Overview
An electronic health network (EHN) or medical care electronic claims clearinghouses (also referred to as a clearinghouse or network) exchanges electronic health care transactions between payors and providers. EHN services include verifying the accuracy of claims submitted, reporting on errors identified during the data cleaning process, and formatting transactions to align with national standards established under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).1 Two key benefits of using EHNs are increased efficiency in operations and reduced administrative costs.2
EHN Certification and Recertification
COMAR 10.25.07, Certification of Electronic Health Networks and Medical Care Electronic Claims Clearinghouses, requires government and private payors that accept electronic health care transactions originating in Maryland to accept transactions only from MHCC certified EHNs. To receive MHCC certification or recertification, a network must be accredited or certified by a nationally recognized organization where standards related to privacy and confidentiality, business practices, physical and human resources, technical performance, and security are evaluated.3 For information on how to certify, recertify, and a list of certified EHNs, click here.
State Regulations
Stakeholder Working Sessions: Informal Draft Amendments to COMAR 10.25.07,
Certification of Electronic Health Networks and Medical Care Electronic Claims
Clearinghouses
In July 2024, the MHCC convened a stakeholder working session to discuss informal draft regulations to support the implementation of electronic health network reporting of certain electronic health care transactions as required by Chapter 790/791 (2021). Information on the working session follows.
- Electronic health network reporting of certain electronic health care transactions: July 30th - Attendees; Recording; Slides
Contact Nicole Majewski (nicole.majewski@marylnd.gov) with questions.
Legally Protected Health Information
During the 2023 legislative session, the Maryland General Assembly passed Chapter 249 (House Bill 812), Health – Reproductive Health Services – Protected Information and Insurance Requirements (law). The law prohibits the disclosure of legally protected health information by health information exchanges (HIEs) and EHNs operating in the State. Legally protected health information includes mifepristone data, the diagnosis, procedure, medication, and related codes for abortion care, and other sensitive health services with a date of service after May 31, 2022, as determined by the Secretary of Health.
The MHCC convenes virtual Town Halls to support implementation of the law. The events provide a forum to share implementation progress and ask questions.
The MHCC has prepared implementation guidance based on stakeholder's questions. The documents that follow serve as a resource for EHNs and HIEs in the management, disclosure, and protection of legally protected health information.
Implementation Guidance: Health Information Exchanges (May 2024)
Implementation Guidance: Electronic Health Networks (May 2024)
Reporting on Implementaton
In January 2024, HIEs and EHNs submitted an affirmation of compliance or an implementation plan. Entities that submitted implementation plans were required to submit a status report by April 1, 2024 detailing progress made under its implementation plan. In an effort to promote transparency on implementation efforts, vendors April 2024 status reports can be viewed here. Please note, vendor implementation strategies are fluid and timelines are subject to change.
Given EHNs and HIEs need for additional time to implement requirements for legally protected health information, MHCC is requesting entities provide ongoing implementation updates. The MHCC has prepared the following guidance on the scope of what should be included in the implementation updates.
Implementation Update Guidance (August 2024)
Workgroup
Chapters 790 (House Bill 1022) and Chapter 791 (Senate Bill 748) of the 2021 Laws of Maryland, Public Health - State Designated Exchange - Clinical Information, require EHNs operating in Maryland to provide electronic health care transactions to the State-Designated health information exchange (CRISP) for public health and clinical purposes, including a State health improvement program, mitigation of public health emergency, and improvement of patient safety.4 The MHCC is required to report to the Governor and General Assembly by January 1, 2022 on the availability of funding and the sustainability of the technical infrastructure required to implement the provisions in the law.
The MHCC convened an EHN Workgroup consisting of representatives from CRISP and EHNs that transmit majority of transactions in the State to inform an iterative implementation strategy for the exchange of data required by the law. Through workgroup deliberations, MHCC aims to establish a draft framework for data sharing that addresses data privacy and security.
September 13, 2021: Agenda, Summary, and Recording
January 25, 2022: Agenda, Summary, Cooperative Exchange Association Considerations, and Recording
March 4, 2022: Agenda, Summary, and Recording
Resources
Electronic Health Networks Overview Flyer (2023)
This informational flyer provides an overview about the role of EHNs and those certified by MHCC.
Briefing Paper: Public Health – State Designated Exchange – Clinical Information (2021)
A legislative update on funding availability and sustainability to support the requirements of Chapters 790 and 791 of the 2021 laws of Maryland.
Electronic Healthcare Network Accreditation Commission (EHNAC)
Information on accreditation programs that ensure the privacy and security of protected health information.
Health Information Trust Alliance (HITRUST)
Provides common risk and compliance management frameworks, related assessment, and assurance methodologies to support an organization’s information risk management and compliance objectives.
1. HIPAA applies generally to health plans, health care clearinghouses, and health care providers who transmit any health information in electronic form, and provides rules designed to ensure the privacy and security of individually identifiable health information or protected health information (PHI), including such information transmitted or maintained electronically (electronic PHI).
2. Nearterm, What is a Healthcare Clearinghouse & Why Use One? Available at: nearterm.com/what-is-a-healthcare-clearinghouse-medical-billing-electronic-claims/.
3. National accreditation/certification organizations currently recognized by MHCC include: The Electronic Healthcare Network Accreditation Commission (EHNAC) and The Health Information Trust Alliance (HITRUST)
4. Other provisions in the law require nursing homes to submit electronic clinical information to the State-Designated Health Information Exchange.