Connecticut’s health information exchange (HIE), Connie, is live and operational. Pursuant to Connecticut Public Act 17-2, hospitals and labs only have until May 3, 2022 to begin the process of connecting with Connie. All other healthcare providers have until May 3, 2023. Pullman & Comley’s Health Care practice has been asked by many of our clients about what is required (and when) in order to connect with Connie.
Regardless of whether the deadline for your organization occurs this coming May 3 or next, it’s important to note that the state statute only requires healthcare providers to begin the connecting process. As noted in the “Commitment to Connect Form,” the process generally includes the following steps: 1) Returning the commitment form; 2) legal on-boarding (including negotiation of the legal agreements); 3) technical onboarding (including creating the necessary connections to facilitate the data exchange) and 4) providing training to end users and establishing the actual integrations. In total, Connie estimates that the process should take less than six months. Given that the standard is that a provider “must begin to connect,” we do not believe that this entire process must be finished by the applicable May 3 deadline (whether 2022 or 2023 depending on your type of organization); however, at a minimum the commitment form should be submitted.
Connecting to Connie is not as simple as merely signing a contract and letting Connie do all the work. In addition to the action items stated above, it’s critical for all areas within healthcare organizations to understand their obligations in connecting with Connie. Most critically, organizations may need to coordinate and contract with their electronic health record technology provider to integrate with Connie. It is our understanding that several important EHR providers (e.g., Epic, AthenaHealth and Greenway) have established integrations with Connie, but that many do not.
Organizations will also be responsible for how their providers interact with the system. That includes not only ensuring that providers do not misuse the system, but also that the providers affirmatively upload patient information and respond to proper requests for additional information. Organizations will be responsible for providing training and support on the Connie system for their team. Provider contracts and policies that may impact these activities need to be reviewed and may need to be updated depending on particular circumstances.
Likewise, patient notices will almost certainly need to be revised to include a notice on the sharing of health information with Connie and to provide an opt-out from the Connie system.
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