A Single Point of Disclosure

The American Recovery and Reinvestment Act of 2009 (ARRA) states that the HIT Policy Committee shall make recommendations on standards, implementation specifications, and certifications criteria in eight specific areas (the ARRA 8) including "Technologies that support accounting of disclosures made by a covered entity" .

The first draft of meaningful use includes three requirements for Population and Public Health data disclosure:

-Submit electronic data to immunization registries where required and can be accepted
-Submit electronic reportable lab results to public health agencies
-Submit electronic syndrome surveillance data to public health agencies according to applicable law and practice

How can Massachusetts enable these data exchanges and at the same time document disclosure?

The answer lies in the New England Healthcare Exchange Network which has served as the Massachusetts healthcare data exchange since 1998.

I've recently met with many stakeholders:

- the Boston Public Health Commission
- local, state and federal biosurveillance organizations
- quality registry hosting entities
- the Social Security Administration

All have agreed that instead of point to point heterogeneous interfaces, data should be disclosed via a standards-based gateway for secure electronic communication.

Here's a vision for Massachusetts:

- Today, all our payers and providers host a NEHEN gateway or have access to a hosted NEHEN Software as a Service called NEHEN.NET

- public health and population health organizations such as the Public Health Commission, Department of Public Health, Massachusetts eHealth Collaborative Quality Registry, and the Social Security Administration should add a NEHEN gateway to their organization. They could then stop using FTP, VPNs, leased lines, or proprietary web uploads for data collection.

- As part of our NEHEN architecture, we have a Participant Directory that contains gateway to gateway routing information. In addition to providers, this directory can contain public health and population health organizations.

- All future disclosures will be made from payers and providers to data collection organizations via NEHEN gateways.

-This means that one set of policies, one set of gateway software, and one set of standards is used for data transmission and disclosure logging throughout Massachusetts.

I have volunteered to move the BIDMC's Social Security Administration transmissions and the Public Health Commission data exchanges from proprietary transmission approaches to the NEHEN gateway.

Although there is still much work to do to ensure the NEHEN gateway can connect to all local, state and federal data gathering entities, the economies of scale of building one transmission/routing mechanism and just changing the payload as needed is appealing to everyone.

NEHEN is currently completing healthcare information exchange work in support of ARRA clinical coordination goals. Once that is done, it is clear that a single point of disclosure for Population and Public Health data exchange is a high priority next step.