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What Public Health Leaders Need to Know About HTI-2 Proposed Rule

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What Public Health Leaders Need to Know About HTI-2 Proposed Rule How Proposed HTI-2 Rule Will Benefit Public Health Data Exchange Lillian Colasurdo, Lana McKinney, Alexandra Woodward Read how the HTI-2 rule improves upon HTI-1 standards and criteria for data exchange among public health, health care, and data providers to benefit public health. On July 10, 2024 HHS’s Assistant Secretary for Technology Policy/Office of the National Coordinator of Health Information Technology (ASTP) published the proposed rule: Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2). This rule, which advances interoperability and supports access, exchange, and use of electronic health information (EHI), represents a significant step towards strengthening public health data infrastructure and promotes interoperability between health care and public health entities. It proposes significant changes impacting public health agencies (PHAs) and removing barriers to EHI exchange, while attempting to streamline health IT processes. Background Two of the most significant federal laws passed in the past fifteen years for health data exchange are the Health Information Technology for Economic and Clinical Health (HITECH) Act and the 21st Century Cures Act. Together, these laws provided ASTP with authority to set standards for and certify heath information technology. ASTP’s certification program mandates that electronic health records (EHR) comply with the new standards and eligible providers and hospitals must use certified technology to be fully reimbursed by the Centers for Medicare & Medicaid Services. Additionally, these laws grant ASTP rulemaking authority. Earlier this year, ASTP finalized the HTI-1 rule, taking substantial steps toward improving public health and health care data exchange. This rule requires EHR systems to support either HL7 Clinical Document Architecture (CDA) or Fast Healthcare Interoperability Resources (FHIR) standards for electronic case reporting, both of which enhance the data quality and timeliness for public health reporting. HTI-1 also directs EHR developers to track and report on the amount of data electronically submitted to Immunization Information Systems (IISs); that information helps improve vaccine product distribution and availability. While the rule sets the stage for a future transition to a FHIR-based approach for case reporting, there must be an adequate transition period for public health agencies. While HTI-1 took significant steps toward improving the way data is exchanged, primarily in the health care setting, the proposed rule HTI-2 aims to expand these standards to further benefit public health. The HTI-2 expands upon the interoperability standards established in HTI-1 and aims to improve interoperability by revising the ONC Health IT Certification Program. It specifically proposes two new sets of certification criteria for IT developers that will benefit public health entities and payers. Public health agencies face many barriers to efficiently exchanging data with health care providers and other entities including lack of common data standards, inconsistent reporting requirements, limited system interoperability, and inadequate public health data infrastructure. HTI-2 addresses these challenges by establishing certification criteria for public health technologies, creating a common floor to support data exchange. In addition, HTI-2 introduces changes to the Information Blocking Rule and provides transparency to Trusted Exchange Framework and Common Agreement (TEFCA) requirements. Micky Tripathi - What PH Leaders Must About HTI-2 Proposed Rule Key HTI-2 Provisions Certification Criteria, Standardizing Application Programming Interfaces (APIs) HTI-2 proposes four standards and certification criteria that may impact public health systems. Depending on the criteria, ASTP proposes that many of them be implemented by the beginning of 2027 and 2028. Updating naming conventions and standards for existing functional criteria. There are currently nine functional (or “f”) criteria EHRs must meet to exchange data with public health agencies. The updated naming conventions and standards point EHR vendors and public health systems to the latest standards for implementation. Additionally, these updates include two new criteria for birth reporting and bi-directional exchange with a prescription drug monitoring program. Establishing new certification “f” criteria for Health IT so Public Health certified systems can receive, validate, parse, and filter standardized data. These functions will apply to immunization, syndromic, laboratory, cancer pathology, case, birth, and prescription drug monitoring program data. Adopting the United States Core Data for Interoperability (USCDI) version 4, a standardized set of health data classes and elements for interoperable health information exchange. Version 4 includes several new data elements relevant to public health, such as health status assessments (e.g., alcohol and substance use). Standardizing HL7 FHIR-based API for public health data exchange by creating new certification criteria to support ongoing development and transition to FHIR for patient and population-level data exchange. CDC and ASTP have noted potential benefits of increasing public health access to critical data while reducing the reporting burden on both health care organizations and developers. HTI-2 proposes similar certification standards and alignment for reporting to payers that comply with existing CMS API requirements. Information Blocking Updates The Information Blocking Rule requires that patients have timely access to their own electronic health records and prohibits health care providers and networks, HIEs, and developers from interfering with said access. When a public health agency serves as a provider, it is crucial to ensure that patients can access records in compliance with the existing rule. HTI-2 clarifies what constitutes “interfering” with the access and exchange and provides a non-exhaustive list of examples. HTI-2 also proposes a new exception to information blocking—the Protected Care Access Exception—that would “apply to acts or omissions likely to interfere with access, exchange, or use of particular EHI that an actor believes could create a risk of exposing patients, care providers, and other persons who assist in access or delivery of health care to potential administrative, civil, or criminal investigations or other actions on certain bases.” This exception is particularly relevant for jurisdictions with more restrictive laws for sharing reproductive health data. TEFCA Governance Rules As ASTP and its Recognized Coordinating Entity (RCE), the Sequoia Project, seek to establish standards for implementing the Trusted Exchange Framework and Common Agreement (TEFCA), the proposed HTI-2 rule would codify one portion of the framework by establishing the qualifications for Qualified Health Information Networks (QHINs), onboarding and designation processes, the attestation process, termination and appeal rights, and ASTP’s formal authority to delegate responsibility to the RCE. Conclusion The HTI-2 proposed rule represents a significant step towards strengthening public health data infrastructure and promotes interoperability between health care and public health entities. It is specifically designed to “address gaps in public health data and help the nation become response-ready, promote health equity, and improve health outcomes for all.” The Joint Public Health Informatics Taskforce (JPHIT), coordinated by ASTHO and consisting of 14 member organizations including public health associations, gathered comments and input from constituent members and submitted consolidated feedback on the proposed rule in October and awaits responses and the final rule from ASTP. OE22-2203 PHIG article yes

