care for All Americans
• Ensure the behavioral health provider networks
fully participate in the adoption of Health IT
• Working closely with the Office of the National
Coordinator for Health IT to support inclusion of
behavioral health
10
National HIT Landscape
 The Health Information Technology for Economic
and Clinical Health Act ( HITECH Act)
• Meaningful Use, EHR Certification
• Large national investment in HIT
• Largely excludes behavioral health providers
 The Affordable Care Act
 Privacy and Confidentiality Regulations
• HIPAA
• 42 CFR Part 2
• State laws
11
Health Information Exchange
Specialty Care
EHR
Primary Care EHR
EHR Hospitals
EHR Clinics
Pharmacies EHR
HIE
NwHIN
Labs EHR
Claims Health Plans
PHR
Patients
Data
Systems
Public Health
Agency
12
HITECH Act
CMS and ONC define the requirements for
meaningful use and certification of EHRs
• Large national investment in HIT
• Largely excludes behavioral health providers
 Funding for Regional Extension Centers and Health
Information Exchange Networks
 NPRMs for Stage 2 were released on March 7th and
the final rule is expected by the end of the summer
• Multiple items of relevance to behavioral health

– Clinical Quality Measures
– Privacy and Confidentiality
13
Meaningful Use
Stage 3 (2016-)
Proposed
Stage 2 (2014-)
Stage 1 (2011-)
• Store Coded and Structured
information in the EHR
• Limited inclusion of BH
Proposed
• Focus on Data Exchange and
Coordinated Care
•Inclusion of BH clinical quality
measures for primary care
audience
• Focus on Improved Outcomes
and Reduced Costs shown
through robust clinical quality
measures
14
Stage 2
15
15
Meaningful Use Incentive Program
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/eligibility_flow_chart.pdf
16
Useful Links
 CMS: https://www.cms.gov/Regulations-and-
Guidance/Legislation/EHRIncentivePrograms/index.html?redi
rect=/EHRIncentivePrograms/
 ONC: http://www.healthit.gov/providers-professionals/ehr-
incentives-certification
 Certified EHR:
http://oncchpl.force.com/ehrcert/EHRProductSearch?setting
=Inpatient
 Regional Extension Centers
http://healthit.hhs.gov/portal/server.pt/community/healthit
_hhs_gov__listing_of_regional_extension_centers/3519
17
The Affordable Care Act
 Establishing
patient-centered medical homes
(PCMH) and accountable care organizations (ACO)
 Focus on coordinating care and pay for performance
 Formation of an ACO is contingent upon HIT for
information exchange and quality measure reporting
18
Privacy and HIT
 Privacy and Confidentiality Regulations
• HIPAA
• 42 CFR Part 2
• State specific laws
19
Ensuring Confidentiality and Trust
Increased accessibility to health records raises the
question of how to ensure patient confidentiality
and trust.
 To be sustainable, electronic exchange efforts must
establish trusting relationships with all participants,
including patients.

Melissa M. Goldstein, JD et al, 2010
20
42 CFR Part 2

Patient consent must be obtained before sharing
information from a substance abuse treatment
facility that is subject to 42 CFR Part 2

