By: Ben Pierson, Program Manager: Health Information Exchange
Mass HIway Opt-In Requirement
The Massachusetts Health Information HIway (Mass HIway) is a secure health information exchange (HIE) that is accessible to all health care systems statewide.  OCHIN currently integrates with Mass HIway via the following connection type:
- Push Based – Direct Messaging  is used for Epic-to-Epic connections using the CareEverywhere network and Epic-to-non-Epic connections using the Health Information Service Provider (HISP) called CareAccord. CareAccord is connected to Mass HIway for inter-HISP communications.
Opt-Out vs. Opt-In Consent
OCHIN is established as an “opt-out” system for consent, which allows the exchange of information for treatment, payment, and operation under HIPAA, without the requirement for patient consent. However, a patient has the right under HIPAA to opt out of exchange of their information.
Massachusetts has elected to implement an “opt-in” requirement for systems that integrate with Mass HIway.  Due to this requirement, consent must be obtained from a patient prior to any transmittal of protected health information (PHI) to Mass HIway. Since this requirement is different from other HIE connections OCHIN has in place across the country, it requires a custom setup for clinics in Massachusetts.
OCHIN has worked with Epic to identify a change that can be made in the system to accommodate this new requirement in a way that will prevent PHI from inadvertently being transmitted to Mass HIway before a patient has signed a consent form. Clinics will need to also implement workflow changes in order to ensure they are capturing patient consent if there is a need to use Mass HIway in the course of delivering patient care.
However, there is a potential negative impact to the system change that has been proposed, and clinics will need to be aware of this. Preventing PHI from being transmitted without a patient consent on file will also impact CareEverywhere functionality for all connections. This will prevent external organizations, including and in addition to Mass HIway, from accessing information in OCHIN Epic unless a patient has already opted in by signing a consent form.
Join Us for a Discussion on November 30
Prior to moving forward with any changes, OCHIN will be discussing the changes and potential impacts with all affected Massachusetts members. OCHIN has scheduled a meeting for November 30 to hold this discussion, and we encourage those members to attend and contribute. It is important that OCHIN and its members fully understand the Mass HIway opt-in rule, the system change that can be made in Epic to accommodate this, and the changes to clinic workflows that will be required.
 “About the Mass HIway.” Massachusetts Health Information HIway. Commonwealth of Massachusetts. Web. http://www.masshiway.net/HPP/About/AboutTheMassHIway/index.htm
“DIRECT Project.” The Direct Project. HealthIT.gov, 15 July 2014. Web. https://www.healthit.gov/policy-researchers-implementers/direct-project
 “About Your Consent.” Massachusetts Health Information HIway. Commonwealth of Massachusetts. Web. http://www.masshiway.net/HPP/PatientsandFamilies/AboutYourConsent/index.htm