Policy Approaches to Improve State and Local Data Sharing

Policy Approaches to Improve State and Local Data Sharing Health officials can pursue organizational policies across key priority areas to advance state and local data sharing. Learn about these policy approaches. Several factors impact effective data sharing between state and local health departments—which is vital to public health decision-making—such as legislation and regulations, limited funding, IT and workforce resources, departmental processes, leadership buy-in, and data governance. Health officials can pursue organizational policies across these key priority areas to advance data sharing practices. Get the Infographic (PDF) website yes

Summary of FY25 Senate Appropriations Bill

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STIs,
HIV,

The Senate released its version of the FY25 LHHS appropriation bill on August 1, 2024, with significant changes in proposed public health funding than the House's proposed bill.

Legal Mapping of Harm Reduction Laws and Overdose Prevention Center Legislation

This ASTHOReport highlights the public health importance of three harm reduction policies and practices to reduce overdoses: facilitating community distribution of naloxone, facilitating community distribution of fentanyl test strips, and overdose prevention centers.

Investing in Indiana’s Public Health Infrastructure Through Community-Driven Policy Change

Investing in Indiana’s Public Health Infrastructure Through Community-Driven Policy Change public health infrastructure, community driven policy, indiana state health commissioner, public health system, indiana department of health, outpatient facilities, technical assistance, data and information integration, emergency preparedness, child and adolescent health, legislative action, state and local elected officials, health problems, health care, health system, health departments, federal agencies, essential public health services, centers for disease control, state and local levels, health outcomes, health organization, covid-19 pandemic, health infrastructure, promoting health, public health organizations, states public health, federal funding, astho, association of state and territorial health officials Maggie Davis, Keith Coleman Indiana enacts historic public health funding through community engagement and legislative support. In April 2023, Indiana passed bill SB 4, which was a historic investment in the state's public health funding and restructuring its public health system. This case study shares how the Governor's Public Health Commission and the Indiana Department of Health approached community listening sessions, formulated recommendations, and successfully built legislative support to reform the public health system in the state. Get the Report (PDF) website yes

Policy Options to Improve Data Sharing Between State and Local Health Departments

Policy Options to Improve Data Sharing Between State and Local Health Departments Organizational policies on data sharing between state and local public health agencies. This report explores organizational policies related to data sharing between state and local public health departments. ASTHO, in collaboration with the National Association of County and City Health Officials and the Network for Public Health Law developed this report, which aims to serve as a guide for state and local public health leaders as they consider organizational policy options to improve state and local data-sharing efforts. Get the Report (PDF) website yes