The purpose of the statute and regulations
prohibiting disclosure of records relating to
substance abuse treatment, except with the
patient's consent or a court order after good cause
is shown, is to encourage patients to seek substance
abuse treatment without fear that by doing so their
privacy will be compromised.
Source: State of Florida Center for Drug-Free Living , Inc.,842 So.2d 177 (2003) at 181.
21
42 CFR Part 2
 Patient consent must be obtained before sharing
information from a substance abuse treatment facility
that is subject to 42 CFR Part 2
 Prohibition on re-disclosure without consent
 Limited exceptions for disclosure without consent :
•
•
•
•
Medical emergencies
Child abuse reporting
Crimes on program premises or against program personnel
Communications with a qualified service organization of information
needed by the organization to provide services to the program
• Public Health research
• Court order
• Audits and evaluations
Source: 42 CFR Part 2
22
MENTAL HEALTH CONFIDENTIALTY
 Non-Substance
Use Disorder mental health records
may be treated as ultra-sensitive in many
jurisdictions.
 Each state approaches the confidentiality of mental
health records from their own perspective
• There are differences
• There are similarities
 EHR systems have to recognize this variability in
state statutes and regulations.
23
Critical Health IT Questions
 42 CFR Part 2 and other regulations provide the
ground rules. Careful analysis determines how the
rules are applied to ensure effective treatment of
substance use and mental health disorders.
• Who needs what information when?
• Who determines who needs what Information when?
• How should psychotherapy notes be treated – as
part of the patient record?
• How should HIT systems be designed to control
disclosure and re-disclosure of sensitive information
24
42 CFR Part 2 FAQs
To help providers in the behavioral health field better
understand privacy issues related to Health IT, SAMHSA, in
collaboration with ONC has created two sets of Frequently
Asked Questions (FAQs).
 These FAQs can be accessed at:
http://www.samhsa.gov/healthprivacy/docs/EHR-FAQs.pdf
and
 http://www.samhsa.gov/about/laws/SAMHSA_42CFRPART2F
AQII_Revised.pdf

25
The Health IT Challenge
 Health IT will provide powerful tool to address the
quality of care
 The challenge is to be ready to use those tools
 Only a small percentage of behavioral health
providers have adopted interoperable Health IT
systems
 Even if the systems are in place, many do not have
the personnel trained to effectively use them.
26
SAMHSA’s Strategic Initiative - Health IT
 The SAMHSA
is working to advance Behavioral
Health through Health IT
• Technologies/policies for privacy and confidentiality
• Develop and test advanced functionality for Behavioral Health
–
Data segmentation and consent management
–
Behavioral Health Clinical decision support
–
Patient engagement and self-management
• Development of data standards to ensure that information can be
efficiently and effectively exchanged and interpreted
• Behavioral health clinical quality measurement
• Deliver technical assistance to increase adoption of HIT by the
behavioral health community
27
SOLUTIONS FOR PRIVACY
Solutions for Privacy
 Working to identify interim solutions
for electronic
exchange of health information that is subject to
42CFR Part 2 using existing technology platforms
• Working with technology and legal experts
 Working with the ONC Standards and
Interoperability Framework and the VA to develop
open source technology for consent management
and data segmentation to give the patient dynamic
control over what information is shared
29
DATA STANDARDS
Benefits of Data Standards
 The integration of behavioral health and physical
health is contingent upon health information
exchange
 It is critical that health care providers can interpret
the information they receive from other providers
 Standards for collection and storage of health
information are needed for both interpretability and
integration of data into the receiving record
31
Benefits of Data Standards
 The adoption of interoperable data standards can
improve patient care and facilitate research
• More accurate and consistent data will be
available
• Quality measurement
• Real time outcome tracking and surveillance
• Standard information will allow programs to cross
reference and validate patient information.
32
SAMHSA HIT Standards Development

