Agency for Health Care Administration, Departmental  

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    AGENCY FOR HEALTH CARE ADMINISTRATION
    Departmental

    Florida Health Information Network

    Request for Public Comment

    The Agency for Health Care Administration (the Agency) is inviting public comment and input on the best way to establish a state wide health information network which will integrate local regional health information organizations (RHIOs) and state-owned health databases in Florida and to coordinate data exchange with other health information networks across the country. The agency will accept response narratives from the time of this publication until COB December 14, 2006.

    Health care providers, consumers, health information technology organizations, industry associations and others are invited to provide public comment in the interest of having the broadest perspective on the role in which state government should play in the development and operation of a statewide health information infrastructure and how such a network may be supported by the private sector.

    Purpose of Request for Public Comment

    The Agency and the Governor’s Health Information Infrastructure Advisory Board (the “Board”) have coordinated a collaborative among interested parties to prepare a white paper that outlines certain considerations in the implementation of a statewide network. That white paper is available online at: http://ahca.myflorida.com/dhit/ FHIN_White_Paper.shtml

    The purpose of the Agency’s request for public comment is to seek input from interested parties on options for the financing, development and operation of the Florida Health Information Network (FHIN). Without limiting the generality of the purpose articulated in the preceding sentence, the Agency specifically would welcome responses that answer the following questions:

    1.The impetus for considering a FHIN is to achieve interoperability of health information technologies used in the delivery of care in Florida as specified in Section 408.062(5), F.S.

    Is the working definition of the Florida Health Information Network provided by the Agency in the white paper appropriate? Should it be modified? And if so, in what way?

    2.Has the agency identified the correct functionalities of and the specifications for the statewide infrastructure? As identified by the Agency, these include:

    Enterprise master patient index;

    Record locator service;

    Web services interface for connection to RHIO servers;

    Database infrastructure for state agency datasets;

    Database software for querying patient records in state agency databases;

    Credentialing and authentication of users including query software for access to physician licensing information at the Department of Health, Privacy and security requirements including authorization and access controls; and

    Web portal for querying data directly from the FHIN.

    3.Is the detailed pro forma budget (found on page 54 of the white paper) reasonable? If not, how should it be amended and why?

    4.What is the most appropriate method for funding the development of the Florida Health Information Network and what are the justifications for the suggested funding source(s)?

    5.What is the appropriate method for funding the operation of the statewide network on a sustainable basis?

    6.How should the entity that will operate the Florida Health Information Network be structured and what is the ideal governance model? Are there benefits to a non-for-profit organization vs. a for-profit organization? Should the state consider a statutorily- created public/private partnership?

    Background or Current Project Description

    The impetuses for development of the FHIN are contained in the following statutory and executive authority and mandates:

    A.Section 20.42(3), F.S. specifies that the Agency for Health Care Administration is Florida’s chief health policy and planning entity.

    B.Section 408.062(5), F.S. specifies that “the agency shall develop and implement a strategy for the adoption and use of electronic health records, including the development of an electronic health information network for the sharing of electronic health records among health care facilities, health care providers, and health insurers. The agency may develop rules to facilitate the functionality and protect the confidentiality of electronic health records.”

    C.Section 2, of the Governor’s Executive Order Number 04-93. This executive order created the Governor’s Health Information Infrastructure Advisory Board and assigned it the following responsibilities:

    1.The Advisory Board shall advise and support the Agency for Health Care Administration (“Agency”) as it develops and implements a strategy for the adoption and use of electronic health records and creates a plan to promote the development and implementation of a Florida health information infrastructure, including measures to promote greater adoption of electronic health record information systems among the state’s health care providers;

    2.The Advisory Board shall identify obstacles to the implementation of an effective health information infrastructure in the state and provide to the Agency policy recommendations to remove or minimize those obstacles;

    3.The Advisory Board shall advise appropriate parties within the Executive and Legislative branches on issues related to the development and implementation of the health information infrastructure; and

    4.The Advisory Board shall assist the Agency in ensuring that the strategy and plan preserve the privacy and security of health information, as required by state and federal law.

    This FHIN initiative proposes an internet-based, statewide network that will integrate communications and data transfer among local RHIOs, establish standards for health information exchange and promote health information exchange among authorized health care providers.

