What is an OHCA? Data Sharing Issues in Integrated Delivery Systems - - PowerPoint PPT Presentation

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Dec 24, 2022 210 likes •466 views

What is an OHCA? Data Sharing Issues in Integrated Delivery Systems L E AR N I N G C O L L AB O R AT I V E AU G U S T 3 0 , 2 0 1 6 R AN D Y F L O Y D G E N E R A L C O U N S E L , C O M M U N I T Y C A R E C O L L A B O R AT I V E B E

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What is an OHCA?

Data Sharing Issues in Integrated Delivery Systems

L E AR N I N G C O L L AB O R AT I V E AU G U S T 3 0 , 2 0 1 6 R AN D Y F L O Y D G E N E R A L C O U N S E L , C O M M U N I T Y C A R E C O L L A B O R AT I V E B E T H D E V E RY G E N E R A L C O U N S E L , C E N T R A L H E A LT H D I R E C T O R , H E A LT H C A R E S E R V I C E S , T R AV I S C O U N T Y AT T O R N E Y ’ S O F F I C E

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Disclaimer

The purpose of this communication is to provide general information that is of a legal nature. It does not contain a full analysis of the law nor does it constitute an opinion

f Central Health, the Travis County Attorney’s Office or

the Community Care Collaborative on points of law presented.

SLIDE 3

Agenda

What is an OHCA?
OHCA advantages
Common hurdles
Developing an OHCA
Risks

SLIDE 4

What is the CCC?

A non-profit corporation created by Central

Health, the hospital district in Travis County, and Seton Healthcare Family

Provides care to the covered population in

Travis County

Works with:
Dell Medical School at The University of Texas
Seton Healthcare Family
Austin Travis County Integral Care
Local federally qualified health centers
Other providers

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What is the Goal of the CCC?

Develop an integrated delivery system (IDS) for patient care in Travis County for the covered population

Coordinate health care services across a

spectrum of primary care, specialty, hospital and social service providers

Improve health outcomes
Serve as a model for high-quality, cost

effective and person-centered care

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What is an OHCA?

OHCA stands for:

Organized
Health
Care
Arrangement

SLIDE 7

Covered Population

Who is included?
Whose information can be shared?
Shared notice of Privacy Practices?

SLIDE 8

45 C.F.R. §160.103

OHCA for the CCC:

Organized system of health care for more than one

covered entity

Entities hold themselves out as participating in

joint activities

Entities participate in joint activities like: utilization

review, quality assessment and improvement, payment activities

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Public Disclosure

The CCC and the participants hold themselves out to the public as participating in a joint arrangement to perform some or all of the following joint activities:

Utilization Review
Quality Assessment and Improvement
Payment activities

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OHCA Goals

Improve quality of care
Create a Longitudinal Patient Record for use at the

point of care

Population management and utilization
State, national and regional health reporting

including Delivery System Reform Improvement Project milestones

Financial analysis
Predictive analytics and clinical decision making

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Operationalizing

Information Management
IT Compatibility
Insurance

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Information Management

Data Warehouse
Point of Care Record (Longitudinal Patient

Record)

CCC Data Set

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IT Compatibility

Can take different forms, depending on

participants

Can require interfaces between providers’

EHR platforms

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Insurance

Requiring it of your organization
Requiring it of the participants
Growing area of cyber/network

security/privacy liability

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Core Documents

Participation Agreement
Policies and Procedures
Notice of Privacy Practices
Cyber liability coverage

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Core Structure

Policies and Procedures
Participation Agreement
Purposes
Definition of the Data Set
How to change process
Language used in the NPP
Plumbers of Choice

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OHCA Advantages

Improved quality of care
Efficiencies
Greater Continuity of Care
Population Health Management
Common Data Set
Sharing of clinical data for patient care

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Sharing of Clinical Data

Allows providers to access clinical data to provide more appropriate, efficient, and better quality of care

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Sharing of Clinical Data

Disparate providers can share standardized data

sets

Avoids redundant test results
Visibility in the system of care
Patient Navigation
Care Coordination

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Efficiencies

Clarity of relationships – replaces multiple

Business Associate Agreements

No authorizations (except as legally

necessary)

Holding out to the public as an OHCA
Notice of privacy practices

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OHCA Challenges Participant Buy-In

Disparate members
Different data policies
Different business plans
Different populations
Different coverages

SLIDE 22

OHCA Challenges

Different payers
Complex and novel conception of sharing

data

Potential up-front infrastructure costs
Control
Agreement on a covered population

SLIDE 23

OHCA Challenges

Longitudinal Patient Record

Not always an easy adoption process
Not always used for intended purposes
Providing the right level of access

SLIDE 24

Future Expansion – New Participants

Smaller providers in the system
Non-medical providers
Sensitive PHI

SLIDE 25

Questions

DISCLAIMER: THE PURPOSE OF THIS COMMUNICATION IS

TO PROVIDE GENERAL INFORMATION THAT’S OF A LEGAL NATUR E. IT DOES NOT CONTAIN A FULL ANALYSIS OF THE LAW NOR DOES IT CONSTITUTE AN OPINION OF TRAVIS CO UNTY ATTORNEY’S OFFICE OR THE COMMUNITY CARE CO LLABORATIV E O N POINTS O F LAW PRESENTED .