The State’s Medicaid Requirements for a Clinical Data Repository

November 1, 2017

November 1, 2017

To:                   Selected CIOs, Rural Health CEOs, and Public Policy Advisory Group

From:              Claudia Sanders, Senior Vice President, Special Projects, 206-216-2508

Zosia Stanley, Director, Government Affairs, 206-216-2511

Subject:           The State’s Medicaid Requirements for a Clinical Data Repository


To provide information on Medicaid hospital and provider requirements to participate in the state’s clinical data repository.


This bulletin applies to all hospitals and providers that treat Medicaid patients and have an electronic health record meeting federal certification standards.


We recommend that hospitals review the information provided and contact WSHA staff to let us know about issues and benefits for your hospital with the state’s establishment of a clinical data repository.


The state is moving forward with its plan to require that all hospitals that treat Medicaid patients participate in a clinical data repository. Yet, member hospitals have raised significant issues about the repository. The issues are both technical and substantive. On the substantive side, some hospitals are questioning the cost and burden of participation in this system, and its value to the clinicians treating patients. On the technical side, the state and its contractor, OneHealthPort, are working to solve several issues: 1.) Working with provider and vendor systems, enabling them to transmit the information required by the repository; 2.) Eliminating or reducing problems that have arisen in matching patient record information across disparate systems; and 3.) Appropriately protecting sensitive information, such as information on the mental health care of a patient.

To make sure we understood the issues being raised by members, WSHA and the Washington State Medical Association (WSMA) held a meeting with invited provider representatives on October 16th.  The meeting reinforced the need of both organizations to engage in a high-level discussion with the Health Care Authority on its implementation plans.

Next Steps

The group of providers gathered on October 16th recommended WSHA and WSMA convene a follow-up meeting between a small group of provider representatives and the Health Care Authority. That meeting is being scheduled for early December. The WSHA and WSMA provider representatives and staff will discuss with the Health Care Authority and OneHealthPort how the state intends to approach this work moving forward. They will also discuss how to better represent, address and communicate provider issues and concerns on implementation plans.

Background and References

In 2013 as the state launched its transformation work as part of the Healthier Washington initiatives, it became clear there was a need for better information to improve clinical care and support strategies for population health and a transition to value-based payment. Providers acknowledged the need for access to clinical data on Medicaid patients from across the provider community to provide clinically appropriate and cost-effective care.

The repository is intended to aggregate clinical information from disparate EHRs in one accessible location. To fund the work, the state required all Medicaid managed care organizations to pay a sponsorship fee for their enrollees. The state is also mandating that its managed care plans require their subcontracted provider organizations with certified EHRs to transmit care summaries accessible via the repository. The summary, called a continuity of care document, is a standardized electronic transaction and includes information about a patient’s diagnoses, procedures, and other information.

As with any technological solution, the state has encountered issues as it has worked with providers to implement the clinical data repository. The original state deadlines were not achievable since many of the providers’ EHR vendors were not set up to transmit the continuity of care document. Many of the vendors have now implemented solutions, but other technical issues remain around matching patient records and protecting the privacy of certain confidential information, such as protected mental health information.

Link to documents summarizing the October 16th meeting

For background on the CDR, WSHA did a webcast on 2/23/16



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