SLIDE 9 Preliminary Findings (Stakeholder Input Ongoing)
Current eCR Approach Scalability Issue(s) Potential Modification(s) Responses 1.
DSI acts as BA of provider (or HIE) sending case report
- Inherent privacy breach risks
associated with role of BA;
- Administrative costs of BAAs;
DSI acts as agent of public health authority
- Public health agencies may not delegate
authority to DSI;
- DSI taking on BA’s risks could be “selling
point” for eCR;
- Administrative costs of BAAs mitigated
through trusted exchange frameworks
2.
Two levels of case adjudication logic:
- Primary logic that is nationally
consistent and implemented in provider’s EHR (i.e., “trigger codes”, “RCTC”)
jurisdiction-specific and implemented in DSI (i.e., “RCKMS”) HIPAA risks associated with provider reporting non-reportable conditions to DSI (i.e., primary case adjudication logic may “over report” to DSI) DSI distributes both primary and secondary case adjudication logic for implementation at EHR, HIE (or) Provider sends de-identified case report to DSI for secondary case adjudication, then sends identified case report as indicated by adjudication
- Primary case adjudication logic (RCTC
“trigger codes”) based on “reasonable suspicion” of reportable case;
- At present, not technically feasible to
distribute both primary and secondary case adjudication logic to EHRs, HIEs;
- At present, insufficient resources to re-
engineer DSI for de-identified case reports
3.
Emphasis on primary case adjudication and case report construction at point of care (i.e., in EHR) Some potential implementers may be motivated to implement case adjudication and case report construction in an HIE (or similar) environment Case adjudication (primary or secondary) and case report construction is implementable in EHRs or HIEs (or environments accessible to EHRs and HIEs) At present, not technically feasible to distribute both primary and secondary case adjudication logic to EHRs, HIEs FOR DISCUSSION USE ONLY – January 2018
