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NCHIE Information and Updates
This page serves as a central communication point for mental health providers in North Carolina to stay up-to-date on information regarding the North Carolina Health Information Exchange initiative (NCHIE or HealthConnex) and mandate. NCHIE requires all providers receiving state funds to connect and share client information with HealthConnex.
IMPORTANT CLARIFICATION – If you accept BCBS, you likely have worked with someone on the State Employees’ Health Plan (SHP)! There are over 700,000 people on this plan across North Carolina, including teachers, government employees, and others. If you are in network with BCBS, this mandate affects you unless you discontinue working with State Health Plan subscribers.**
**This (NCHIE) is not to be confused with the State Health Plans’s announced new reimbursement strategy. The two issues are not directly related. They are somewhat related in that the SHP plans to contract with providers separately from the “regular” BCBS network. As such, it may be possible if that happens, to remain in network with BCBS, but not with the SHP. This may be one way to avoid dealing with NCHIE, but at the expense of not being able to work with SHP members through their benefits. To read more about, and contract with, the new State Health Plan (still managed by BCBS) head to this page. Note that the deadline for joining the new SHP network is July 1, 2019. The deadline for NCHIE (the focus of this page) is June 1, 2019.
I start with the current status section. For background on NCHIE, continue reading below.
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Open-Ended Delay (Update July 2022)
When the NC budget bill was passed, it included a provision that “connecting to and submitting data through the HIE Network known as NC HealthConnex shall not be a condition precedent to the receipt of State funds, including Medicaid funds, by any provider or entity subject to subsection (b) of G.S. 90-414.4 until a bill designating a lead agency responsible for enforcement of the Statewide Health Information Exchange Act is enacted into law.”
In short, until the State of NC creates/declares an agency responsible for enforcing the HIE mandate, no state funds will be withheld from providers. When and how such an agency may come into being is unknown, so the time frame is completely wide open. Stay tuned for updates.
Deadline to Connect Extended to October 1, 2021
5/4/2020 Governor Roy Cooper signed the COVID-19 Recovery Act into law, extending the deadling to connect to HealthConnex until October 1, 2021. This includes those who have already signed a participation agreement and were in the process of connecting. This extension will happen automatically; no action is required. (see also hardship extension below).
Hardship Extension now December 31, 2022
3/20/2020 On March 20, 2020, it was announced that providers with certain taxonomy codes, or who meet other qualifications (for example, plans to retire within the next 2 years), would qualify for a hardship extension. Those granted the extension will not have to connect until Dec 31, 2022. There are some questions about how and when this extension will be accurately applied, especially for those it is supposed to happen automatically. I encourage everyone interested in this extension to contact the email provided to inquire. You can find full details here.
As for those hoping to be connected through their EHR, it remains to be seen how many of the EHRs aimed at small practices will actually be connected by June 1. Further complicating things is a lack of information on how COVID-19 may be affecting forward movement as many resources have been diverted to address the crisis.
12/10/2019 – There’s been little movement in things since the delay was passed. NCHIE continues to work through the details of what data will be collected and EHRs continue to work toward connectivity. I don’t expect much to change until the “rush” happens in 2020.
6/6/2019 HB70 has been signed into law by the governor! Behavioral health clinicians now have an extra year to address compliance with the NCHIE mandate.
6/5/2019 The HB70 update has “re-passed” the House and now is on to the governor’s office to be signed!
5/30/2019 HB70 has passed the Senate and is headed back to the House to be revoted on. It is likely to pass but will not pass before the June 1st deadline. NASWNC reports that people will not be penalized for not completing the participation agreement during this interim period.
5/28/2019 – Word is that HB70 has made it’s way past the Senate Health Committee and is back in the Rules committee. There’s a chance it will make it to the Senate Floor for a vote this week.
5/22/2019 – There has finally been movement for House Bill 70. It has made it’s way from the Rules Committee to the Senate Health Committee and looks to be voted on there on the 23rd. If that is approved, one more stop in the Rules committee before heading to a Senate floor vote.
May 2019 – While HB 70 passed the House it’s future is uncertain as it has ended up back in committee.
3/12/2019 – House Bill 70 has been introduced which, if passed as written, includes a delay of required compliance with the NCHIE mandate for mental health providers until 2020. You can read it here. Now is the time to contact your elected representatives in support of this bill.
3/11/2019 – BCBS has finally spoken up about their role in the NCHIE initiative, noting that claims from those not in compliance, after the deadline, will be denied. This will not happen to those who have been granted an extension (which requires completing the Participation Agreement; read on)
Note: This is a brief update. If this is your first time on this page, I encourage you to read everything below this section for it to make the most sense.
