The typical use case of an HIE under a federated exchange model transaction involves:

• Initiation of a request to the HIE service to determine if a person has relevant medical information within the HIE;
• A response is returned to the requesting organization, which would request to receive the relevant data.
• The HIE service would verify that the requesting organization is authorized, authenticated, and has access privileges to the information and that the person has provided consent for transmission of the given information;
• The approval along with supporting metadata is transmitted to the supplying organization who has the relevant information; and
• The disclosing organization would supply the information as required by the underlying data sharing or HIE participation agreements.

Both HIEs and networks of HIE (basically the NHIN) must be able establishing a baseline of trust among participants, typically, this trust includes–

• Processes to ensure the integrity of patient data;
• Verifiability of data after transforming, storing and/or sending (e.g. checksum, error checking, etc.);
• Verification that the data source and data content are true; and
• Organization the HIE or the NHIN can define standardized data values and a protocol format for sharing medical data.

Implementation usually requires:

• A data sharing agreements and policies to enable information sharing and make system usable;
• An enterprise master patient index (eMPI) which serves as a record locator; and
• A balancing of data standardization (normalization) and physician freedom to have clinical control of the medical record while being efficient in their treatment of patients.[ii]

I have excerpted privacy and security related covenants from a document entitled Overview: Data Use and Reciprocal Support (DURSA) Provisions Overview, dated November 20, 2009, which provides a summary of key features of a comprehensive agreement that governs the exchange of health data across a diverse set of public and private entities.  This agreement – the Data Use and Reciprocal Support Agreement (“DURSA”) requires that:

• To the extent that each Participant has existing privacy and security obligations under applicable law (e.g. HIPAA or other state or federal privacy and security statutes and regulations), the Participant is required to continue complying with these obligations.  Participants, which are neither HIPAA covered entities, HIPAA business associates nor governmental agencies, are obligated to comply with specified HIPAA Privacy and Security Rules as a contractual standard of performance.
• It is the responsibility of the responding Participant – the one disclosing the data – to make sure that it has met all legal requirements before disclosing the data, including, but not limited to, obtaining any consent or authorization that is required by law applicable to the responding Participant. This policy is essential for nationwide health information exchange given the number of different state laws, Federal statutes and local policies related to consent or authorization to exchange data for treatment purposes. To effectively enable the exchange of health information in a manner that protects the privacy, confidentiality and security of the data, the DURSA adopts the HIPAA Privacy and Security Rules as minimum requirements.
• Participants are required to promptly notify the NHIN Coordinating Committee and other impacted Participants of breaches which involve the unauthorized disclosure of data through the NHIN, take steps to mitigate the breach and implement corrective action plans to prevent such breaches from occurring in the future. Suspected breaches must be reported within one (1) hour of discovering information that leads the Participant to believe that a breach may have occurred.  As soon as reasonably practicable, but no later than twenty-four (24) hours, Participants must notify affected Participants and the NHIN Coordinating Committee This process is not intended to address any obligations for notifying consumers of breaches, but simply establishes an obligation for Participants to notify each other when breaches occur to facilitate an appropriate response.

(See Overview: Data Use and Reciprocal Support (DURSA) Provisions Overview, dated November 20, 2009)

HIE services typically includes:

• Patient identification and registry services within a directory structure;
• Consent management and enforcement of a user’s consent when collecting, storing, accessing, processing, and disclosing personal health information; and
• Information for the patient about the HIE at the point of care and a business process to obtain consent that will be used  for future exchange of data until changed by the individual.

The CONNECT framework is designed to offer similar services for the NHIN.  CONNECT is designed to implement privacy and security controls defined in the NHIN services, and when implemented and combined with the NHIN operating procedures and the DURSA, it allows organizations to participate in the “web of trust” that enables the secure exchange of interoperable health information among the participants of the NHIN.

Privacy and security laws do not directly cover NHIN in the sense NHIN is really a collaboration of many organizations who elect to participate in the network.  Several different types of entities participate in the NHIN. There are HIPAA “covered entities”, such as providers, there are the HIPAA-defined “business associates” of those covered entities, and there are non-covered entities which are not currently required to comply with HIPAA rules.

