 Good afternoon and welcome to the Green Mountain Care Board meeting. My name is Covan Mullen, Chair of the Board. The first item on the agenda for today's meeting is the Executive Director's Report, Susan Barrett. Thank you, Mr. Chair. I have a few announcements. First, I wanted to remind folks we have several ongoing special comment periods and they are located on our website under public comment. But I'll just summarize them here. There are two that are out until November 30th, 2020 and that is we're accepting public comment on the hospital budget process and the materials are located on our website under that public comment item. And then the other, until the other ongoing comment period until November 30th, 2020 is the topic of our meeting today, which is the Health Information Exchange Plan. And then the last ongoing special comment period is the ACO budget. That period will end on December 2nd, 2020. And then I'd also like to announce that as of now we are agenda for November 25th, which is next Wednesday remains TBD. So I just encourage folks to just check our website and check on the scheduling the beginning of next week to see whether or not we're going to have that meeting. We do have it on the calendar as of now, but check back in at the beginning of next week to see what the plan is. And that is all I have to report. I'll turn it back to you, Mr. Chair. Thank you, Susan. The next item on the agenda are the minutes of Wednesday, November 4th. Is there a motion? Second. It's been moved to approve the minutes of Wednesday, November 4th without any additions, deletions, or corrections. Is there any discussion? Hearing none, all those in favor signify by saying aye. Aye. Those opposed signify by saying nay. Motion carries. So at this point, we're going to focus our discussion on the Health Information Exchange, and I'm going to turn it over to Sarah Kinsler to tee it up for Sarah. Thank you so much. For the record, this is Sarah Kinsler, Jeanne to be Director of Strategy and Operations. And I'm just going to turn off my video and share some slides real quick. Can folks see those slides? We can. Excellent. I'm just going to do a very quick introduction today to cover our statutory authority and then hand it over to Diva and Vital to present the plan itself and the connectivity criteria. And then I will come back to present the staff review of the 2020 update to the HIE plan and the 2021 be high connectivity criteria afterwards. So today we will be talking about two responsibilities that the board has related to health information technology and health information exchange. First reviewing the state HIT plan, which is now known as the HIE plan more commonly. The board's authority is focused on whether or not the plan will support achieving the principles of health care reform laid out in Act 48. And in addition, the HIE plan statute in section 9351 outlines a variety of features that HIE plan must address or include. The plan is still referred to as the HIT plan and statute, so sometimes you'll hear me use that title instead. As noted here, Diva is required to revise the HIE plan annually with a comprehensive update every five years. The current plan was approved in 2018 with an annual update approved in 2019 and today we have the 2020 update before us. Secondly, the board is required to review the connectivity criteria for providers connecting to the be high. Vital is required to present that criteria for approval annually before March 1st, but since 2018 we've been reviewing the criteria for the coming year. In conjunction with the board's HIE plan review since the connectivity criteria are really about how we operationalize HIE planning and the connections to meet the HIE plan goals. The board also reviews and approves vital budget annually in the spring, which I have not included on a slide since it's not on the agenda today. And now I'm just going to turn it over to Diva and Vital and I'll return after their presentation to talk to the staff now. Hello, can you hear me okay? We can. Hi, I'm Emily Richards. I'm the director of the health information exchange program at Diva. So I'm going to share the presentation with you. Just give me one moment here. I think. Can you see that okay? Yes. Okay, great. So Sarah mentioned this is the 2020 update to the plan that was approved in 2018. This is the plan that's called for under title 18 and so we're running through the components of it today. So as I said, I'm Emily Richards. I'm the director of the health information exchange program at AHS. Sandy Hoffman was supposed to join me today. She's a newly appointed deputy commissioner, but unfortunately she's not able to join us. So, Beth and Carolyn from vital. Do you want to do a quick introduction before I jump in? Sure. This is Carolyn Stone. And I am director of operations at vital and I'll be presenting the connectivity criteria update later. Thanks, Karen. Beth Anderson, the CEO of vital. Great. Thanks, Beth. Okay. All right, so today I hope to do a couple of things first review the core concept concepts underpinning the HIE plan. We came up with a number of sort of guiding principles are guiding tenants in 2018 and those continue to guide our work. And so I just wanted to review those with the board and participants to make sure that the process for strategic planning was very clear. We thought we'd go over progress made in 2020, as well as plans ahead for 2021 based on the progress we've made this year, and then review the evolution of the HIE ecosystem. The HIE ecosystem is something I'll talk about basically the component parts that need to advance in order or excuse me need to work together in order to advance an HIE effort. We'll talk a little bit about where we thought we'd be in terms of maturity and where we expect to go. And I've been having a little bit of a microphone challenge. So if you're having any trouble hearing me, please just let me know. Coming through clearly now. Okay, great. Thanks so much. Okay, so the idea behind the HIE plan is to drive progress. So in a sort of a transparent and accountable manner. And so to do that, the HIE plan covers three essential elements. First, the specific goals and vision for how we'd like to exchange health data. So the sort of aim or drive is very clear. Second, the HIE ecosystem or the environment required for HIE to effectively function, which I'd like to go into a little bit more and then clear objectives and tactical plans. Can be measured and the plan ahead is very clear. So in 2017 when the when the steering committee initially joined, they spent some time pulling together use cases or sort of stories that articulate how folks might use health data to improve their work. So this goes from providers to analysts to policymakers and what they were able to do looking across those different user needs was to roll up the goals of each of those users and to these sort of three overarching goals for the system. And these continue to be our North Star. And so the goals are to create one health record for every person to support optimal care delivery and coordination. So this we're working to ensure a complete and accurate what we call longitudinal health record for every person who seeks care in Vermont. The second is to improve health care operations enriching care operations through data collection and analysis. So that can be to support quality improvement reporting and direct care and to use data to enable investment and policy decisions. So an overarching look at how we bolter the health systems function functions excuse me an ability to learn by providing accurate and comprehensive data. So the next core concept here that sort of underpins the strategic planning work that we do is this combination of things. Here's here on the left you see the ecosystem this sort of triangle diagram. And what we think this does is it represents the dependent parts that have to work together to advance an HIE effort. What this means is that you need formalized governance financing to ensure that there are appropriate resources to maintain your systems and advance your systems and the appropriate policy and processes to facilitate the type of data collection and exchange you're trying to do and all of that underpins the technology. What we wrote in 2018 in the initial HIE plan is that a focus on technology is myopic meaning that it's sort of a single focus without a look for what the dependencies would be in order to ensure that that technology is appropriately used and leveraged and funded. And so that's how we think about the HIE ecosystem. And so when the steering committee embarks on both developing and overseeing the execution of the strategic plan they're thinking about how all of these component parts work together to advance our work. What you see on the right here is the technology portion of that blown out. And so how we think about technology is really inspired by something from the Office of the National Coordinator which is the federal entity designated with strategic planning for health information exchange nationwide. And what they say is that HIE systems are kind of built in this modular way. I often use the metaphor of a house that you build the foundation first and then think about the walls and the windows which is the sort of middle section here that we're calling exchange services. And then you can pick the paint color and do you have a smart oven or not where you're going to hang the drapes. And so when we think about foundational and exchange services we're looking at that's where we look at where public investment would be focused. And end user services are only able to occur once this foundational and exchange services are in place. So kind of all of these component parts are guiding principles for strategic