The Youth Mental Health Crisis: States Invest in Suicide Prevention, Intervention, and Postvention Strategies

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ACEs,

Following disruptions to daily life caused by the COVID-19 pandemic, emergency departments saw an increase of mental health-related visits. A June 2021 study showed a significant increase of mental health-related visits among 12–17-year-olds compared to the previous year. States and territories that implement a comprehensive public health approach to suicide prevention across all domains of life—an approach known as the socio-ecological model—can reduce contributing risk factors.

ASTHO Policy Watch 2022: Data Modernization and Privacy Protections

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ASTHO notes the top state public health policy issues in an annual Legislative Prospectus series. ASTHO is publishing a prospectus for the top 10 policy issues to watch in 2022. This week we are featuring data modernization and privacy protections.

Modernizing Public Health Data and Protecting Privacy

Utah,

ASTHO Legislative Prospectus | Previewing 2025 state legislative actions on data modernization and privacy.

Proposed Vaccination Laws to Watch in the New Year

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STIs,
HIV,
PFAS,

Vaccines are one of the greatest public health achievements of the last century, as well as some of the most powerful and cost-effective tools to prevent disease, disparities, disability, and death among children and adults. The COVID-19 pandemic and the unprecedented development and distribution of the vaccines against the novel coronavirus have generated much focus on state laws related to vaccinations. As state and territorial legislatures prepare to convene in the coming weeks, we can already identify several topics within vaccine law that policymakers across the country will consider.

Interagency Collaboration to Improve Business Processes in the U.S. Virgin Islands

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A groundbreaking “all-of-government” approach is getting underway in the U.S. Virgin Islands to more efficiently manage and expend federal grant funding for social determinants of health and overall population health improvement. The initiative follows findings that public health agencies encounter redundant, multi-layered review and approval processes that hamper their ability to efficiently procure needed goods and services that address long standing and emerging public health needs. Moreover, such processes hinder the ability to quickly stand up critical programs and respond to public health emergencies.

Ending the HIV Epidemic: 40 Years of Progress

STIs,
HIV,
Blog,

This June marked the 40-year anniversary of the first five cases of what later became known as AIDS reported in CDC’s Morbidity and Mortality Weekly Report. Since then, more than 32 million people have died from the disease worldwide and nearly 38 million currently live with the HIV virus (including 1.2 million people in the United States). Over that period, tremendous strides have been made in HIV testing, prevention strategies, and treatment of individuals living with the virus to ensure that they can lead healthier and longer lives. While these advancements have led to significant progress in reducing HIV/AIDS-related deaths and new infection rates, HIV/AIDS continues to be a persistent problem in the United States. The federal government and state legislatures are taking significant steps toward ending the HIV epidemic, including steps to reduce new infections, combating stigma, and advancing access to care and HIV prevention

2023 Legislative Session Update: Part Two

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Iowa,

A mid-session legislative update on five of ASTHO's top 10 public health state policy issues to watch in 2023: data privacy and modernization, reproductive health, health equity, strengthening public health agencies, and immunization.

The Seven Biggest Public Health Policy Issues on the Hill in 2020

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As a truly historic year comes to an end, many public health policy issues received a considerable amount of attention in 2020. Subjects such as the pandemic that will live on in infamy, racial health disparities, and the future of the Affordable Care Act, are just a few of the major health issues that took center stage on Capitol Hill this year.

What Gets Measured Gets Done: Using Data to Improve Child Health and Well-Being

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ACEs,

The adage “what gets measured, gets done” has had staying power for a reason. When we can accurately describe conditions, quantify impact, and elucidate connections, we have a better chance at taking collective (and effective) action to tackle even the most challenging problems facing our communities. The National Survey of Children’s Health is a powerful tool to provide this critical information to researchers, policymakers, and state-level decision makers.

Jurisdictions Using Policy to Address Unique Island Area Health Challenges

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Guam,

ASTHO has several members from the territories and Freely Associated States—jurisdictions with unique challenges, and do not fall under the category of a state or federal district. This post is a brief look at some of the public health related legislation introduced during recent legislative sessions.