The NHIN is more like the Internet than a traditional health information system found within a hospital.  NHIN while not a covered entity, NHIN has a similar threat profile.  Similar to an HIE, the Data Use and Reciprocal Support Agreements (DURSA) permit network participants to contract the specific terms under which they will exchange information, including addressing privacy and security needs of each NHIE amongst themselves.  The responsibility for security, including compliance with state and federal laws, including HIPAA, rests with the member organizations or the network nodes a hospital, physician’s office, etc.  Examples of common DURSA contracts/agreements are listed in the table below.

The typical Connect implementation involves the use of a server based PKI and the NHIN NHIE service registry which define and secure the NHIN core backbone.  Connect services include-

• The messaging platform and authorization framework to implement security and privacy controls to address the known threats for Web services implementations of service-oriented-architectures;
• The audit log query service is designed to meet the requirements for HIPAA disclosure accounting;
• The consumer preferences profile allowomg consumers to express their preferences for whether or not to share their information on the NHIN and for more granular control over access to their private information. The CONNECT policy engine enforces those preferences in the runtime environment to insure that the access policies of the organization and the preferences of the consumer are honored in the decision to release health information in response to a request from the NHIN

In a separate draft publication ONC has detailed use cases on how to obtain, modify, and detail a patient’s consent to access his/her medical record.

If this all seems to daunting, a less ambitious project was recently announced by ONC called NHIN Direct.  The NHIN Direct project is focused on smaller providers who are unable to implement the Connect solution, and/or put in place an appropriate DURSA.  According to ONC- “NHIN Direct is intended to solve simple direct secure electronic transport supporting health information exchange currently being handled via paper or portal communication following existing trust models.”

Transactions that would fall within the scope of NHIN Direct would be those transactions involving the communication of pre-existing information typically transferred via fax, courier, mail or clipboard, or in some cases, via a patient/physician portal.  The transactions must be “push transactions” where patient identity is known and consent and legal authorization exists for the information transfer. (See http://nhindirect.org/User+Stories).[iii]

Additional Information – Data Sharing Agreements

Sample DURSA Business Associate Addendum

Sample Health Information Exchange Agreement

AMENDED AND RESTATED CLINICAL OUTCOMES ASSESSMENT PROGRAM HEALTH CARE PROVIDER INFORMATION SHARING AGREEMENT

ONC NHIN Draft Policies

2010 NHIN Final Production Specifications
The following specifications have been provisionally approved by the NHIN Technical Committee. This approval is subject to the validation of the NHIN reference implementation.

• Access Consent Policies Production Specification – v1.0 [PDF - 176 KB]
  
• Authorization Framework Production Specification v2.0 [PDF - 256 KB]
  
• Query for Documents Production Specification v2.0 [PDF - 212 KB]
  
• Retrieve Documents Production Specification v2.0 [PDF - 178 KB]
  
• Health Information Event Messaging Production Specification v2.0 [PDF - 152 KB]
  
• Messaging Platform Production Specification v2.0 [PDF - 248 KB]
  
• Patient Discovery Production Specification v1.0 [PDF - 214 KB]
  
• Web Services Registry Production Specification v2.0 [PDF - 378 KB]
  

Additional Information Available at the Following Sites:

• American Health Information Community (AHIC) http://www.hhs.gov/healthit/ahic.html
• American Health Information Management Association (AHIMA) http://www.ahima.org/
• Certification Commission for Healthcare Information Technology (CCHIT) http://www.cchit.org
• Commission on Systemic Interoperability http://endingthedocumentgame.gov
• Healthcare Information and Management Systems Society (HIMSS) http://himss.org/ASP/index.asp
• HL7 United States http://www.hl7.org/
• International Health Terminology Standards Development Organization (IHTSDO) and SNOMED International http://www.ihtsdo.org/
• Office of the National Coordinator of Health Information Technology (ONCHIT) http://www.hhs.gov/healthit/

[ii] CONNECT has three primary components:

1. The Core Services Gateway implements the core NHIN services enabling such functions as locating patients at other health organizations within the NHIN, requesting and receiving documents associated with the patient, and recording these transactions for subsequent auditing by patients and others. Other features include authenticating network participants, formulating and evaluating authorizations for the release of medical information, and honoring consumer preferences for sharing their information.
2. The Enterprise Service Component (ESC) provides default implementations of many critical enterprise components required to support electronic health information exchange, including a Master Patient Index (MPI), Document Registry and Repository, Authorization Policy Engine, Consumer Preferences Manager, HIPAA-compliant Audit Log.
3. The Universal Client Framework contains a set of applications that can be adapted to create an edge system, and be used as a reference system, and/or can be used as a test and demonstration system for the gateway solution.