planning. So going on next. Okay so one really important piece of governance in Vermont is the HIE steering committee who I keep referring to. They were joined together in 2017 really in response to statewide evaluation. They talked about our fractured governance and how that had impacted our progress on health information exchange efforts in the recent past. So in 2017 that group got together and 2018 presented you with an HIE plan. And the Vermont legislature gave them authority under Title 18 to work with Diva to develop and oversee the strategic plan for the state. So this group is intentionally kept small to support agile and quick strategic planning as you know year over year. We're updating the plan while we are overseeing execution. And they're guided by subcommittees who are formed as groups of technical experts to provide these group of this group of people with the technical or planning insights they may need on specific topics. And the steering committee is also committed to leveraging groups that already exist. So we're not you know sort of bombarding the limited group of folks who may be interested in this in Vermont with you know more groups to participate in rather leveraging the tables that they're already seated at. In this next slide. This is something we went over in 2018 but I just you know in reviewing our past materials felt like it was an important thing to go over again. You know because as I mentioned in 2017 or excuse me yes in 2017 there was a statewide evaluation that noted that HIE governance in Vermont was fragmented. And we really come together I think over the last couple of years with a solidified look at roles and accountability in our HIE governance model so I think they're important to go over. So of course first up here it's the HIE steering committee which I've just gone over and this is where stakeholders go to set priorities, propose policy, talk about operational direction. Or the decision makers go for support as I mentioned these ad hoc subcommittees are groups that already exist. Who's responsible for oversight of course that's you the Green Mountain care board as you approve the HIE plan and vitals budget. Who provides HIE services. That's vital and other HIE vendors like by State primary care one care Vermont and how are these service providers held accountable and for us that's through performance based contracts, which have been refined considerably in the last couple of years. So that it's very clear to see how HIE services are funded in this day. So before I move on to talking about the 2020 work and 2021 plans ahead. Are there any questions about sort of those core principles or core things that underpin the strategic planning process? Are there any questions from the board? I don't hear any Emily. Okay, great. I'll keep going. Thank you. Okay, so let's jump into 2020 progress and our 2021 plans ahead. So I'm going to start with the collaborative services project and I think you're familiar with this, but just as a reminder, this is kind of our cornerstone effort of the last couple of years to bolster the Vermont Health Information Exchange or the V high to meet a broad range of end user needs with, you know, the core mission of the HIE, which is to be a central aggregator of health data. So this kicked off in 2019 and we gained commitment from a number of stakeholders who were funded separately to sort of build wraparound services because of I guess perceived need in the ecosystem. And so they've all joined together as a collective to agree to this investment in the foundational services offered by the HIE. So what we're hoping to do is invest in one system as an efficient way to obtain valuable usable data to meet all of those goals that we talked about up front. So the projects managing phases phase one and phase two are well underway and we'll talk about plans for phases three and four. So phase one, you know, we just talked about the sort of the foundational services. So this is an investment in in solidifying the master patient index terminology services and integration engine at the Health Information Exchange. And so when I think of these and non technical terms this is how the HIE matches records across systems so different doctors sending different doctor offices sending records matching our records into one for each person with different terminology services taking many ways to say one thing or many ways to say one thing like many ways to say blood pressure and translating it into one term or syntax that works for whoever's using the data and then integration engine which means collecting the data and sending it to the right place. So all of these updates are live and they're proving to enhance the HIE services. So as an example here we're seeing great results in match rates. So match rates for reference population went from approximately 65% to over 95% after they implemented the new technology. So phase two is well underway. This is a new data repository. So the idea beyond just sort of real time exchange of data is to collect that data for different uses. There's a policy and legislative analysis namely and so a group called the Collaborative Services Subcommittee helped vital select a new data repository by understanding what unique needs or needs would be for this data repository and they ended up selecting a technology from a group called Nikasoft. This platform is expected to be live in April 2021 with enhancements thereafter. And one of the I think sort of demonstrations that this concept is working is that the Department of Vermont Health Access was able to retire an old piece of technology used by the blueprint for health a clinical repository because we'll now be able to leverage this platform for data extracts beginning in 2021. So this Collaborative Services Subcommittee continues to provide insights to vital as they work through the implementation of the new data repository and a point in time assessment that they delivered to the steering committee concluded that the new platform will meet the data needs of the subcommittee members. Moving on to phases three and four of the projects that we plan to do ahead. So phase three is managing new data types. The steering committee agreed that aggregation of an expanded data in the V hi would be valuable including data representing social determinants of health substance disorders mental health behavioral health and claims data. The goal you know we've talked about the goal of one record for every person and having a longitudinal look at that individual's health and the steering committee agrees that physical health data coming solely from electronic health records is not enough. And that we need to aggregate greater data sources so that users can have a holistic look at people's health and the impacts on their health. So I'm going to talk a little bit about how we expect to work on that in 2021. But before I do just to talk a little bit about sort of what's after this public investment or phases one through three of the project. So phases four we're calling decision support and analytics and this is where customers of the V hi come in and you know we talked about the foundation of the house the windows in the doors and then the sort of fun stuff the pink color in the bells and whistles. So this is where customers would come to the V hi and say you've now have the base a technology up. You are meeting your mission of aggregating and exchanging health data. Here's how we'd like to use your services. So this would be an area where public investment was not focused. So just a quick look at how we expect to help vital on board or aggregate new data types. In green you're seeing the policy components and yellow the governance components in this deep gray is technology. And so what we're saying for if you sort of look across the swim lanes read from left to right on the left you're seeing the data type and the right the plans each of the H I ecosystem component parts needed to aid in the collection of new data types. So physical health is at the top. That's what we're calling the data that comes from electronic health records now leaving out substance use disorder behavior health and mental health data. And so as examples of things that we need to do to support this effort connectivity criteria subcommittee will work to ensure that there are appropriate definitions and standards for collecting this data type interface prioritization subcommittee will work to ensure that vitals connectivity goals for the year to come support aggregation of physical health data will come up with policies around that. And then the collaborative services subcommittee will continue to help vital and implementing the base technology to support the enhanced management quote unquote of these data of this data and then social determinants of health. We are doing a currently a pilot project with one care between the agency of human services and one care for my to collect a chess data and share it with one care to support their risk classification model. And so that's phase one of testing using vital to aggregate this data type. So in the process of doing that the policies that we need are data sharing agreements and connectivity criteria on this this specific data type and then we will also be doing a social determinants of health subcommittee to talk about what additional policies we need to expand the types of the sources of social determinants of health data coming into the V high and those that are able to access it. And then substance use disorder behavioral health and mental health. We had a pilot project this year is that well for this data type. The state legislator legislature decided to fund the purchase of electronic health record systems for a number of the da s and in that asked