Open Behavioral Health Information Technology Architecture
(OBHITA) project:
• Working with the International Standards Organization
Health Level 7 (HL-7) to define consensus standards for
behavioral health information to be included in the
standard Continuity of Care Document (CCD)
• Working with the ONC Standards and Interoperability
Framework for Data Segmentation for Privacy (DS4P) to
identify exchange standards for patient consent
information across EHRs
33
QUALITY MEASUREMENT
Quality Measurement
 Quality measures have the potential to drive
improvement in the healthcare system and can be
used to demonstrate successful outcomes and
reduced waste.
 HIT performance and outcome measures will help
answer the questions:
•
•
•
•
Are our goals measurable and evidence-based?
Are we reaching the right populations?
Are client and treatment properly aligned?
Are our programs successful?
35
Quality Measurement
 Structural Measures
• Healthcare facility's organization and resources, such as nursing
staff levels, or the presence of a behavioral health provider on a
care team
 Process Measures
• The actual techniques used to treat patients, such as screening
and brief intervention for alcohol use or depression
 Outcome Measures
• The consequences of a patient's interaction with the healthcare
system (i.e. Did the patient’s depression score decrease with
treatment)
36
SAMHSA Quality Measurement Activities
 Developing clinical quality measures for behavioral
health that are relevant for the meaningful use
program
NQF #0109, Bipolar Disorder and Major Depression: Assessment for Manic or Hypomanic Behaviors
NQF #0110, Bipolar Disorder and Major Depression: Appraisal for Alcohol or Chemical Substance Use
NQF #0111, Bipolar Disorder: Appraisal for Risk of Suicide
NQF #1385, Developmental Screening Using a Parent Completed Screening Tool (Parent report, Children 0-5)
NQF #0576, Follow-Up After Hospitalization for Mental Illness
NQF #1401, Maternal Depression Screening
NQF $1406, Risky Behavior Assessment or Counseling by Age 13
NQF #1507, Risky Behavior Assessment or Counseling by Age 18
NQF #0580, Bipolar Anti-manic Agent
NQF #1661, SUB-1 Alcohol Use Screening
NQF #1663, SUB-2 Alcohol Use Brief Intervention Provided or Offered and SUB-2a Alcohol Use Brief Intervention
37
SAMHSA Quality Measurement Activities
 Two contracts are working with technical and clinical
experts to determine what additional quality
measures need to be developed to support
behavioral health care
• Both in primary and specialty care
• New quality measures will be developed to fill
gaps that are identified through this process
38
ADVANCED TOOLS
BH Treatment Lifecycle
Brief
Intervention
or Referral
Brief Patient
Assessment
Full Patient
Assessment
Patient
Identification
Clinical Decision
Support
Patient Education
and Engagement
Patient
Placement
Shared Decision
Making
Quality Data
Reporting
Outcome
Tracking
Patient
Treatment
40
BH Treatment Lifecycle
Brief
Intervention
or Referral
Brief Patient
Assessment
Full Patient
Assessment
Patient
Identification
EHRs
orDecision
PHRs can be used to:
Clinical
Support
Collect patient reported information
 Alert healthcare providers of patients at risk
 Educate
Patient
Education patient and link them to resources
andEngagement
Positive reinforcement
Patient
Placement
Shared Decision
Making
Quality Data
Reporting
Outcome
Tracking
Patient
Treatment
41
BH Treatment Lifecycle
Brief Patient
Assessment
Brief
Intervention
or Referral
Full Patient
Assessment
 EHRs/PHRs
can collect patient
reported
Clinical
Decision
Patient
Support
standardIdentification
assessments
 Computer adaptive testing to minimize
burden
Patient Education
and Engagement
 Automated Scoring to determine
the level
of risk
Shared Decision
 Alerts and reminders
Making
 To rule out alternative diagnoses
 To assess
contributing
physical health
Quality
Data
Reporting
problems
 To alert provider to critical risks (i.e.
suicidality)
Outcome
Tracking symptoms
 Collect standard data on patient
Patient
Placement
Patient
Treatment
42
BH Treatment Lifecycle
Brief Patient
Assessment
Brief
Intervention
or Referral
Full Patient
Assessment
Patient
Identification
Quality Data
Reporting
 Checklists
for evidence based care
Clinical Decision
Support
 Links to
clinical guidelines and
information
 Sharing
information with patients
Patient Education
and Engagement
 Linking
patients to community
resources
Patient
Shared Decision
 Consent
Management for health
Placement
Makingexchange
information
 Health Information Exchange tools
 Referral appointment scheduling
 Referral management
and follow up
Patient
Treatment
tools
Outcome
 Tracking
Care coordination tools
43
BH Treatment Lifecycle
Brief Patient
Assessment
Brief
Intervention
or Referral
Full Patient
Assessment
Patient
Decision supportClinical
for level
of
Decision
Support
care
Identification
 Treatment plan is autopopulated and modified
by
Patient Education
and Engagement
clinician
 Methods for capturing
standardizedShared
dataDecision
on nonpharmacologic Making
treatments
be needed
Qualitywill
Data
Patient
Placement
Reporting
Outcome
Tracking
Patient
Treatment
44
BH Treatment Lifecycle
 Evidence based practice checklists
Brief
 Links to clinical guidelines
Intervention
Brief
Patient
 Alerts to identify patients who are or
‘falling
Referralthrough
Assessment
the cracks’
Full Patient
 If critical prescriptions are not refilled
Assessment
 If appointments are missed
Clinical Decision
Patient
 PatientIdentification
progress monitoring Support
 Clinical decision support for adjusting treatment:
 Step up to the next level
of care
Patient
Education
 Continue in current care
level
and Engagement
 Enroll in recovery maintenance services
 Data standardization to ensure
interpretability
Patient
Shared
Decision
Placement
across providers
Making
 Care coordination
and management tools
Quality Data
Reporting
Outcome
Tracking
Patient
Treatment
45
BH Treatment Lifecycle
Brief
Intervention
or Referral
Brief Patient
Assessment
Patient
Identification
Quality Data
Reporting
Patient
 Structure, Process Full
and
Outcome
Assessment
measurement
Clinical Decision
 Individual
and community based
Support
results
 Determine if evidence based
Patient Education
were used
andprotocols
Engagement
 Assess the efficacy of individual
providers and healthcarePatient
systems
Shared Decision
 Public
Makinghealth reporting Placement
 Research to improve health service
delivery
Outcome
Tracking
Patient
Treatment
46
Learning Systems
 Data can be analyzed to correlate symptom profiles
and treatments used with Outcomes:
• Algorithm that determine the treatment plan can
be updated based on feedback loop
• Creates continuous learning environment
• Personalized medicine
• Support research into the biological basis of
behavioral health disorders
47
Patient Engagement
 Capturing patient reported data in the EHR
 Interface with the patient through a web portal or
PHR
 Provide the patient with health information tailored
to their own risks and to level of health literacy
 Provide community and online resources
 Tools to support shared decision making
 Goal setting and tracking
 Link with mHealth tools
48
SAMHSA HIT Activities: Patient Engagement

