A pilot project for the exchange of electronic behavioral health data between states has uncovered technical and operational challenges.

The challenges revolve around using common data exchange procedures and policies, but has also demonstrated that such exchanges can be successfully performed.

The pilot, conducted through the Behavioral Health Data Exchange Consortium, included a coalition of states testing the Direct Project secure messaging software in partnership with the Office of the National Coordinator for Health IT and the Substance Abuse and Mental Health Services Administration. The goal was to execute at least one successful pilot demonstrating the ability of providers to exchange behavioral health data electronically across state lines.

According to a June 27 blog co-authored by John Rancourt, public health analyst in ONC’s Office of Health Information Exchange, federal laws and state laws that provide important privacy protections have created complex challenges for sharing behavioral health information electronically. “These privacy protections may require written patient consent prior to the disclosure of such information, even for treatment,” states the blog. “This is more restrictive than the ‘floor’ of permitted information uses set by the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.”

Nevertheless, a final report released June 27 finds that pilot data was exchanged between providers in Florida and Alabama and the necessary frameworks for exchange were established in three additional states. “Direct messages can now be sent by providers using these services at any time to facilitate care coordination interstate for real-life patients,” according to the report. “Perhaps more importantly, these connections have allowed the states to be much more prepared to share patient information if large numbers of citizens are displaced by a potential hurricane or natural disaster.”

Despite overcoming basic technical and policy barriers, the report concluded that a number of challenges remain to be resolved in future work. “EHR systems must begin to provide a mechanism for segmenting and/or flagging data that require specific processes for disclosure or re-disclosure,” states the final report. “Without such functionality, it is incumbent upon providers to understand the requirements for manually segmenting this data, which creates a barrier and, because of the challenges presented by legal and technical complexity, can erode trust between providers that the data will be handled appropriately. This functionality would also allow for the exchange of structured data that could be incorporated into the receiving provider’s system rather than sent in a static format such as PDF.”

The report also notes that widespread understanding and agreement about the requirements for consent and disclosure of behavioral health data are still major challenges that must be overcome. “Although these requirements may be better known to behavioral health specialists, the majority of providers do not know how to appropriately manage the receipt and redisclosure of this information,” states the document. “Participants in this project worked to create materials that helped to de-mystify these requirements and engender trust between providers, but expanding this type of trust environment beyond the pilot projects is a much more significant task. Such expansion will require a significant education campaign and assurance about the appropriate safeguards, particularly as policies and procedures built for a ‘push’ environment using Direct exchange are revised to support robust query-based or ‘push/pull’ models of HIE.”

The Behavioral Health Data Exchange Consortium was supported by ONC and managed by contractor RTI International.

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