them to work with vital and the steering committee to ensure interoperability. So the connectivity criteria is enhanced has been enhanced this year to include substance use disorder mental health data types. We are looking at potentially proposing a policy update to the protocols for access to data on the V high to allow for additional data of this sort to be aggregated by the V high will be a stakeholder informed process to do so. And so this is kind of the pilot for this year and next and then similarly we'll convene a subcommittee to look at what it would mean to aggregate these data types beyond designated agencies. And then finally for claims. The steering committee since 2018 has posited that integration of clinical and claims data would further the goals set forth in the plan. And so here we are embarking on a pilot to design what it would mean to aggregate claims at the V high with a focus on Medicaid claims data first. OK. So that was a lot. Should I stop for questions or keep going. Does anybody have any questions. This is Robin I have a couple questions. Go ahead. Hi Emily I hope you're well. Starting with the what you just ended with around the claims data. I'm wondering and this may be a premature question but I want to get it out there so you can be thinking about it. What is the interaction between what would be happening in the V high and V cures. Because obviously we're already collecting claims data. So are we going to be collecting it twice. And how is that going to work. Yeah. Oh I'm sorry. Did you have one more. Yeah. Well my other sort of related to that is so if the data is collected from the payers then you have to worry about a risk of preemption. So I'm assuming that there will be somebody working on that aspect of it. And my other sort of related question or thought is if it's possible to collect the claims directly from providers when they're submitting it. Which may or may not be the right time. You may be able to get a fuller set of claims. So I mean those are all great questions and I think the work of the subcommittee to do so the subcommittee is going to look at doing something that we've never done before which is meeting first defining use cases so how do we need to use clinical claims together. And so what are we trying to build for. And then what would that mean for existing systems and existing processes. So one thing that the steering committee has just determined early on and really that was fed by the 2017 evaluation is that there are inefficiencies in the system. So I wouldn't want to say that there is not going to be a look at potential overlap between V high and V cures because that could be something that comes up in the subcommittee. But the idea would be for us to come out with a pilot design so that users can really look at what the system implementation approach would be including what policies we need and where where data would lie to answer all of the questions. And I think one thing particularly that the Greenmont care board staff brought up is it will be important to do with with Medicaid data but Medicaid data is unique in a lot of ways. So we're likely going to have to do this design work. Excuse me with commercial claims as well. Great and presumably Medicare as well Medicare as well. Yes. Thank you. Okay. Great. And then related to the social determinants of health data I happen to be on the blueprint executive committee call this morning and they were talking about the women's health initiative and and how the practices that they're working with are collecting some social determinants of health data. So I was curious to know if the blueprint is involved in in the work or that you guys are connecting so that we're really getting figuring out the right places to be pulling data that's already being collected. It's a great question. So there is a blueprint representative on the steering committee. And of course Steve cheers it but we can always all do a better job of you know being coordinated. So women's health is a data type that we've specifically called out as something that needs to be looked at. And I will put this on my radar but I think sort of similarly to the claims subcommittee a lot of work to be done ahead on social determinants of health particularly on social determinants of health in some ways will be the most challenging because we do not have a lot of federal and state laws guiding us. That makes sense. Thank you. Those were my questions. Thanks. Other questions from the board. Not hearing any Emily so I guess proceed. Okay. So let's talk about COVID COVID response and whereas we're all sitting in our home offices. So you know as you can imagine nationwide there's been there have traditionally been data sharing challenges between public health and sort of the broader healthcare community. So that's not new to HIE. So what is new to new in this situation is how clear it has become that health information exchanges can be really essential to the public health response. So by that I mean that HIEs exist to create efficiencies and connectivity. So for from data source to the HIE creating one pipeline of data as opposed to a public health entity having to create their own pipelines of data and then the HIE creating those pipelines separately with the existence of HIEs and really the purpose of HIEs is to gather data from multiple sources into one central spot. HIEs offer just enhanced data quality because it is their business to translate different data types for different users. And so that is a model of practice that they already have an existence. They obviously offer the record matching service that we were talking about the our HIE in Vermont has just enhanced. But this again is a core function of an HIE to match records across systems and not necessarily a core function of a public health entity. So it's a service that an HIE can offer. It also acts as I'm describing a central access point to clinical data, meaning that as our core function is to bring clinical data from electronic health records into one place. So just sort of to paint the picture nationwide we've dealt with sort of a discrepancy in how public health data is managed and and the existence of HIE HIEs can help with some of sort of the siloed or fractured nature of public health data collection. So in Vermont specifically in early April, the secretary of AHS issued a directive for vital to provide access to patient data on the VHI to AHS to VDH specifically to support the COVID response effort throughout the duration of the governor's declared state of emergency. So a number of things have happened in April to support this effort. And if you don't mind, I'll go over it at a high level, but I think any questions should probably be directed to Beth and Carolyn of vital because this work is evolving so quickly. But I guess just sort of to say this. This is a long list of things that they've been working on since April, but I would summarize their actions as working with the Department of Health Agency of Digital Services and AHS at large to automate state and federal reporting both for the Department of Health and for hospitals. They've also been helping with those daily reports that we see on COVID response. They've aided VDH in doing the contact tracing work so that staff don't have to reach out to providers who are already burdened to gain necessary details to do contact tracing and that same data has helped with syndromic modeling. They've provided data to support care coordination work and they've active as the central aggregator for test results which supports the Department of Health and tracking those test results and also for providers who are able to log into the system to see patients who have been tested. So there's a lot of information here so I'm just going to stop for a moment in case there are specific questions about the response effort that's underway. Are there questions from the board. Yeah I have one. I saw in a joint fiscal committee recently met and awarded recognizing what you have up on the screen now $931,000 to DIVA and I'm just wondering if any of that flows through the vital. Yes all of that is intended to cover work that DIVA has already paid for under the contract or is ongoing through the remainder of the year. So yes the COVID response fund was funding request was approved and I think as you stated which is basically recognizes the importance of vital work in aiding the COVID response effort. In 2021 we've built into our contract monies to continue the COVID response effort. So if there was not COVID response funding available and going forward that work can be accounted for under the contract. Well thank you for that I know when I was talking to Sarah earlier in the week about this. It's just amazing that those reports that some of us kind of are taking interest in every single day. You know we're coming off the vital and the HIE platform and it's just and that it happened so fast. So congratulations to all of you on that. Beth or Carol did you want to add anything there. Thank you covered it perfectly thank you. Before I forget though I would like to thank Beth and vital for not only the COVID response but also for the help that they've given in the cybersecurity issues that are currently being dealt with by the network. So vital has really been proving it's worth so thank you. Thank you. We are happy to be helpful where we can. Unfortunate circumstances but happy to be helpful. Yeah the silver lining I think we all agree has been that vital has been able to demonstrate how valuable an HIE can really be in times of emergency and hopefully in day to day work. So when we think about continuing this momentum that Department of Health and vital are really seeing the benefit in integration as I mentioned we're