Mobile Health Tools
• Telephone Monitoring and Adaptive Counseling program,
part of Access to Recovery:
– Life: Wire – A text messaging platform that supports ongoing
client contact & a continuously updating database that can be
used to evaluate service effectiveness & make program changes to
support improved outcomes.
• Addiction Comprehensive Health Enhancement Support
System (A-Chess) –
– Features online peer support groups and clinical counselors, a GPS
feature that sends an alert when the user is near an area of
previous drug or alcohol activity, real-time video counseling, and a
“panic button” that allows the user to place an immediate call for
help with cravings or triggers.
49
SAMHSA HIT GRANTS
SAMHSA HIT Activities: Expansion Grants

SAMHSA awarded 29 Targeted Capacity Expansion (TCE)-Health
IT grants.
• To leverage technology to enhance or expand the capacity of
substance abuse treatment providers to serve persons in
treatment who have been underserved
• Examples include Web-based services, smartphones, and
behavioral health electronic applications (e-apps).
51
51
SAMHSA HIT Activities: Expansion Grants

SAMHSA has awarded 49 supplemental funds grants for
Health IT infrastructure for current primary and behavioral
health care integration (PBHCI) grantees.


To develop infrastructure that supports the exchange of health
information through EHR data systems.
Sub-awards support sharing of health records among
behavioral health providers and general medical providers
through a state HIE (ME, KY, IL, OK, RI)
•
Technological infrastructure
•
Privacy and Security Policies
52
Conclusion



