Executive Summary

Qualifacts + Credible continues its commitment to and support for information sharing, interoperability, the 21st Century Cares Act and state Health Information Exchanges (HIEs). Both the CareLogic EHR and the Credible Behavioral Health EHR platforms are designed to strategically future-proof customers from the ever-escalating information-sharing requirements of payers, MCOs, and Federal, regional, state and local regulatory bodies.

Interoperability and the Federal Office of the National Coordinator for Health IT (ONC)

At the Federal level, the Office of the National Coordinator for Health IT (ONC) is responsible for advancing the connectivity and interoperability of health information technology (HIT). According to section 4003 of the 21st Century Cures Act, HIT interoperability:

(A) enables the secure exchange of electronic health information with, and use of electronic health information from, other HIT without special effort on the part of the user;

(B) allows for complete access, exchange and use of all electronically accessible health information for authorized use under applicable State or Federal law; and

(C) does not constitute information blocking as defined in section 3022(a).”

A Decade of Federal Interoperability Certifications

Enhancing interoperability for the CareLogic and Credible EHRs has been part of the Qualifacts + Credible mission for more than a decade. From earning federal certifications through the phased iterations of the federal Meaningful Use Health IT incentive program and its repositioning as Promoting interoperability, to supporting partners who attest to the MACRA federal quality program or even enabling provider agencies to meet the requirements of national and state models for Certified Community Behavioral Health Clinics (CCBHCs), we have been at the forefront of advancing interoperability.

The Qualifacts + Credible commitment to interoperability and information sharing also includes supporting and complying with the 21st Century Cures Act, whose mandates include making healthcare data available to consumers.

ONC includes in its patient engagement playbook the position that better communication leads to better care and better outcomes. These goals are facilitated by easy enrollment and active portal features that ensure that all patients can access and understand information relevant to their care.

“Information sharing with the people receiving care empowers them to make decisions that will improve their outcomes,” said Hope Winkowski, Qualifacts + Credible Vice President of Outsourced Billing & Product Compliance. “Interoperability also supports provider teams to participate in shared plans, with visibility into analytics and metrics, whether team members are all onsite or care is being managed through partnerships and referrals.”

“The information-sharing components of the 21st Century Cures Act build on the right of access provision that is a central component of the Health Insurance Portability and Accountability Act (HIPAA). This provision requires providers to allow patients to inspect, access and copy their medical records,” said Holly Carman, Qualifacts + Credible Compliance Manager. “The 21st Century Cures Act and the HIPAA Privacy Rule both regulate disclosure of Protected Health Information (PHI).”

The Centers for Medicaid and Medicare Services (CMS), Interoperability and CCBHCs

“Interoperability supports shared information to drive coordinated care, and information sharing is at the heart of the CCBHC mission with its emphasis on whole-person care. This includes the wraparound services that are part of the social determinants of health, which can so greatly support an individual’s treatment plan, care and progress,” said Mary Givens, Qualifacts + Credible CCBHC Program Manager. “The CCBHCs are supporting a new level of coordinated care, and higher demands for information sharing are part of that, from tracking readmission notifications to monitoring comorbidities such as diabetes. Mitigating barriers like homelessness or lack of transportation that hinder people from participating in their care is also key.”

The CMS Final Rule on Interoperability and Patient Access aligns with the CCBHC prioritization of visibility into and support for whole-person care by mandating the exchange of Admission, Discharge and Transfer notifications, which keep providers updated as to changes in a person’s care status. “The CMS Interoperability and Patient Access final rule establishes policies that break down barriers in the nation’s health system to enable better patient access to their health information, improve interoperability and unleash innovation while reducing the burden on payers and providers.”

Interoperability and State Health Information Exchanges (HIEs)

Another goal of interoperability is to support state Health Information Exchanges (HIEs), which have a long history of driving whole-person care at the local level. State HIEs enable providers to connect people with their information and their care teams, securely facilitating the sharing of health data across information systems.

ONC gave states and territories a major infusion of grant money in 2010 when 56 awards totaling $548 million were distributed to develop and advance HIE resources. The aim was to facilitate the exchange of health information among health care providers and hospitals within their jurisdictions to encourage and support information exchange across states. Additional federal and state funding has since supported HIE growth, from Alabama to the Virgin Islands. This initiative is vital because interoperability with a state HIE can enhance visibility into a client’s total health record, enabling care teams to work together more effectively for better outcomes.

Interoperability, Information Sharing, and Coordinated Care

To achieve federal and state interoperability compliance while also meeting the demands of payer contracts and meeting organizational objectives to enhance the quality of care, behavioral health and human services provider agencies need a connected EHR that facilitates access to and retrieval of clinical data. This level of data access can promote patient-centered care that is not only safer but more timely, efficient, effective and equitable.

Admission, Discharge and Transfer (ADT) workflow data triggers support greater care coordination and collaboration across healthcare settings, with validated data, ease-of-use, data visibility, frictionless exchange of info and awareness of clinical data and updates. Updates shared across providers can inform care teams of client care information and status changes from hospitalizations to lab test results. “As the COVID-19 pandemic has brought to light, there has never been a greater need for secure, easy health data sharing and transparency,” said Robert Patton, Qualifacts + Credible Vice President for Implementation Services. “Interoperability supports more informed clinical decision making and real-time event notification can help teams avoid duplicative tests and assessments, which saves time and creates efficiency gains for clients and providers.”

“Automatically sharing client demographics and summary care of information, such as kept appointments or admission to or discharge from a program, can enhance the interactions of care teams when they are making cross-program decisions for clients with complex histories,” said Meredith Howell, Qualifacts + Credible Integrations Practice Lead. “Both of our EHR platforms support the guiding principles of interoperability by supporting data accuracy and oversight with privacy and security.”

“Our two EHR platforms are continuing to invest in care coordination, analytics and enhanced support for outcomes and metrics. These investments enable provider teams and leadership to meet the ongoing challenges of care coordination, compliance and contract requirements that are increasingly metrics-based, performance reviewed and managed through data-driven decision making,” said Eric Arnson, Qualifacts + Credible Chief Product Officer. “Data availability at the point of care is as important for the success of treatment plans as analytics and metrics are for organizational success. Our two EHR platforms share those same customer success goals.”


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