going to keep the COVID work going for as long as necessary under the current contract. Our federal partners are in the long term outside of an emergency very interested in HIE and public health integration. And so this is certainly in their wheelhouse of things that they are willing to fund. And then thinking about prep for future emergencies. Vital is has proposed you know continued work so that in the event of a future emergency the HIE is ready and established to support things like automated hospital reporting and lab data collection. We've also been talking to the Department of Health about leveraging the HIE functionalities to enhance their registries. And so one piece of work that's well the immunization connection to the HIE already already existed until we're talking about enhancing that. But the another piece of work that's new is death registry connection to the HIE so that providers have access to real time death information which has been a challenge in Vermont for many years. Okay. And then I actually updated this slide so I hope you don't mind. I think I articulated it in a confusing way before. So I also wanted to note that the protocols for access to protected health information on the VHIE have been updated to do a couple of things. Articulate how health data can be accessed by VDH from the VHIE to support VH's work that's mandated by federal and state law as an example immunization reporting. And then it articulates this concept of a significant public health risk in state law. But it basically allows the commissioner of the Department of Health to determine when it would be necessary to access a great data for emergency response or to mitigate a public health risk. So that as a reminder those protocols are we're sort of the next iteration of the consent policy that now lives within the HIE plan for your approval. Okay. So I'm going to move on from the COVID work. Okay. Another big if you can imagine lots of big things happening this year. Another big thing that she that dropped this year was the final interoperability quote unquote rules from U.S. Health and Human Services. So this is a joint set of rules from the Office of the National Coordinator and CMS that basically are intended to work together to put the patient at the center of their health care by opening a window to them to their own health care and a window to information about their health care providers. So the way that they work together is the Office of the National Coordinator sort of sets the technical framework and enforcement and enforcement framework that CMS builds off of. And so they're each kind of regulating different actors to drive efforts that will open data access to patients. So the Office of the National Coordinator is really focused on this one focused on health information exchanges health IT developers and health care providers and how they access how they open access to data. And I'm going to use a techie term for just a second. It's called an API. I think about it as a window into data. So how we open our window you open your window and then we can share information across the open windows. That's the idea. And so there's a technical framework for doing so. They've also enhanced IT the IT certification process for IT developers and they've defined a term called information blocking to prevent folks from not sharing patient data. And then they've raised the baseline for data exchange standards relying now on something called the US core data set for interoperability which is just an enhancement to federal standards that already existed. So the next one the CMS interoperability and patient access final rules. They're focused on payers providing Medicare Advantage Medicaid chip and QHPs on the federally facilitated exchanges. So in Vermont that's really it's just Medicaid that's impacted here. And so they're relying on the technical standards set forth by the ONC as I said to drive action. And so that will mean for Medicaid opening access to claims and encounter data for Medicaid beneficiaries. I kind of I sort of breezed over that one because it can get technical quick. But the idea there was just to leave you with the notion that there are new federal rules. Again an effort from the federal government to enhance or excuse me further this idea of interoperability or systems talking to one another. And so if you think back to that the beginning of the High Tech Act it was to digitize electronic health records. So to get money to health care organizations so they purchased electronic health records so we could just start moving from paper to electronic health records. And then they expanded the funding and wanted to amplify health information exchanges. So there were entities that could collect and exchange this data. And now as a further step they're saying that they want to promote interoperability by opening or excuse me creating a framework whereby patients have access to their own data. Okay so I'm going to move on to the next one. Okay so in 2020 the I should say in 2019 the steering committee set forth a lot of work to go forward into 2020. And a lot of work has happened this year despite all of the the myriad challenges that have come up in our health system. So the first is the collaborative services subcommittee that we talked about a little bit. Those are the group of people who helped to vital procure a data repository to find what their use cases were and assessed for the steering committee. How they think the collaborative services project is going to further the goal set forth in the HIE plan. And so they're going to continue or I guess that is on the next slide so I won't pre up to myself. So in the 2020 the connectivity criteria subcommittee got together. They updated the connectivity criteria which Carolyn will present. And then they expanded the focus to support connectivity with designated agencies. And as I mentioned that's sort of a pilot program for how vital will manage substance use disorder mental health and behavioral health data. The interface prioritization subcommittee came up with a matrix to help us support vital and annually selecting connectivity priorities. And by connectivity priorities I mean which how resources will be funded to connect healthcare organizations to the HIE. This consent subcommittee continued their work in evaluating the rollout of the shift in the consent policy. And there is an assessment of this work although we're expecting major findings from the patient engagement survey which will be available later this month. And then finally the part two plus group which is a group that vitals leading is an effort to pull together stakeholders to develop an informed policy and processes at vital for managing substance use disorder data and other sensitive data types. This work will be largely impacted by the rollout of the CARES Act but vital has begun by really designing a really robust stakeholder engagement process to be ready for that. So looking ahead for these groups in 2021 the collaborative services subcommittee is going to aid vital in developing a longer term technical roadmap. So thinking about the future phases of collaborative services how will the HIE platform be used to meet the needs of Vermont's customers. The connectivity criteria subcommittee will continue to update the criteria considering changes to federal law considering changes in Vermont's needs. And then update that criteria depending on how far we get with updated or excuse me new data types. So for example expanding to include social determinants of health. The interface prioritization subcommittee will develop annual connectivity priorities they'll be working on that in the early part of 2021. New population health subcommittee will be looking to advise vital and other health data producers and aggregators on needed data sets to augment research and population health management efforts. So it hasn't felt like we've really had a table of advisors to sit down and talk about how that data repository or excuse me how upcoming research or population health management means so that vital and other health data producers can prepare. And in 2021 we're going to focus that group on social determinants of health. The part two group will continue as I mentioned and really their work ahead is going to be impacted by the CARES Act. And yeah so we expect that depending on how the final rules for the CARES Act come out that we may be coming back midterm with an update to the protocols for data access. On the VHI if it does look like we're able to advance with the aggregation of sensitive data types this year. The outcomes based certification subcommittee is also a new group. CMS has offered us a new opportunity to certify the HIE which is which opens the door to maintenance funding of the HIE which has never been before been available to us. And so we will be one of the first states to pursue the certification of an HIE. And so we're working now to define the outcome measures that will hopefully allow us collectively to measure the value of the VHI going forward. And then the claims pilot subcommittee which I think to Robin's question we discussed a little bit before but basically they'll be designing a pilot to test the integration of claims data into the VHI. And then just a couple of notes on the the steering committee going forward the committee has requested that we invite new representatives from long term care and home health. So the CEO from Central Vermont Home Health and Hospice will be joining us and we're still looking for a long long term care representative. Okay. So I threw this up there one more time just to kind of reiterate sort of all the subcommittee work that we're doing for the year ahead but I think we've gone over it. Okay. And then I'm putting