Health IT has the potential to benefit behavioral health
treatment providers and their clients through increased
efficiency, coordination, and patient engagement.
42 CFR Part 2 provides the ability to share protected health
information, but it is the responsibility of the organizations to
use that information in a way that benefits the health of the
individuals.
SAMHSA is working to ensure that providers understand the
benefits of integrating Health IT into their programs and that
they have the training and tools to support their HIT goals.
53
HAVE QUESTIONS?
Now for your questions...
54
Office of the
Chief Privacy Officer (OCPO):
ONC Efforts to Maintain the Privacy of Health
Information Protected by 42 CFR Part 2
May 25, 2012
Scott Weinstein, JD
OCPO Overview
• Chief Privacy Officer position created in HITECH Act
• OCPO’s responsibilities include:
– Advise the National Coordinator on privacy, security, and data
stewardship of electronic health information
– Coordinate with other Federal agencies, State and regional efforts, and
foreign countries with regard to the privacy, security, and data
stewardship of electronic individually identifiable health information
56
SAMHSA, ONC-OCPO, and 42 CFR Part 2
• SAMHSA
– Enforces Part 2
– Provides Guidance to Providers on Part 2
Compliance
• ONC-OCPO
– Working with SAMHSA to explore technologies
that allow exchange of electronic substance abuse
clinical information while complying with Part 2
57
ONC initiatives that implicate 42 CFR Part 2
• Data Segmentation for Privacy
• Query Health
• SHPC Behavioral Health Data Exchange
Consortium
• State HIE Community of Practice Privacy and
Security Workgroup on 42 CFR Part 2
58
Data Segmentation for Privacy
Initiative
59
Data Segmentation for Privacy Objective
• Produce a pilot project that will allow providers to
share portions of an electronic health record while
not sharing others
• Certain privacy laws, such as 42 CFR Part 2, already
require providers to ensure that parts of a medical
record will not be shared without patient consent
• Data Segmentation for Privacy provides a means for
electronically implementing choices made by
patients under these laws
• Several use cases developed that focus on 42 CFR
Part 2
60
User Story Example (1)

 The Patient receives care at their
local hospital for a variety of conditions,
including substance abuse as part of
an Alcohol/Drug Abuse Treatment
Program (ADATP).

 Data requiring additional protection
and consent directive are captured and
recorded in the EHR system. The
patient is advised that the protected
information will not be shared without
their consent.
Provider/Healthcare Organization 1
61
User Story Example (2)


Provider/Healthcare
Organization 1
Provider/Healthcare
Organization 2
 A clinical workflow event
triggers additional data to be
sent to Provider/Organization
2. This disclosure has been
authorized by the patient, so
the data requiring heightened
protection is sent along with a
prohibition on redisclosure.
 Provider/ Organization 2
electronically receives and
incorporates patient
additionally protected data,
data annotations, and
prohibition on redisclosure.
62
User Story Example (3)


