Program Tracks and Milestones

Introduction 

Participation in the MDAAP is organized within five distinct program tracks, which are described in greater detail in the tables below.  Providers are free to select the most appropriate program track to match their technology goals.  Completion of all milestones is voluntary, but incentive payments are contingent upon documented achievement of program milestones.    

The five available program tracks are grouped into three main pathways for program participation:   

• Adoption of new electronic health records (EHR) or other approved technology  

• Connection to the Vermont Health Information Exchange (VHIE) using existing EHR technology 

• Establishing provider access and use of the VITLAccess clinical portal  

Adoption of New EHR Technology (Tracks 1 and 2)  

This program pathway involves implementing new EHR technology, either certified EHR technology (CEHRT) or an “EHR Lite” solution that is not certified but meets HIPAA Security Rule requirements. (See Vendor Requirements below for more information on system security requirements.) Upon completion of technology implementation, Tracks 1 and 2 require integration with the VHIE, which is operated by Vermont Information Technology Leaders (VITL), the not-for-profit legislatively designated administrator of the VHIE.   

Program Tracks 1 and 2 are similar in requiring documentation of a technology purchase (i.e., executed vendor contract), completion of a Security Risk Analysis (SRA) using VITL’s SRA template, and activation or “go-live” of the new system, defined as the date upon which the provider began using the new technology to document ongoing services for active client records.  

Track 1 includes additional incentive payment milestones for providers who wish to connect their EHR system electronically to VITL via interfaces to share data with the VHIE. These additional milestones require agreements with VITL as well as contracts with the provider’s EHR vendor for developing, testing, and activating interfaces. Track 1 concludes with the “go-live” of interfaces to begin sharing production data with the VHIE. 

Although Track 2 does not specifically encompass interface connectivity to VITL, the final incentive payment milestone for Track 2 involves obtaining VITLAccess, the web-based clinical portal that allows authorized users to view client/patient data submitted to the VHIE from participating organizations.  This milestone for VITLAccess is incorporated into multiple program tracks. 

Vendor Requirements 

The MDAAP design reflects the understanding that a certified EHR system (CEHRT) may not be the right solution for all eligible providers and provider organizations.  Instead, the program design offers flexibility in choosing the most appropriate health IT solution while recognizing the importance of complying with HIPAA security and privacy standards to safeguard protected health information (PHI).  To that end, the following minimum standards are required for EHR/HIT vendors under Tracks 1 and 2.  

• To be eligible under Track 1: Implement Certified EHR Technology (CEHRT), vendor solutions must possess 2015 Cures Edition certification as defined by the Office of the National Coordinator for Health Information Technology (ONC).  The list of certified vendors is maintained by ONC on the Certified Health IT Product List (https://chpl.healthit.gov/#/search).   

• To be eligible under Track 2: Implement EHR Lite/Other Program-Eligible System, vendors must possess HITRUST Common Security Framework (CSF) certification, as granted by the HITRUST Alliance (https://hitrustalliance.net/product-tool/hitrust-csf). Evidence of current certification is required. Software or hardware that does not hold itself out as an electronic health record system is not eligible for this track. 

Organization Size and Incentive Payments 

The cost of new EHR and other HIT solutions is almost always dependent on the number of licensed users stipulated in the vendor agreement.  Since larger organizations with more licensed users will pay higher acquistion and implementations costs compared to a smaller organization with fewer end users implementing the same software, the program tracks that entail the purchase of new software (Tracks 1 and 2) also incoporate three tiers of incentive payments based on the number of licensed end users.  Similarly, Tracks 4 and 5 provide graduated incentive payments based on the number of users who will undergo training and gain credentials to VITLAccess since it is recognized that it will require more time, effort, and resources to train and credential a larger number of VITLAccess users. 

Adoption of New EHR Technology 

Connection to the VHIE Using Existing EHR Technology 

This program pathway is for providers who already have either a CEHRT system or an EHR Lite/Other Program-Eligible System and desire to develop electronic connectivity to the VHIE.  Track 3 is unique in that it is designed for two types of provider groups who currently utilize CEHRT: 1) Vermont Designated Agencies (DAs) and Specialized Services Agencies (SSAs) required to connect to the VHIE under an Approved Connectivity Plan Proposal, and 2) All other eligible Vermont providers.  

Within Track 3, participating DA and SSA providers will be eligible for two alternative incentive payments: A signed VHIE Service Agreement Amendment for 42 CFR Part 2 Data and an Approved Connectivity Plan Proposal as required by an existing DA Provider Agreement.  The incentive payment structure is higher because the hours and effort required to develop and draft an approved Connectivity Plan Proposal are significant. All other Track 3 providers will complete milestones for the standard Signed Participation Agreement and Signed Scope of Services Agreement with VITL.  

Track 4 is designed for providers utilizing an “EHR Lite” or other program-eligible system that desire to develop electronic connectivity with the VHIE.  Instead of milestones tied to development of specific interface types (i.e., ADT and CCD interfaces), this program track requires collaboration between each HIT vendor and VITL to determine the appropriate data fields, file or message types, and method of secure data exchange to accomplish electronic connectivity.  Both tracks within the VHIE Connection Only pathway culminate with milestones associated with the “go-live” of interfaces that will send production data to the VHIE. 

VHIE Connection Using Existing EHR Technology 

*The MDAAP team will work directly with Vermont Designated Agencies and Specialized Service Agencies participating in program track 3a under an approved Connectivity Plan Proposal with VITL.

Acquisition and Use of VITLAccess   

The third program pathway includes a track for providers who only desire obtaining and using VITLAccess.  Even though this program track does not require the purchase of vendor software or services, providers are still required to complete a Participation Agreement to ensure program eligibility and a Services Agreement with VITL as part of the documentation process for VITLAccess credentialing, training, and usage.  

VITLAccess Only Track