this one up one more time because I just wanted to spend a moment talking about Diva and Vitals contract for calendar year 21. We have our civil negotiations so I can't tell you the details but I wanted to go over one I think important point which is that since we've created this concept and you know we talked about accountability and clarity and transparency. Vitals contracts with Diva have mirrored this these concepts that we have in the HIE plan including investments in tier one and tier two of this sort of stack of HIE capabilities that we talk about. So another way to look at it is on the left you're seeing that same stack. It's just now in a pyramid and on the right you're seeing kind of concepts that we should see in the calendar year 21 contract with between Diva and vital. So for example at the foundational level we're investing in an MPI which is already done, policy management, the medical soft platform which is that data repository exchange services. We're talking about translating data, interoperating systems, end user services that would be things that go beyond sort of the foundation of public investment. But we are also kind of wearing the hat as a consumer of HIE services. So that's COVID-19 reporting, Medicaid services reporting and the extra to the blue card for health. And then at the top here there are some end user services that we will be funding and that is to ensure that the HIE meets the new interoperability rules and can provide access to patients as directed by federal law. And then it's to ensure that we're ready to certify the HIE system so that we can gain federal investment to maintain the system in the long term. So hopefully that makes sense. Okay, I'm going to shift gears and go over to the HIE ecosystem parts unless there are questions. Not hearing any so you might as well proceed. Sorry, this is Robin. I took me a while to get to the mute. I had a question on the provider access to protected health information protocol, but I can come back to it later if that would be better. Oh, I'm happy to go back over here. Whatever works best for you, Robin. Well, I'll throw it out there because I my questions you probably are going to need to take back to general counselor VDH. So let me just get them out there and if it would be helpful for me to work with Sarah to email them so that they're clear for the translation just let me know. Thank you for your the slide I thought was clear in the actual policy document I found the drafting of section five the public health access to be a little bit confusing because there's a paragraph V and a paragraph V and I would read them as interacting but that's not clear from the document so I think with some minor modifications that could be clarified. So that would be one thing that I would be looking for before we vote on it. And then I also have some questions about the definition of public health authorities in terms of how broad or narrow that is. It's clearly to me would include VDH. Their county level officers and the CDC, but I'm not sure if it's intended to be broader than that so that was the other clarification that I was hoping to begin. Okay, you are right I feel like I will need to take those back but thank you I think I got them but if if writing them down as possible that would be great to absolutely. Okay, absolutely. Thank you. No thank you I appreciate it it's been a really great collaboration between board staff and Department of Health and Diva and trying to get these protocols in the right place so thank you very much for everybody's work so far and thanks for the work ahead. So the final thing I'm hoping to do before I turn it over to Vital to talk about the connectivity criteria is just to revisit these HIE ecosystem component parts. Because in the original 2018 plan we talked about sort of maturity models for each and so I wanted to revisit where we think we are and where we think we're going. So as Robin just asked a question about you know we've we are introducing updates the protocols for access to data on the VHIE and what I've sort of circled here is this statewide consent management. So what we basically have in these protocols is a unified consent management process that articulates how we govern the physical health data or the data the clinical data coming directly from electronic health records without sort of that clinically sensitive data included. And so what we think is the evolution is that sort of all of the organizations that comprise the network are building aligned processes. So we think that there we will continue to evolve these protocols and continue to update HIE plan to reflect that evolution. And so we think likely the next topic to be considered would be clinically sensitive data again waiting for those federal rules to come down. But if what's expected is that there'll be greater alignment between HIPAA and Part 2. We will be able to articulate how we are manifesting that new data collection through the VHIE in Vermont. So looking at finance a couple of things to note here. I think we've been talking about for a couple of years first that the US High Tech Act funding which was really stimulus funding which we've been using since 2011. It expires at the end of next year September 2021. And so this means that a lot of the development dollars that we've used to amplify the HIE to build out the public health systems and to incentivize the adoption of electronic health records are going away. What CMS says though as you can tell from the interoperability rules is their investment in this work is not done but it is changing. And so they are shifting from something that was basically a stimulus fund to more traditional Medicaid enterprise systems funding which with comes with different rules about who can benefit from the funding and how costs are allocated. They're also offering as I mentioned this outcomes based certification process which opens a new door for us to obtain maintenance funds. Right now a great portion of the state's HIE fund is used to maintain the HIE and so opening the door for more federal investment would would just allow more dollars for development work. I'm noting here that the steering committee supports an extension of the HIE fund the HIE fund is that small claims tax on private funds. It continues to propel this work for a number of years. The HIE fund generally sends us every year in the legislature reviews the HIE work and suggests that it continues. Last two years ago it was extended for two years considering the progress being made by the state and vital. And so we go before the legislature again this coming session to hopefully get that HIE fund extended without those resources it would be a real challenge to do this work. And finally just a note that the collaborative services project is expected to position the VI to provide demand driven services so again in sort of that phase four of the project. It you know opening the door to customers to work directly with vital on leveraging the HIE services that would benefit them. On the governance part of the HIE ecosystem I just thought it was important to note and we have a new section in our new narrative in this year about data governance. And we were calling out specifically a couple of things one that vital does not own health data rather it acts as the stored of health data that originates from various sources. So because that's true we need a comprehensive way to govern the way that data is made available access how systems interchange the data how that data access is audited the quality of the data and the security of the data. And so what the steering committee has agreed to do is ensure that there is sort of a current of data governance within the subcommittees and then the larger sub steering committee itself will be used to pull together the different data governance concepts and work with other data governance entities like at the HIE and on technologies so you know we continue to use that sort of stack diagram we're talking about the foundation of the house exchange services and the end user services on top but we took another look at a way to depict the architecture of the HIE in Vermont this year and and the steering committee agreed so this is kind of a look ahead although a lot of these systems are already in place so you see that vitals infrastructure is sort of central here where we've got bidirectional feeds between electronic health records and the HIE infrastructure itself. The HIE can has a data warehouse meaning that it can it can aggregate and extract a different data. It has the ability to do translations or take many terms and translate them into one depending on the the user need to match MPIs match patient records across systems and then use the integration engine to make sure that the parts of the records that need to get to where they are go to the right place. You see on the right here there's non EHR non electronic health record data sources feeding in. So that's look at potentially getting insurance claims geographic information more social determinants of health data and public health data. And then feeding all of those data types out for population and public health work and then for provider in patient access and analytics work. So that's just a sort of a new structure that the HIE steering committee thought represented sort of the the work that we're trying to do as building the HIE to in building the HIE is sort of central to the HIE ecosystem technologically in Vermont. Okay, so that it concludes my part of the presentation so Carolyn I have this slide up for you. Thank you. So yeah, thank you for the opportunity. As a review the connectivity criteria is a tiered system that establishes standards for connecting and meeting the data quality goals of the V