In July of 2018, NCHIE released the results of their feasibility study. They made several recommendations, one of which is to establish “waves” of implementation, including a delay for behavioral health until “at least 2020”. (This is an overall delay, separate from the delay that you can apply for if you have already signed up).
It’s important to note that is currently just a “recommendation” and would need to be approved by the legislature or powers that be (see information on HB 70 above). Please support your professional organizations and listen for updates from them on progress.
NCHIE is also examining possible alternative ways for providers to report, due to the variance in information collected/stored and the fact that most behavioral health providers haven’t been involved in the Meaningful Use program. IMO, this will be an important piece if we are to continue to use more affordable, more user-friendly systems that fit our practices best.
My recommendations for now are:
- If you already are using an EMR/EHR/Practice Management System you’re happy with, keep using it.
- If you aren’t already using an EMR/EHR/Practice Management System and don’t have a compelling reason to use one yet (***), don’t rush to choose one. It’s going to be important that you have more information about how reporting might happen, and whether the delay gets approved. ***There are other compelling reasons to use one, but if they aren’t time-sensitive you may want to hold off for a bit.
- If there is any chance you plan to continue to work with State Health Plan members (or Medicaid members), as an in network provider, I recommended completing a participation agreement now for NCHealthConnex (link further down the page). You can even complete an agreement without making a final choice of EHR. The NCHIE has announced that anyone who has completed a participation agreement, will be granted an automatic one year extension when the deadline arrive.
- OON providers have a more difficult choice to make. Currently NCHIE reports that their translation of the law is that OON providers will also have to comply if state funds are paid to the client (i.e. provider “not accepting assignment” or providing superbill). If this interpretation holds, then my recommendation in the previous point would as well. There is some doubt as to the ethics/legality of this interpretation so it could change. I encourage OON providers to seek clarification from NCHIE and their professional organizations.
- Important – I recommend against choosing an EHR solely because it will allow you to meet the mandate as it is currently written. Choosing an EHR that is a poor fit for your practice, just to meet the mandate could cost you significant time and money in the long run.
If you feel you need detailed help regarding your specific situation, consider a consultation.
What is the NCHIE?
For full details, you can read the NCHIE FAQ. See my FAQ below.
Following is a brief summary.
Health Information Exchanges (HIE) are set up to promote efficiency and quality in the health care system. This is accomplished by providing a central database for health providers to share and query health care information of their clients. Providers can readily query information about medications, and other diagnoses and treatments, for example, to increase efficiency and decrease errors.
The North Carolina HIE system is known as HealthConnex. Law related to the NCHIE requires that all providers that receive state funds (e.g. Medicaid, State Health Plan) for the provision of health care services, must connect to NC HealthConnex. The deadline for those that receive Medicaid reimbursement is June 2018 (if you are a hospital, physician, or nurse practitioner. The deadline for those that receive reimbursement from the State Health Plan (for State employees, managed by BCBS) and all other Medicaid providers, is June of 2019.
By “connected” it means that you transmit clinical and demographic information for State Funded health care plans to the HealthConnex system, at least twice daily. Note that this does not mean that you transmit “psychotherapy notes”. Only clinical data is required to be transmitted. You are not required to query the system (i.e. do searches for data). HealthConnex is currently funded by the State and free for providers to connect to. This transmission of data is typically handled through an EHR capable of such transmission. The EHR vendor also needs to set up the transmission/connection for it to happen. (Similar to connecting you to a clearinghouse so that you can file electronic insurance claims).
It is strongly recommended that you view the NCHIE FAQ as it addresses many of the questions that come up. Have more questions? Be sure to complete the survey linked above where you will have an opportunity to have those questions sent to the NCHIE.
You can find the participations agreements here:
Who is Subject to the NCHIE/HealthConnex Mandate?
The NCHIE FAQ is extensive and directly from the source. However, it can seem overwhelming for some as it presents a lot of information. Following is a curated list of Frequently Asked Questions I’ve seen asked about NCHIE from those in private practice. It’s important that you read the NCHIE FAQ first and then use this as a resource for clarification.
Note that I use the term “EHR” generically below to refer to EHR, EMR, and practice management systems.
Exactly What Data Has to Be Reported?
This is still being clarified by NCHIE. They have stated that the goal is to have all treatment data included (i.e. clinical notes, not psychotherapy notes). They have also divided data sets into parts and therefore are pursuing staged goals. In short, you may not be required to report much more than demographic data at first, but would eventually be asked to report more. Part of the lack of clarity is due to NCHIE working to translate mental health data into a schema that works in the system since we typically don’t work on an “encounter” basis like medical professionals.
Will I Have to Use an EHR to Comply?
Pretty much. While NCHIE has expressed they are looking into potential alternative reporting methods, they are all based on digital delivery of data. The easiest solutions for mental health clinicians in private practice will likely involve an EHR.
