Update: September 12, 2012
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Regulation and law require patient specific
consent for sharing of information.
The main goal of Health Homes is the
coordination of care and services across
multiple different types of entities for a
Medicaid member with complex health
issues.
The NYS DOH goal – Single consent form
could act as a consent for Health Home
services and Health Information Exchanges
(HIE) including RHIOs.
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The NYS DOH Health Home consent form was
difficult for some RHIOs and Health Homes to
operationalize:
 If the member withdrew consent from the
Health Home, he/she would also withdraw
consent for each of those entities to access
the RHIO’s HIE.
 RHIOs use different platforms/consent
management for their HIE. Some can manage
multi-entity consents; some cannot.
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The Unreachable Goal?
A single consent that allowed Health Home access to
the member’s PHI and allowed sharing through the HIE.
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Consent Form 5055 – revised to allow:
 Lead Health Home to access the RHIO’s HIE for information
on the member
 Lead Health Home share that information with other
Health Home partners.
Form 5058 (withdrawal of consent) now only affects the
RHIO’s relationship with the lead Health Home.
Consent continues to allow Health Home partners to share
PHI of the member.
OHIP has worked with OHITT, DOH attorneys, and the
attorneys from OMH and OASAS on this revision and
obtained their signoff.
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Outreach and engagement activities are
supported by the limited information the NYS
DOH can provide to the Health Home without a
patient consent.
When the Care Manager determines that the
member is in active case management (actively
engaged with the member beyond outreach and
engagement activities) is the beginning of “active
care management”.
The member does not need to sign a Health
Home consent to be in active care management.
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Because many of the HH eligible members may
be disenfranchised from the health care system,
they may not immediately be comfortable signing
a consent.
Without the consent, the HH care manager
cannot share PHI. This does not mean the HH
care manager cannot work with the member in
care management activities.
The goal is to have the member sign the consent
so all providers involved in the member’s care
has access to the same information to better
serve the member.
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The consent does not have
to signed for care
management activities to
begin in the Health Home.
We do not link these two
together.
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1.
2.
3.
Modifications
Functional schematic
FAQs
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New format allows better personalization for listing
member’s particular providers◦ No need to list all HH partners
◦ No need to define a ‘core’ list of HH partners
◦ List the providers that are needed for each member
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Specifies that the members of the Health Home listed
at the end of the consent are allowed to share
information regarding the member.
Specifies that the lead Health Home can access the
RHIO’s health information exchange and share
information from there with the designated Health
Home providers.
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Improves/clarifies language in other parts.
Continues to allow sharing of all PHI as listed
on the document.
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HH
Partner
HH
Partner
Care
Management
Record
HH consent
(5055)
RHIO
consent
Lead
Health
Home
RHIO
consent
HIE
RHIO
consent
RHIO
consent
HH
Partner
Health Home Care
Management
Network
Agency
outside HH
RHIO Data
Contributors and Viewers
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The members served by health homes are chronically ill, often
disenfranchised from even the fragmented system of health care they
access and often have hierarchical concerns for food and shelter. They
often have low trust of the system and low health literacy, both adding
to their concerns of interacting with the health care system.
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The goal of the NYS DOH was to have one consent that could be signed
to open the Health Home gateway of care to quickly meet critical care
needs, build trust in accessing the system of care, and build selfreliance skills in managing health care conditions.
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The goal of the Health Home consent form is to allow the Health Home
member’s PHI to be shared with the member’s Health Home team.
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A Member’s Health Home team is comprised of all providers (physical,
behavioral, social services) involved in member’s care.
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The original consent form was operationally difficult for Health Homes
and RHIOs to implement and linked to the RHIO consent so that if a
member withdrew his/her Health Home consent, it impacted the RHIO
consent process.
We modified the consent to address the implementation issues by
separating the Health Home consent from the RHIO consent process
except for the lead Health Home which still has its RHIO consent tied to
Form 5055.
Health Home partners must now obtain a separate signed RHIO consent
form to allow those partners direct access to the RHIO.
The original consent form was approved by all the appropriate state
agencies. Likewise, this consent has been reviewed and approved by
OMH, OASAS and DOH. It includes the necessary language from the
NYeC consent.
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The signing of the Health Home consent form
will serve two distinct functions. It will allow
the Health Home care providers to share
patient information, and it will allow the lead
Health Home to access patient information
directly from the local RHIO.
17
A signed RHIO consent form will only allow
access to the RHIO if the organization is a
member of or has a data sharing relationship
with that local RHIO.
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Each individual entity or organization that
seeks membership in a RHIO is responsible to
pay for their membership in that RHIO.
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The Health Home consent form is only a
proxy for the RHIO consent form for the lead
Health Home. It is not the RHIO consent for
all other Health Home partners. They will
need to follow the consenting process in
place for their local RHIO. The Health Home
consent form is for data sharing among the
relevant members of the Health Home and
allows the lead Health Home only to data
share with the RHIO.
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A multi-entity RHIO consent form is permitted
but is not required.
21
The RHIO can use the Health Home consent form
as their multi-entity consent form but if the
member withdraws consent (form 5058) from the
Health Home, the RHIO consent would be lost as
well.
If a form 5058 is signed to withdraw from the
Health Home (where a single-entity RHIO consent
was used), only the lead Health Home’s access to
the RHIO for that member is ended.
22
No, a Health Home member is considered
enrolled in a Health Home once the member
is assigned to a Health Home.
23
No, a member can be considered in active
care management without having signed a
Health Home consent form.
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No, a member can remain in a Health Home and in
active care management as long as the care
manager can demonstrate s/he can advance the
member’s care plan and improve the member’s
health status without signed consent
Care Managers need to work with members so they
understand the importance of signing a consent.
Care Managers should assure that only the
providers involved with that member’s care and
needed to get PHI are listed on the consent.
Without a consent, there is a limited ability to share
member health information; defeating the purpose
of the Health Home.
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A signed Health Home consent form can allow
a lead Health Home access to more than one
RHIO if each of the RHIOs that will be directly
accessed is named on the consent form. In
other words, the member must give
permission for each of the RHIOs the Health
Home is directly accessing for his/her health
information.
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The lead entity Health Home must be able to
transmit and receive data electronically with its
associated organizations and providers. Health
information exchange through a RHIO would be
the preferred way to do this. However access for
data sharing is managed in a RHIO would be the
appropriate mechanism. RHIOs may require an
entity to become a member of the RHIO and sign
a participation agreement. Some may have a
service charge for data transmission or
membership fees. The RHIO manages this as it
would for any other data sharing entity.
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If the Health Home and RHIO can
operationalize the original version of Form
5055, the member will not be required to
sign the updated version.
If the RHIO cannot operationalize the original
consent form, the newer version will need to
be signed again.
28
If a Health Home withdrawal (Form 5058) is signed,
permission to share new data among Health
Home partners is negated and the lead Health
Home loses RHIO access for that patient.
It is important to remember that any patient data
that has already been shared prior to the signing
of the 5058 does not have to be removed from
the Health Home lead or partners EHR or Care
Management Plan.
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It is likely that many of the data exchanges in a
Health Home would fall under 1:1 exchanges
both within and outside the network. The Health
Home member consent should cover such an
exchange. However, without a RHIO consent in
place, the Health Home cannot pull data from the
HIE. Given the fragmented health care and lack
of provider loyalty that many of these members
have had, it will be crucial at least in the
beginning to be able to pull data and not just
push data or be the recipient of a 1:1 push of
data.
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Any questions?