[iii] The project has highlighted the following use cases for the NHIN project:
1. Primary care provider refers patient to specialist including summary care record
2. Primary care provider refers patient to hospital including summary care record
3. Specialist sends summary care information back to referring provider
4. Hospital sends discharge information to referring provider
5. Laboratory sends lab results to ordering provider
6. Providers without a fully certified EHR send and receive data
7. Primary care provider sends patient immunization data to public health
8. Pharmacist sends medication therapy management consult to primary care provider
9. Provider sends patient health information to the patient
10. Provider sends a clinical summary of an office visit to the patient
11. Hospital sends a clinical summary at discharge to the patient
12. Provider or hospital reports quality measures to CMS
13. Provider or hospital reports quality measures to State
14. Laboratory reports test results for some specific conditions to public health
15. State public health agency reports public health data to Centers for Disease Control
16. Provider reports to the State
17. Hospitals reporting to the State

Related Blogs

• Great Visualizers: Stefanie Posavec | Information Is Beautiful
• The anatomy of HIPAA.: An article from: Arkansas Business
• ‘This is a patient’s bill of rights on steroids’ | RedState
• Patient input in their treatment should be valued by doctors | KevinMD.com

          

HIE and NHIN Implementation Issues: (a) Data Sharing Agreements, (b) the Master Patient Index, (c) Data Standardization, (d) Consent Requirements, and (e) Duties of Network Participants originally appeared on Law Blog 2.0 on March 25, 2010.

HHS

On March 15, 2010, ONC completed the announcement of State Health Information (State HIE) Exchange Cooperative Agreement Program awardees.  The first announcement of awards were on February 12th, 2010.   These awards are meant as seed money for State HIE’s which are expected to reach financial independent within 2 to 4 years.  The Awardees will be evaluated on various criteria over a four year period.  The criteria are detailed in http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_888442_0_0_18/FOA_State%20Health%20Information%20Exchange%20Cooperative%20Agreement%20Program_Sept3_updated%20funding%20formula.doc.  A PDF of this same document is available here: FOA_State Health Information Exchange Cooperative Agreement Program_Sept3_updated funding formula.  Generally, HIEs are intended to transmit healthcare information electronically across organizations within a region, community or hospital system.  HIE generally allow for the movement of clinical information among disparate health systems.  Various gateways and interface utilities are used to translate data from disparate information systems.

The parameters of the program include:

• The Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as part of the American Recovery and Reinvestment Act of 2009 (ARRA), amends Title XXX of the Public Health Service Act (PHSA) by adding Section 3013, State Grants to Promote Health Information Technology. Section 3013 establishes the State Health Information Exchange Cooperative Agreement Program;
• The State Health Information Exchange (State HIE) Cooperative Agreement Program awards cooperative agreements to states, eligible territories, and qualified State Designated Entities (SDEs) to develop and advance mechanisms for information sharing across the health care system, including establishing health information exchange (HIE) capacity among health care providers and hospitals in their jurisdiction, ultimately enabling exchange across states;
• The funding instrument that the State HIE Program has chosen to use in administering the awards is a cooperative agreement.  A cooperative agreement is a partnership between the grant recipient and the Federal government, when the Federal government has a substantial stake in the outcomes or operations of the program.  The State HIE cooperative agreements have a four-year performance period and recipients will be required to match a portion of grant awards beginning in the second year of the award, 2011; and
• Under this program, $548 million has been awarded to support efforts to facilitate and expand the secure, electronic movement and use of health information among organizations according to nationally recognized standards. The governance, policy and technical infrastructure supported through this program will enable standards-based HIE and a high performance health care system.  HIE is fundamental to realizing the promise of meaningful use of EHRs and HIT that leads to improved quality, efficiency and safety of health care.

(See HealthIT.hhs.gov)

States must also:

• Develop and implement up-to-date privacy and security requirements for HIE with and across state borders;
• Develop state-level directories and technical services to enable interoperability within and across States;
• Coordinate with Medicaid and state public health programs to enable information exchange and support monitoring of provider participation in HIE;
• Remove barriers that may hinder effective HIE, particularly those related to interoperability across laboratories, hospitals, clinician offices, health plans and other health information exchange partners;
• Ensure an effective model for HIE governance and accountability is in place; and
• Convene health care stakeholders to build trust in and support for a statewide approach to HIE.