hi and our downstream stakeholders who use the data. As Emily mentioned, we've based the criteria based on the federal interoperability standards that were passed earlier this year as part of the own Secures Act. This includes the US HDI or the US core data for interoperability steps. And, you know, in the past few years, our initial criteria was mainly based on primary care of physical health providers. So as we started to explore taking on these new data types. It became clear that we needed additional ways of categorizing or measuring data quality for the different organizations. So, you know, for an example, mental or behavioral health providers are not expected to run cholesterol tests, but they may be expected to run red blood cell count tests, which are very common when treating. So, you know, to support bringing on this new data type in the future. The vital and the connectivity criteria subcommittee worked to develop new criteria for mental health and behavioral health organizations. Our work was primarily based on the expertise and data being collected by the designated agencies we work closely with Vermont care partners and their member agencies, and the rest of the subcommittee to influence and guide our decisions. It really is meant to serve the broader group of organizations going forward. That was just a great starting place, because the designated agencies, implementing their new EMRs this year. Had a really good view into their data and making sure that their data could meet what was needed. So that was that was a major effort. In addition to that, we also did a review of the existing physical health criteria. And we decided that that was working fairly well. You know, this year has been definitely disrupted by COVID and much attention and focus has been there. We did add the COVID-19 vaccination to the tier two immunization list, knowing how important that's going to be for all immunization data to be collected that way for the state once the vaccine becomes available. And we've provided all of these documents, all the standard documents associated with the criteria as an attachment to the HIE plan. Are there any questions on that a brief summary. Will it make any difference. If the vaccines were made available free or not on your ability with the data. It should not. We're working closely with the Vermont Department of Health and the teams, the logistic teams and everyone else in the state. On the statewide plan to ensure that we can try and capture as much of that data as possible. We're working electronically from whoever's providing it, irregardless of whether it's free or not CVS and Walgreens are the two major pharmacy change who will be leading the, the vaccine efforts with that the federal government is paying for. And we're already connected to CVS and we're in the process of trying to connect Walgreens right now in preparation for that. Just ask a quick question. I'm just wondering if the recent cyber attack has changed people's willingness to consent to having their records. You know, accessible. So change any of the opt in opt out data or discussions. I think in some ways it depends on who you're talking to if you're talking to providers who would like to be able to see their own data, then they're very much in favor of sharing data with us at this point because they've seen the value of it. If you're talking about patients. I would have to check to see whether the numbers did go up, the number of opt out or the number of conversations that we got, you know, asked about. We haven't seen a large, we haven't seen a change that would indicate there was a big shift, at least initial looks now. So if you don't mind me adding one thing. This is the hard part about consent is, you know, data is aggregated in electronic health records so the VHS just collecting it for exchange and so that I mean, and I know you know that of course. And I see where your question is coming from of course, it just, you know, that data is clearly out there. And so the existence of the he doesn't change that. Right, that's what I was thinking actually I was thinking there may be more interest in either submitting the data and or having patients knowing that their data is back, you know, is well it's already up there but having their providers be able to access it in the event of a, you know, cyber event. So I just was wondering if it changes those mindsets on either side consumers or providers. We've, we've definitely heard stories of a number of patients who went to their providers in the past couple of weeks or past two weeks and heard that they were now using the vital tools of their source of data. Maybe just a quick other question. How much do you think maybe this is a question for Emily. How much do you think that the anticipated maintenance funding that we might be able to draw down from the federal government through this outcomes based organization. How much will that offset the funding that has been coming through from the high tech act that's going to expire like how much you know what percentage of it will be maintained if in the event that that funding through the new stream is available to Vermont. I wish that I had a straightforward answer to your question what we're going to be doing over the next couple of months is proposing a new cost allocation methodology to CMS, because basically high tech allowed us to take the benefit to based on the number of providers serving Medicaid beneficiaries and what the new funding stream is focused on is patients and so obviously the ratio of Medicaid patients to the total is much smaller than the number of providers serving Medicaid patients in Vermont. And so that's going to be something that we struggle with, but we are feeling optimistic at this point because of CMS's intention to keep this work moving forward. In a lot of ways we are going to be interacting with a new part of CMS that has never managed this type of work. So it's going to be a lot of going back and forth on what may work for this for this work in this tiny state. So developing a new public funding model I'd say is the top of my priority list for the beginning part of 2021 and there are a lot of component parts. I hope that soon we'll have more answers. Well, good luck with that. It's important. I just had one question on when you looked at the deliverables that you had laid out for 2021 and first thank you for the presentation. It was very thorough. What risks do you see in meeting all of those deliverables, if any, and you know, either either from Emily or back whoever wants to sign in. Beth, I'm happy to start. I would say that the state and vital share a goal to not overextend ourselves and to continue this work going forward. It's very important to meet expectations considering where we were just a couple of years ago and the really positive momentum that we have going forward. And so I think that's our commitment. And so all of the conversations that we have about what's possible. Consider what's what currently needs to be finished. Beth, I don't know if you want to put more color on that. Yeah, I think I would thank you. I mean, I think you're completely right. I think the one thing I would point to and you heard this a little bit from us. I think in September that we presented our quarterly update update. You know, we are a little behind on the medical implementation of the new platform for next year. We have a new plan, you know, we've kind of re estimated based upon what we've learned about the platform and the technology also our estimates of how much of our time will be focused on COVID work right which we didn't have on our plan surprisingly this year. And I think we have a good, a good plan to achieve all of these deliverables for next year. Thanks. So I have a question. I'm just wondering if there's any relationship at all or any potential for integrating this, the interoperability, the hardware to pronounce interoperability. There are several rules to integrate those with the new rule that's also coming out on January 1 having to do with price transparency and the negotiated rates of providers along with estimates of out of pocket expenses because it would just seem to me, you know, here's a universal question that we're trying to create and and the first it has to do with a patient access to their records. And why wouldn't we want to try to integrate that with price transparency. So it's kind of one stop shopping for reminders. And the trace price transparency under the support act is that I believe where it's coming from. And the CMS announced I think in November to go live January 1 this January 1. That is a really good question. I don't know about integration of federal rules but I will say in sort of like the practice of CMS supporting our work a lot of what we hear is better integrations of system, including pharmaceutical systems are prescription drug monitoring system. So it seems that they would be leaning that way and I'm sure look to states to see how that could be implemented I haven't gotten a real directive though on the collaboration of that but it's a good concept to be thinking about. And from what I've read that, which isn't that much but the data is going to be readily available in kind of a standard operating system. So, so it'll be there. You know, the hospitals are going to have to produce it. So I just, it just seems to me that, you know, rather than have the scattered around. If that could be integrated or it would be helpful. One thing that might come up is so what payers and he is and others are being asked to do is like sort of keep using this analogy of a window it's on API opening the window to data, but they're not being asked to do like the actual, you know, application on your cell phone. So not you get to