Will It Have To Be a Meaningful Use Certified EHR?
It shouldn’t. This is going to be an important question moving forward. Theoretically, connecting to HealthConnex should not require a MU Certified EHR. Any EHR/Practice Management System capable of filing electronic insurance claims has the capability of connecting to, and sharing data with, Healthconnex and NCHIE is working closely with many EHRs that are not MU certified to get them connected.
So, Which EHR Can I Use?
Each EHR below is linked to my review of it.
If you need to meet the mandate now (i.e. are a physician or NP in network with Medicaid), then the list primarily consists of MU Certified EHRs, and can be found in the NCHIE FAQ. The ones that I have reviewed and are usually most applicable to behavioral health, especially private practice are the following: (be sure to read my recommendations above. I recommend NOT choosing an EHR solely for the purposes of meeting the mandate)
Note that the list on the NCHIE site may not be up to date. I have seen EHRs take several weeks to be listed, even after they have completed connectivity.
Fortunately, you currently do not have to use an Meaningful Use Certified EHR in order to meet the mandate. As long as you use an EHR that is working toward connectivity, you will meet the mandate (and likely also qualify for an extension).
EHR Connectivity Status
Note: This is the information that the EHRs have reported to me. I currently have no way to confirm their status of efforts toward connectivity as the NCHIE only releases a list of EHR vendors already connected.
BestNotes – Reports they are pursuing setting up a one-way connection with HealthConnext/NCHIE.
BreezyNotes – Not pursuing connectivity at this time.
Carepaths – No response yet.
ClinicTracker – Reports that they have established connection and are waiting on certification from NCHIE.
CounSol – Reports they are looking into connectivity.
MyClientsPlus – “We are aware that the June 2019 deadline is coming and our development team is currently working on a solution to connect to NC Health Connx through HL7 to meet these requirements. We plan to be compliant by the June 2019 deadline. We are in conversation with the NC HIEA to comply with the deadline and will let you know as soon as we have updates.“
PSYBooks – May consider in the future, but is not currently in the queue.
SimplePractice – “We are working closely with key stakeholders in the NC HIEA to enable connection to NC HealthConnex within North Carolina’s required timeframe. As part of that process, SimplePractice current and future customers are advised to complete the NC HIEA’s Submission Only Participation Agreement. We’re asking that when filling out the Agreement, those customers connect with our Help Desk here.
As we continue our work with the NC HIEA regarding connection to the exchange, we’re committed to transparency, simplicity, and support for all. We will continue to release additional information throughout this process.”
TheraNest – “We plan on implementing interoperability features that will make our software compliant with North Carolina’s HIEA standards by the June 2019 deadline. Though we are not pursuing ONC certification at this time, we are considering it is an option as we evaluate whether the standards would benefit the majority of our customers.”
TherapyAppointment – *UPDATE* TherapyAppointment has indicated they have changed their stance and will be pursuing connectivity with HealthConnex/NCHIE.
TherapyNotes – “We are committed to HIE support and have a team doing planning. No schedule just yet.”
TherapyPartner – Looking into it.
TherapyZen – No response yet.
Therasoft Online – Looking into providing submission only connectivity.
Which EHR SHOULD I Use?
Unless you’re in network with Medicaid, there’s no reason to jump to one of the EHRs above. Even with the mandate looming, you don’t have to commit to a specific EHR. They will allow you to complete a Participation Agreement, noting that you are still deciding.
How do I know if my EHR will meet the requirements of the mandate?
Ask them. If they use phrases like “it’s on our roadmap”, “we have a team focusing on this” and other vague responses, they will likely be quite challenged to meet the June 2019 deadline. As someone who has a background in software development I can say that those kinds of phrases typically mean they have no solid timeline on when things will get done yet. For the most part, they also don’t have significant incentive to meet the deadline.That’s not to say they aren’t going to work toward it. They simply have no reason to prioritize it over other features they are trying to launch in order to stay competitive. (i.e. people are asking them more for things like telehealth features). Further, NCHIE has already reported they will grant an automatic one year extension to those who have completed a Participation Agreement, but either a) haven’t chosen their EHR yet or b) their EHR has not yet connected.
If My Current EHR Isn't Going to Meet the Mandate, Do I Have to Switch EHRs?
Not likely. First, there is an extension process with NCHIE. It does require that you sign their participation agreement. If your EHR reports they will never meet the mandate, you may have to change eventually in order to comply. However, most popular EHRs are making efforts to acheive connectivity.
Will I Really Have to Report Data Twice a Day?
That is what the legislation requires. That said, in meetings, the NCHIE reps acknowledged that wasn’t a good fit for everyone and may not be strict in enforcing that.