The State HIE Cooperative Agreement Program funds states’ efforts to rapidly build capacity for exchanging health information across the health care system both within and across states. Awardees are responsible for increasing connectivity and enabling patient-centric information flow to improve the quality and efficiency of care. Key to this is the continual evolution and advancement of necessary governance, policies, technical services, business operations, and financing mechanisms for HIE over each state, territory, and SDE’s four-year performance period.

Grantees in the second round of awards (announced March 15, 2010):

• State of Alaska
• Department of Public Health, State of CT
• Agency of Health Care Administration (FL)
• Iowa Department of Public Health
• Idaho Health Data Exchange
• Indiana Health Information Technology, Inc.
• Louisiana Health Care Quality Forum
• The Maryland Department of Health and Mental Hygiene
• State of Mississippi
• HealthShare Montana
• State of North Dakota, Information Technology Department
• Nebraska Department of Administrative Services
• New Jersey Health Care Facilities Financing Authority
• South Carolina Department of Health & Human Services
• South Dakota Department of Health
• Texas Health and Human Services Commission

Grantees in the first round of awards (announced February 12, 2010):

• Rhode Island Quality Institute
• State of Oregon
• Georgia Department of Community Health
• Kansas Health Information Exchange Project
• Cabinet for Health and Family Services (KY)
• Missouri Depart of Social Services
• Colorado Regional Health Information Organization
• Health Care Authority (Washington)
• Governor’s Office of Health Care Reform Commonwealth of PA
• Virginia Department of Health
• State of Maine/Governor’s Office of Health Policy & Finance
• The Hawaii Health Information Exchange
• Wisconsin Department of Health and Family Services
• Government of the District of Columbia
• Minnesota Department of Health
• Virgin Islands Department of Health
• Oticina del Gobernador La Fortaeza (PR)
• Illinois Department of Healthcare and Family Services
• New Hampshire Department of Health and Human Services
• Alabama Medicaid Agency
• California Health and Human Services Agency
• Utah Department of Health
• Vermont Department of Human Services
• Massachusetts Technology Park Corporation
• Lovelace Clinic Foundation (New Mexico)
• State of Tennessee
• North Carolina Department of State Treasurer
• West Virginia Department of Health and Human Resources
• Arkansas Dept of Finance and Administration
• Delaware Health Information Network
• Michigan Department of Health
• New York eHealth Collaborative, Inc.
• Oklahoma Health Care Authority
• Pacific Ecommerce Development Corporation (American Samoa)
• Ohio Health Information Partnership, LLC
• Arizona Governor’s Office of Economic Recovery
• Nevada Department of Health and Human Services
• Office of the Governor (Guam)
• Commonwealth of the NMI, Department of Public Health
• Office of the Governor (WY)

(see http://healthit.hhs.gov/portal/server.pt?open=512&objID=1488&parentname=CommunityPage&parentid=2&mode=2&in_hi_userid=10741&cached=true).

Related Blogs

          

ONC 2nd Annoucement for HIE Grants and a Review of Program Requirements originally appeared on Law Blog 2.0 on March 16, 2010.

HHS

On December 1st, 2009 the Office of the Secretary of the Office of the National Coordinator (ONC) for Health Information Technology announced the creation of a new Chief Privacy Office and the Office of Economic Modeling and Analysis (among three others including the Office of Chief Scientist, Deputy National Coordinator for Programs & Policy, and Deputy National Coordinator for Operations).  The New Chief Privacy Officer is a necessary creation under the ARRA (and the HITECH Act).  This role is different from the other positions that seem to be a re-organization of roles and responsibilities that already existed to some extent just with more specificity around functions and duties.  Aside from the Chief Privacy Officer the New Economic Modeling and Analysis Position seems like a timely creation given recent articles discussing whether Health Information Technology and more specifically Electronic Health Record Systems (EHRs) actually reduce the cost of care and/or increase the quality of care.  Also of note, the new Office of the Deputy National Coordinator for Programs and Policy will be responsible for the open source Connect initiative and the National Health Information Network.