Alle
rgie
s
Alle
Provider/Healthcare
Organization 1
rgie
s
Provider/Healthcare
Organization 3
 The Patient receives care
for new, unrelated condition
and is referred by
Organization 1 to a specialist
(Provider/Organization 3).
Organization 1 checks the
consent directive and sends
authorized data to
Organization 3.
 Provider/Organization 3
electronically receives and
incorporates data which does
not require heightened
protection.
63
Segmentation of medical information
• Determine information covered by Part 2
– Use standardized terminology to express that data
came from a covered provider (“FacilityType”)
• Determine if patient has consented to share
protected information
– Consent refers to documents, document sections,
or individual data elements that may be sent
64
Application of Metadata
• Helps receiving EHR/HIO implement access
control
• Electronic enforcement of prohibition against
redisclosure of information
• Provides a reference to a consent document
that controls the data
65
Query Health
66
What is Query Health?
Objective:
• Enable a learning health system to understand
population measures of health, performance, disease
and quality, while respecting patient privacy, to
improve patient and population health and reduce
costs.
67
Improve community understanding of
patient population health
Questions about
disease outbreaks,
prevention activities,
health research,
quality measures, etc.
68
Summary: Query Health Specifications and Standards
Query Health must standardize how queries are asked, how they are
returned, and how the information travels between parties.
Specification
Definition
Standard
Query Envelope
A means to package the
query and results along with
security/privacy
requirements, as well as
other instructions
PopMedNet Query
Envelope
Query Format
The way in which a query is
constructed, its code,
vocabulary etc.
HQMF- Health Quality
Measures Format
Results Format
The way in which a result is
reported, its code,
vocabulary etc.
QRDA- Quality Reporting
Document Architecture
69
Policy Sandbox
Query requests and responses shall be implemented in the pilot to use the least identifiable
form of health data necessary in the aggregate within the following guidelines:
1. Disclosing Entity: Queries and results will be under the control of the disclosing entity
(e.g., manual or automated publish / subscribe model).
2. Data Exchange: Data will be either 1) mock or test data, 2) de-identified data sets or
limited data sets each with data use agreements1 or 3) a public health permitted use2
under state or federal law and regulation.
3. Small cells: For other than regulated/permitted use purposes, cells with less than 5
observations in a cell shall be blurred by methods that reduce the accuracy of the
information provided3.
Notes:
1. It is understood that de-identified data sets do not require a data use agreement, but in the
abundance of caution, and unless otherwise guided by the Tiger Team or HIT Policy Committee, the
pilot will have data use agreements for de-identified data
2. For a public health permitted use, individually identifiable health information may be provided by
the disclosing entity to the public health agency consistent with applicable law and regulation.
3. The CDC-CSTE Intergovernmental Data Release Guidelines Working Group has recommended limiting
cell size to three counts presuming a sufficiently large population. This is also reflected in Guidelines
for Working with Small Numbers used by several states.
70
Query Health and Part 2
• In future, Query Health technology may be
used to query identifiable patient information
• Must prevent identifiable Part 2 information
from being returned in response to a query
• Privacy metadata to restrict information from
being queryable
• Metadata in “query envelope” to
communicate sensitivity when information
allowed to be shared
71
State Health Policy Consortium
(SHPC) - Behavioral Health Data
Exchange Consortium
72
Purpose
• Pilot the interstate exchange of behavioral health
treatment records among treating health care
providers using Nationwide Health Information
Direct protocols
• Draft Policies and Procedures (P&P) for exchange
of behavioral health treatment records
• The focus is on meeting the requirements of
federal regulations at 42 CFR Part 2 and meeting
mental health laws of consortium states
73
Participants
• Consortium States are: Alabama, Florida, Kentucky,
Michigan, Nebraska and New Mexico; representatives
include legal and behavioral health subject matter experts
• Each state is to recruit Behavioral Health providers and
other providers that might exchange with Behavioral Health
providers to participate in the pilots
• Representatives of the ONC, Substance Abuse and Mental
Health Services Administration, the Legal Action Center and
subject matter technical experts on the NwHIN Direct
protocols
74
Workflow Scenarios for Discussion
Workflow #1: Request
for info

Workflow #2: Update
PCP
•
Florida Part 2
program requests
patient’s records
from prior stay at
Michigan
behavioral health
provider facility
(a Part 2
program)
Workflow #3: referral
At end of patient’s • Alabama PCP
stay, New Mexico
sends referral to
provider (who is a
Florida Part 2
Part 2 program
program
and a mental
health provider)
sends patient
summary to
patient’s PCP in
Kentucky
75
Workflow #1 – Request for Info
6
Receive
request for
records
along with
patient
consent
7
4
HISP
Send patient
records specified in
patient consent
Michigan Part
2 Program
5
HISP
Send
request for
records
along with
patient
consent
8
9
Jane
Patient
Receive requested
patient records
Florida Part
2 Program
3
1
2
76
Workflow #2 – Update PCP
5
Sends visit
summary
and
clarifying info
HISP
HISP
3
New Mexico
Part 2 Program 4
& Mental
Health
Provider
7
6
Receives
visit
summary
and
clarifying info
Jane
Patient
1
Kentucky
Primary
Care
Provider
2
77
Workflow #3 - Referral
3
2
Sends
referral
Alabama
Primary Care
Provider
HISP
4
HISP
Receives
referral
Jane
Patient
5
1
Florida Part
2 Program
78
State HIE Community of Practice
Privacy and Security Workgroup on
42 CFR Part 2
79
State HIE 42 CFR Part 2 Community of Practice
• Discuss compliance approaches for listing entities, including location,
formatting, and effective business processes for updates.
• Present examples of “break the glass” access and the feedback loop. The
focus will be on map process requirements, formatting, and efficiencies.
• Explain required notices and limitations on the re-disclosure of protected
information
• Discuss data protection and how data may be shareable in a query-based
HIE environment
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Thank you
Prepared in 2012 by –
the Legal Action Center,
under a subcontract from
Partners for Recovery
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