choose what app you use to get that data out of the window. So it will be interesting to see if application developers think of the same idea that you're thinking of which is like let's just create apps where we get we provide access to all of the available data that might that a patient might need including price transparency. Well to me it just seemed that there's coming out of the starting blocks on January 1 of these two things going on at the same time, and they seem on a common sense basis pretty related but Another question I had is kind of looking at the collaborative services work and and the development over the last year of estimates of what that saved the system that the the avoided cost the value of of aligning these three you know in a unified way. And I'm wondering as you begin to look at your kind of long term funding approach. If, if, if it makes sense to kind of link the benefits of the HIV system. And with, you know, who benefits and who pays right now, you know, with the high tech tax it's a tax. And, you know, certainly we would all support, at least I would support, you know, keeping that tax it makes sense but I'm just wondering out there in it with a system that is is is there for a lot of people to benefit from that the relationship between those who benefit and those who pay might be a little askew and so as we go through the work programs, kind of looking at these, these areas where, like for example and I don't know this I don't know whether the, the insurance plans that we lost with the go bait decision, you know, I don't know how much they benefit by the system that we, you know, that we're talking about today, and how much those folks contribute to the support of the system. So, I'm just thinking, as you go through this. You know, and or entertaining the linkage between who benefits with who pays might expose some areas where people you could see long term funding for you. And my final question. That wasn't a question I guess that was an observation. But this is a question one of the when I first came on the board one of the charts that astounded me was this, what are the driving forces of health and behavior and this seemed well established because I saw this chart a lot that individual behaviors 40% genetics was 30% health care was 10% environmental was 5% and the social circumstances kind of the social determinants of health for 15%. So, I'm just, I'm just wondering what, what is the expected, what is the expectation to be found from this pilot project with one care in that context. Yeah, I mean, I'm on the side of things where we're providing data for the rest ratification work and the implementation that one cares doing so probably better for others at AHS or one care to answer that question but I will say sort of a related thing which is I think many people in the health care industry including payers are really interested in, you know, addressing each of those component parts to shift the needle in a positive way. And so we've gotten a lot of interest in the social determinant of health work because of that, the committee to define the policies and the protocols for making sure that that data is available no matter what the effort is to to address the facets of people's lives that impact their health and well being. I mean, it makes sense, but it's, it makes sense to me is kind of looking at, I mean, at those relationships but I'm just wondering how this project developed in that context. But that's my questions and observations I think you come a long way in the last two years it's been the energy is palpable and you know to see the kind of step into the shoes in this COVID-19 crisis and be an instrumental force in terms of informing the public and contract trace tracing folks is is just a gift and thank you all for it. Any other questions from the board. Are you finished with the your presentation Emily completely. Yes. Okay. Sarah, could you walk us through our next steps. Thank you. So I'm going to go off video and start sharing slides again and I'll just walk those through. I'm having a little trouble sharing slides. Maybe that I think Emily's still sharing something on the screen. So maybe if she could exit the screen there we go. Can you do it now Sarah. Thanks Emily. And then again maybe not. Are you potentially able to pop these slides on the screen. Yeah I just have to pull them up to me a second. We need to shoot them over to you Abigail. Sorry about the folks. Are they showing up now. Yes. Yes they are. Thank you. I'm over. Great. Thanks. Abigail will you go to slide. For. Thank you. Perfect. Okay. So this is question of honor, and I'll just go through the steps that Deva and vital. For that presentation. I'm just gonna, as the said walk us through the principles that we use to review the HIE plan and connectivity criteria. And then walk through the preliminary findings that the staff review. So a quick timeline and process reminder. Diba submitted the plan to the board earlier this month. and in her and her executive director's report and that public comment period will end on November 30th. Today I'll walk us through the staff review following public comment. We'll have a staff recommendation of potential votes on December 2nd for both the HIE plan and connectivity criteria. So a little bit of history on this in 2018 when we received the HIE, the version of the HIE plan that this is an update to staff proposed for principles for review. They can really be summarized as alignment with our statutes and alignment with the HIE plan statute, whether the HIE plan meets the goals of other recent relevant legislation and whether the HIE plan incorporates national best practices and stakeholder input. Abigail, will you go to slide six? Thank you. So first is the HIE plan consistent with the statute. Section 9351 describes requirements for the plan including supporting effective efficient statewide use of electronic health information for a variety of purposes, educating providers in the public, supporting interoperability, proposing strategic investments in technology and infrastructure, recommending funding mechanisms, incorporating existing initiatives wherever possible, integrating the blueprint and other Medicaid information systems and addressing issues related to governance and security. It also specifies that the HIE is to use an opt-out consent model starting in March 2020. So the staff finding is that the HIE plan does meet each of these criteria. The plan approved in 2018 that this is based on really focused on setting a groundwork for thoughtful planning and investment. And this update reports on work to further develop the foundational and exchange services that underpin all successful HIE efforts. The foundation and walls and roofs of the house that Emily was talking about. And it also describes work plans for the coming years that will continue to further those aims. This year's plan really reports major strides and describes upcoming work, particularly supporting interoperability and strategic technology and infrastructure investments through the collaborative services project, which is also making big steps forward in blueprint V-high integration as the Vermont clinical registry system got folded into the V-high this year. The HIE plan also includes an updated protocol for accessing P-H-I contained in the V-high and appendix A, if you heard, which outlines how the opt-out consent model can function in terms of providers and the public health entities access to patient data, which again is super timely this year. Planning for integration of additional data types is also moving forward, particularly data produced by providers subject to 42 CFR Part II and other sensitive clinical data as well as the social determinants of health data from Vermont, from state of Vermont data sources. Abigail, will you move me to the next slide, please? Thank you. So that's kind of half of the statutory obligation side. The second half is related to how the HIE plan supports achieving the principles for healthcare reform. Act 48 established 14 principles for healthcare reform. And in a 2018 decision to approve the HIE plan, the board found that the plan spoke to several of these principles, either directly or a little bit more indirectly. These areas really still remain core to the 2020 update and have not changed. So those descriptions remain on this slide. But rather than read that to you, I just want to highlight that these principles for healthcare reform, I think are really well aligned with those three HIE system goals that Emily described earlier and that are laid out in the HIE plan of creating one health record for every person to support clinical care, improving healthcare operations such as QI efforts and reporting and really supporting policymaking and evaluation. I do want to note on the last bullet on this slide that stakeholder engagement has changed somewhat from past years and especially due to COVID, but that there's a much broader collection of stakeholders engaged in the development of the HIE plan and the implementation of the HIE plan through those HIE steering committee subcommittees. So that's kind of more ongoing now. Next slide, please. The third principle focuses on alignment with other relevant legislation. So there wasn't big new legislation related to HIE or vital in 2020, but there was in 2017, 18 and 19 and I think those are all still quite relevant. So we've included a review of those as the board heard last year, implementing the consent change to opt out consent required by Act 53 was a major focus of HIE work in 2019 and early 2020, particularly engaging key stakeholders and Vermonters around what this change means for them and their options in terms of opting in or opting out or including their data in the