 (see http://healthit.hhs.gov/portal/server.ptopen=512&objID=1200&&PageID=15520&mode=2&in_hi_userid=10741&cached=true)

Below is a diagram detailing the new offices relative to the National Coordinator.

The Notice in the Federal Register note that the reorganization affects all four of the original Director-level offices:

• The Office of Health Information Technology Adoption (OHITA);
• The  Office of Interoperability and Standards (OIS);
• Office of Programs and  Coordination (OPC); and
• The Office of Policy and Research (OPR).

Five offices will have direct reporting capability to the National Coordinator for Health Information Technology (National Coordinator):

1. The Office of Economic Modeling and  Analysis (ARB);
2. the Office of the Chief Scientist (ARC);
3. The Office of the Deputy National Coordinator for Programs & Policy (ARD);
4. The Office of the Deputy National Coordinator for Operations (ARE); and
5. The Office of the Chief Privacy Officer (ARF).

(see http://edocket.access.gpo.gov/2009/E9-28755.htm).

The Office of the Chief Privacy Officer will advise the National Coordinator.  Chief Privacy Officer of the Office of the National Coordinator for Health Information Technology will be appointed by the Secretary.  The Office of the Chief Privacy Officer duties include:

1. Advising the National Coordinator on privacy, security, and data stewardship of electronic health information; and
2. Coordinating the Office of the National Coordinator for Health Information Technology’s efforts with similar privacy officers in other Federal agencies, State and regional agencies, and foreign countries with regard to the privacy, security, and data stewardship of electronic, individually identifiable health information.

The Office of Economic Modeling and Analysis responsibilities include:

1. Applying advanced mathematical or quantitative modeling to the U.S. health care system for simulating the microeconomic and macroeconomic effects of investing in health information technology; and
2. Providing advanced policy analysis of health information technology strategies and policies to the National Coordinator.

The purpose this position will be to model varying public policy scenarios to perform advanced health care policy analysis for requirements of the Recovery Act, such as reductions in health care costs resulting from adoption and use of health information technology.  The results of these analyses provided to the National Coordinator will inform strategies to enhance the use of health information technology in improving the quality and efficiency of health care and improving public health.

The Office of the Chief Scientist will be responsible for:

1. Applying research methodologies to perform evaluation studies of health information technology grant programs;
2. Identifying, tracking and supporting innovations in health information technology;
3. Leading research activities mandated under the HITECH Act provisions of ARRA;
4. Promoting applications of health information technology that support basic and clinical research;
5. Collecting and communicating knowledge of health care informatics from and to international audiences;
6. Collaborating with other agencies and departments on assessments of new health information technology programs; and
7. Developing and maintaining educational programs for staff of the Office of the National Coordinator and advising the National Coordinator concerning the educational needs of the field of HIT.

The Office of the Chief Scientist possesses and utilizes specialized knowledge of medical bioinformatics, which involves the study and application of advanced information methods and technologies in support of health care and population health.

The Office of the Deputy National Coordinator for Programs and Policy assumes functions previously performed by the Office of Health Information Technology Adoption, the Office of Interoperability and Standards, the Office of Adoption Provider Support, the Office of State and Community Programs, and the Office of Policy and Planning.  The new office will lead ONC programs related to health information exchange, regional extension centers, training of the health IT workforce, and the development of technical standards for interoperability, security, and certification of health IT systems.  The new office comprises:

1. The Office of Standards and Interoperability, with responsibility for standards, security, certification, the Nationwide Health Information Network, Federal Health Architecture and the CONNECT program;
2. The Office of Provider Adoption Support, which administers the Regional Extension Centers program and health IT workforce development;
3. The Office of State and Community Programs, which administers the state-level health information exchange program and the Beacon Communities Program; and
4. The Office of Policy and Planning, which is realigned to include all policy development, including privacy and security policy, and is liaison with legal affairs and legislative affairs, regulations development  and externally focused strategic planning.

The Office of the Deputy National Coordinator for Operations is responsible for activities that are vital to supporting ONC’s numerous programs and enhancing ONC’s ability to communication about health IT.

          

Office of the National Coordinator — Time to Reorganize. originally appeared on Law Blog 2.0 on December 10, 2009.