    The FHIN is envisioned as a statewide health information infrastructure that will enable health care professionals to access a patient’s medical records from any provider database connected to the network over a secure internet connection. The FHIN represents a collaborative effort between the public and private sectors, state and local governments, RHIOs and health information exchanges, providers, employers, consumers, health plans and payors. It proposes to interconnect health care providers across Florida to facilitate the sharing of health care data without regard to where in the state the consumer resides or where the health care was delivered. The FHIN infrastructure will allow local RHIOs the greatest amount of flexibility in implementing their plans to integrate health care data in their communities.

    Response Narrative Format

    Interested parties who choose to offer public comment should do so in writing and should address each of the component services listed in the Purpose of Request. The discussion can address each component separately, or in an integrated manner. There is no limit to the number of pages in the response. All narrative text should be double spaced, with 1 inch margins. Please identify discrete sections through the use of clear headings.

    Please include the title that appears above, “Florida Health Information Network,” and identify the respondent, address, telephone number, fax number and e-mail address of respondent on the cover page of the Response Narrative. The response narrative should be submitted in three (3) copies and in electronic format readable by Microsoft Word.

    Questions on the Request for Public Comment

    Direct questions concerning this request to:

    Lisa K. Rawlins, Bureau Chief

    Florida Center for Health Information and Policy Analysis

    Agency for Health Care Administration

    2727 Mahan Drive, Mail Stop #16

    Tallahassee, FL 32308-5403 

    E-mail: FHIN@AHCA.MyFlorida.com

    Telephone: (850)922-7036

    Fax: (850)414-7831

    Process for Submitting Response

    Submit all Response Narratives by December 14, 2006 to:

    Lisa Rawlins, Bureau Chief

    Florida Center for Health Information and Policy Analysis

    Agency for Health Care Administration

    2727 Mahan Drive, Mail Stop #16

    Tallahassee, FL 32308-5403 

    E-mail: FHIN@ahca.myflorida.com

    Timeline for Agency Review

    The Governor’s Health Information Infrastructure Advisory Board will convene on, December 7, 2006, in Miami, Florida, to receive comments from the public and address specific questions about the request for public comment. The Board invites health care experts to an open dialog regarding the development of FHIN during the meeting. The Agency response to specific questions will be posted on the agency website at: http://ahca.myflorida.com/dhit/FHIN_White_ Paper.shtml

    The Governor’s Health Information Infrastructure Advisory Board will convene on December 19, 2006, via telephone conference to publicly review a compilation of the comments at the December Board meeting, scheduled from 1:00 p.m. – 3:00 p.m. During the scheduled Board meeting, time is allocated for further public input.

    Proprietary Information and Public Records

    Written responses received by the Agency will be public records under Chapter 119, Florida Statutes. Organizations must indicate which portions, if any, of the information being provided is proprietary and confidential, by marking each page upon which such information appears as follows: “The information on this page is proprietary and a trade secret under Section 812.081, Florida Statutes.” Failure to do so will result in all submitted information being subject to public disclosure in accordance with the Florida Government-in-the-Sunshine- Law, subsection 286.011(1), and Chapter 119, Florida Statutes.

    Responsibility for Costs in Preparing Response

    Responses to this request are strictly voluntary on the part of the responder. Organizations are responsible for all costs associated with preparing a response to this Request for Public Comment and the state of Florida, Agency for Health Care Administration, Florida Center for Health Information and Policy Analysis will not be responsible for any organization costs associated with preparing this information.

    TO RESPOND: The Florida Health Information Network White Paper and all relevant materials will be posted at: http://ahca.myflorida.com/dhit/FHIN_White_Paper.shtml

    beginning November 20, 2006. The Governor’s Health Information Infrastructure Advisory Board will hear public comments on the White Paper on December 7, 2006, 9:00 a.m. to 1:00 p.m. at:

    Health Choice Network

    9064 N. W. 13th Terrace

    Miami, Florida 33172 

    Information on the December 7, 2006, Board meeting is posted at: http://ahca.myflorida.com/dhit/meetings.shtml

    All written comments on the White Paper are due by December 14, 2006. Inquiries regarding the White Paper must be submitted by December 5, 2006.

    INQUIRIES AND CONTACTS: All comments must be submitted by e-mail to FHIN@ahca.myflorida.com. Answers to inquiries received by December 5, 2006, will be made available on the website. All general correspondence relating to this request for comment should be directed to: Florida Health Information Network, Florida Center for Health Information and Policy Analysis, Florida Agency for Health Care Administration, 2727 Mahan Drive, Mail Stop #16, Tallahassee, FL 32308.

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