behind. An evaluation of the policy changes included the appendix G of this year's plan, which we want to highlight. In addition, this year's update really demonstrates continued efforts to improve operational effectiveness and governance according to the goals of Act 73 and Act 2087. Next slide, please. So finally, does this plan incorporate best practices and expertise as well as feedback from stakeholders? In terms of national best practices and expertise, the 2018 plan built on national standards and models for HIE governance technology. D-Ven, the HIE Steering Committee, consulted with the Federal Office of the National Coordinator for HIE, including experts from Colorado and Oklahoma, which both have very successful HIEs so that we could learn about their governance and financing. These best practices continue to underpin the updated HIE plan. And in terms of incorporating feedback from Vermonters, the HIE Steering Committee and its subcommittees include stakeholders from a variety of key HIE constituencies, including hospitals, FQHDs, DAs, one care, payers, the blueprint and VDH. And this includes high level leadership as well as the high data users who can kind of inform on the more technical issues. On that, that COVID-19 hampered D-Ven's efforts to present directly to groups of practicing providers like NCDP CAG, but expanded subcommittees in 2020 again resulted in greater stakeholder participation and actual HIE plan development from the start. On consent, as required by Act 53, Diva made major efforts to engage stakeholders and Vermonters in the HIE Consent Policy Change, including the groups listed here on the slide. In addition, Diva hosted focus groups for Vermonters, specifically for Vermonters living with developmental disabilities from their families, Vermonters living with HIGAs and refugees and new Americans, as well as three focus groups in different parts of the state that engage the general population of individuals seeking healthcare in Vermonters. Work to engage and educate consumers on this change continued into 2020 as vital prepared to make the change to opt out consent in March. Would the board like to have any discussion or have any questions about the HIE plan assessment or should we move on to connectivity criteria and discuss at the end? Any questions from the board? I guess we'll move on. Alrighty, next slide please Abigail. Thank you. So moving on to the connectivity criteria. Here we use two principles for the board's annual review focusing on alignment with HIE plan goals and the clarity of the criteria themselves since this is really an operational tool. Next slide please. So first are the proposed criteria and alignment with HIE plan goals and will they support implementation of the plan and achievement of the state health reform goals? I believe the answer here is yes. This year's connectivity criteria remain aligned with the HIE plan's goals and structure and will support increased availability of high quality usable data which is really critical to achieving our health reform goals. The 2021 connectivity criteria made minor adjustments to the physical health criteria that are included in tiers two and three from last year while adding mental health and behavioral health data elements to support exchange with DAs and other mental health or behavioral health providers. This new data, these new data elements will support the goals of the HIE plan very much. And then secondly, are the proposed criteria sufficiently clear to be operationalized by vital, state, and provider organizations? And again, I believe the answer is yes. These criteria were really developed to expand providers' abilities to submit and receive structured data from the B-High in part by providing specific standards and requirements to support providers in contract negotiations with the HR vendors. That is all. Abbey, do you mind going to the last slide? Thank you. So just to wrap up, I'll return to the board on December 2nd for the recommendation following the end of public comment period which goes through November 30th. And that is all I have to present. Thank you. Are there any last-minute questions for Sarah from the board? If not I'm going to open it up for public comment for anything that that's been talked about from whether it's DEVA, VITAL, or the board. So public comment. Have a question. Go ahead, Dale. When it comes to the contact tracing, are they able to determine the accuracy of the data itself in terms of even if there has been issues about people answering the questions honestly or is it simply they're able to tell that flow of transmission? It seems relevant to me and I haven't seen anybody really speak on it. How well the compliance is in terms of answering contact tracing questions. I might be revealing my age because I can remember the outbreaks in the old days before we had very many vaccines at all for anything and what that looked like. And that was actually a very relevant question back then. You had to answer honestly if you were contacted by a contact tracer. That was considered by huge offense if you did not. Not criminal in nature necessarily, but still huge as an offense. Any feedback on that from them? Anyone? So I'll answer. So my understanding of the way that the vital data is being used in contact tracing is more for using it for finding finding finding contact. So once someone gives them a person's information, it might help them find an address or a phone number to be able to do the reach out. And I don't believe that they're using our data to actually identify who someone's who and a positive patient who has been in contact with. It's more for finding out how to get in touch with them. So I can't answer your question directly. Okay. Thank you. Is there any other public comment? Hi, this is Mort Wasserman and I have a question. Go ahead, Mort. So I was struck by the term physical health data in the presentation from Vital. And I was wondering if a provider lists as a problem. So the de facto mental health system for most Vermonters, children and adults is actually the primary care system. It's not the behavioral health system. So if I as a provider put down depression and I put on my medications, SSRI or some other medication, is that scrubbed or is that considered physical with air quotes, health data? You know, in terms of the data repository, we don't designate whether something fits into a category. But as we're working with providers and organizations to onboard them and to try and get as much quality data, we take into account what type of data provider they are. And the criteria and the connectivity criteria are just the minimum we're looking for. It's not that we won't accept any data that they can provide on the patient. It's just to say, have they met a minimum data quality standard to participate in some of the downstream programs effectively? Right. So this isn't a data quality comment. This is a data content comment. It sounds like there are plenty of behavioral health data and I believe as a provider who is seeing patients, I'd wanna know what medications and what diagnoses had been given to a patient that I didn't actually know. So it seems like there are plenty of behavioral health data in the current physical air quotes again, health data, which is reassuring to me. And the behavior, adding behavioral health from the behavioral health providers is only a fraction of mental health and behavioral health problems for Vermont. And so even a primary care provider as permission to treat patients for substance abuse, I would assume herd data are also the problem less. Substance abuse disorder might also be in that quote, physical data unquote. It could absolutely be. So the first step in the process is to have the organization that we're looking to onboard go through that criteria and say, what do they even collect in terms of their care that they provide? Because each organization we work with is slightly different. So we find out what they provide and then we say, okay, if you have that data, if you are generating those types of data, can we get it into the electronic submissions to the VI? And we use the criteria to really prioritize, if you don't have much of it in there, if you only have 10% in there, we use that list that's in the criteria to prioritize what are the top things that would make the most impact? And tier two would be the first places we would focus. And then we would say, okay, great, you did tier two this year, let's work on tier two next year because that's gonna be a much bigger lift and your EMR vendor might have some work to do or you have some workflow processes that you need to reimplement or work on to be able to provide that data in a discrete format. So it's really the baseline by which we can somehow measure data quality. It's not to say that we're going to only accept one type of data or another from an organization, if that makes more sense. Yeah. Thank you. Okay, is there other public comment? Hearing none, I wish to thank everybody for the very succinct and informative presentation. So thank you. The next item on the agenda is old business for the board. I'm gonna call on Mike Barber to make an announcement. Thank you, Kevin. I just need to announce the board's decision on the 2021 large group HMO rate filing of MVP health plan. MVP proposed a negative 1.2% annual rate change for members renewing in the first quarter of 2021. On November 12th, 2020, the board modified and then approved the filing resulting in an average annual rate change of approximately minus 4.6%. There are approximately 2,100 members enrolled in these large group plans in Vermont. And that's all I have. Thank you. Thank you, Mike. Is there any other old business to come before the board at this time? Thank you. Thank you.