ONC Grants Announced

The Office of the National Coordinator for Health Information Technology (ONC) has recently release more information on two grant programs.  The HITECH Act authorizes two grant programs: (1) a Health Information Technology Extension Program (Extension Program) and (2) the State Health Information Exchange Coopertive Agreement Program (Agreement Program).  This program provides grants for the establishment of Health Information Technology Regional Extension Centers that will offer technical assistance, guidance and information on best practices to support and accelerate health care providers’ efforts to become meaningful users of Electronic Health Records (EHRs). The consistent, nationwide adoption and use of secure EHRs will ultimately enhance the quality and value of health care.  The State Health Information Exchange Cooperative Agreement Program supports states and/or State Designated Entities (SDEs) in establishing health information exchange (HIE) capacity among health care providers and hospitals in their jurisdiction. Such efforts at the state level will establish and implement appropriate governance, policies and network services within the broader national framework to rapidly build capacity for connectivity between and among health care providers. State programs to promote HIE will help to realize the full potential of EHRs to improve the coordination, efficiency and quality of care.  For those interested ONC has made available a “grants primer” (avaliable at http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_877878_0_0_18/Grants_Primer_update.pdf).  The primer will help a state find and apply for grants.

Health Information Technology Extension Program- Regional Centers

Grants are available to Regional Centers that are affiliated with a U.S.-based, nonprofit institution or organization, or an entity thereof, that applies for and is awarded funding under the Extension Program.  “The program anticipates that potential applicants will represent various types of nonprofit organizations and institutions with established support and recognition within the local communities they propose to serve.”

Principally Regional Centers will support health care providers with direct, individualized and on-site technical assistance in:

• Selecting a certified EHR product that offers best value for the providers’ needs;
• Achieving effective implementation of a certified EHR product;
• Enhancing clinical and administrative workflows to optimally leverage an EHR system’s potential to improve quality and value of care, including patient experience as well as outcome of care; and,
• Observing and complying with applicable legal, regulatory, professional and ethical requirements to protect the integrity, privacy and security of patients’ health information.

The Grant Process

“The application review and funding process will be separated into three application cycles, the dates of which are outlined in the table below.  Applicants will be required to submit a preliminary application that will undergo an objective review; successful preliminary applicants will be requested to submit a full application for merit review.  Successful full applications will result in award of four-year cooperative agreements.  Initial award decisions for Regional Centers are anticipated to be made in the first quarter of FY2010.  Additional awards are expected to be made as a result of two subsequent application cycles to be completed in FY2010.”

State Grants to Promote Health Information Technology Planning and Implementation Projects

“The State Cooperative Agreements to Promote Health Information Technology: Planning and Implementation Projects are to advance appropriate and secure health information exchange (HIE) across the health care system. Awards will be made in the form of cooperative agreements to states or qualified State Designated Entities (SDEs). The purpose of this program is to continuously improve and expand HIE services over time to reach all health care providers in an effort to improve the quality and efficiency of health care. Cooperative agreement recipients will evolve and advance the necessary governance, policies, technical services, business operations and financing mechanisms for HIE over a four year performance period. This program will build off of existing efforts to advance regional and state level HIE while moving towards nationwide interoperability.”

Participating states will also be expected to use their authority and resources to:

• Develop and implement up-to-date privacy and security requirements for HIE;Develop directories and technical services to enable interoperability within and across states;
• Coordinate with Medicaid and state public health programs to enable information exchange and support monitoring of provider participation in HIE.
• Remove barriers that may hinder effective HIE, particularly those related to interoperability across laboratories, hospitals, clinician offices, health plans and other health information exchange partners;
• Ensure an effective model for HIE governance and accountability is in place; and
• Convene health care stakeholders to build trust in and support for a statewide approach to HIE.

“Total funding for this initiative is $564,000,000. States (including territories) or their non-profit SDEs may apply, as designated by the state. No more than one award will be made per state. States may choose in enter into multi-state arrangements.”

See http://healthit.hhs.gov/portal/server.pt?open=512&objID=1331&parentname=CommunityPage&parentid=47&mode=2&in_hi_userid=11113&cached=true# for more information.

See also http://healthit.hhs.gov/portal/server.pt?open=512&objID=1333&parentname=CommunityPage&parentid=47&mode=2&in_hi_userid=11113&cached=true#

          

HITECH Grant Opportunities for Regional HIT Centers and HIE Cooperatives originally appeared on Law Blog 2.0 on August 24, 2009.