Compliance
Meaningful Use Certification
This EHR Module is 2011/2012 compliant and has received Modular Ambulatory certification by an ONC-ATCB in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. Certificate # 11172011-1298-6. This certification does not represent an endorsement by the US Department of Health and Human Services or guarantee the receipt of incentive payments.

HIPAA Information for our Clients
Foothold understands that our customers may be confused and experiencing some difficulty in determining whether and to what degree they are HIPAA compliant. To that end, we offer the following basic information regarding patient privacy and consent. Below you will find a list of explanations of various parts of HIPAA followed by sample forms that can be used at your agency. These explanations and sample forms come to us from a well-respected organization in Wisconsin. The information may be freely distributed in its entirety provided that the copyright notice on each form is not removed. This information may not be sold for profit or used in commercial documents without the written permission of the copyright holder. This information is provided “as is” without any express or implied warranty. This information is for educational purposes only and does not constitute legal advice. If you require legal advice, you should consult with an attorney. This information may need to be modified in order to comply with local law. The forms and explanations are left in Microsoft Word format for easy downloading.

Click here for a sample agreement that should be signed by and between the provider and any and all Business Associates as defined by HIPAA.
Click here for a sample HITECH addendum to your HIPAA business associates agreement.
Here are a few links with valuable information on HIPAA and compliance.
HIPAA information about AWARDS
Among other things, the new HIPAA regulations are designed to protect the security and privacy of agencies and the consumers they serve. At Foothold Technology, security is our top priority. Using Secure-Socket Layer (SSL) and 128-bit encryption technologies, Foothold Technology's security is second to none. We utilize several layers of encryption to protect data from both external sources and internal accessibility. Below are a number of our specific security measures which should address any concerns you may have.
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AWARDS safeguards the confidentiality of chart records.
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All system users must authenticate themselves using a login and encrypted password. Passwords must meet minimum standards such as not using words found in a dictionary.
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Your agency has its own separate database and database server process with login accounts for your agency's staff only.
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The database server is protected by a "firewall" that by default blocks all access except the secure sockets layer connection to the web server process running for your agency alone.
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All data transmitted to and from the database server uses 128-bit encryption, the highest legal limit that is also used by online banking.
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Physical access to the servers is under lock and key. Backup media can be transported offsite by messenger and stored at a secure site under lock and key.
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No access to chart records is permitted unless the user is direct care staff in that clinical program as determined by caseload information or the user is a supervisor in that program or that program's director has granted a specific permit to the user.
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Access to progress notes is restricted to the past 10 days unless the consumer is on the caseload of the user or the user is the program director or the program director has issued a specific permit to the user. All exception permits have expiration dates set at the time the permit is issued.
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AWARDS keeps an audit trail each time a progress note is viewed.
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AWARDS blocks all access to notes concerning incidents except by the note writer and users who have a permit to access these notes.
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Whenever an exception permit is issued to grant access to chart records, all administration staff with permits to issue such permits are automatically notified by an internal email message.
Health Information Technology for Economic and Clinical Health Act (HiTECH) and Meaningful Use
Including Behavioral Health Organizations
The American Recovery and Reinvestment Act of 2009 (Stimulus Bill) included a subsection called HiTECH which provides funds to incentivize hospitals and doctors to purchase and implement an electronic health record (EHR). To determine whether a doctor or hospital has implemented such a system, and is thus qualified to receive the incentive, the government created a concept called Meaningful Use. Not included in the Recovery Act were behavioral health providers, including alcohol and substance abuse and mental health services as well as other non-physical healthcare providers. To rectify this omission, Congress introduced two bills (HR 5040 and S3709) aimed at specifically making these providers eligible for Medicaid incentives.
Be Prepared
Most experts believe that these two bills will pass, thus making funds available to behavioral healthcare agencies that meet the Meaningful Use criteria and adopt a certified electronic health record. The Federal government has issued standards to assess which organizations qualify as meaningful users as well as which vendors provide the necessary functionality. Both requirements must be met for an agency to qualify.
EHR Software Certification
The Federal Department of Health and Human Services is currently taking applications from standards and certification organizations that can administer the EHR certification test. Presently, three companies are authorized to conduct certifications, with more to follow. The substance of the certification process is very closely related to the Meaningful Use definitions. As agencies prepare to become meaningful users, Foothold Technology is making the necessary updates to our software to become a certified vendor.
What is Foothold doing?
Foothold’s application development team is putting everything in place to code, test and deploy the functionality required to get certified and keep our community of agencies in compliance.
Additional HiTECH and Meaningful Use Information:
Electronic Health Records and Meaningful Use
Standards and Certification
New York State Office of Mental Health - PROS
Personalized Recovery Oriented Services (PROS) is a comprehensive recovery oriented program for individuals with severe and persistent mental illness. The goal of the program is to integrate treatment, support, and rehabilitation in a manner that facilitates the individual's recovery. Goals for individuals in the program are to: improve functioning, reduce inpatient utilization, reduce emergency services, reduce contact with the criminal justice system, increase employment, attain higher levels of education, and secure preferred housing.1
AWARDS has tools that make PROS reporting and billing easier, including:
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End-to-end screening and tracking of individuals receiving services in any of the PROS Components including CRS, IR, ORS and optional Clinical Treatment
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One-click availability of the automated PROS Monthly Summary Record of Services (PROS Units Calculator)
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Intensive case tracking including Individualized Recovery Plans, PROS Progress Notes and Groups, Onsite/Offsite Program Attendance Tracking
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Standardization of agency data collection and charting procedures
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More staff accountability through reporting, audit trails and reminders
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Easier access to your data, accessible from any location at the agency
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Easier audits using AWARDS' robust reporting functionality
1"PROS Description". New York Office of Mental Health. http://www.omh.ny.gov/omhweb/pros/
New York State Office of Mental Health - APGs
In 2010, the New York State Department of Health (SDOH) announced that the federal Centers for Medicare and Medicaid Services (CMS) approved the State Plan Amendment authorizing the Ambulatory Patient Group Payment (APG) Medicaid payment methodology for freestanding Diagnostic and Treatment Centers and Ambulatory Surgery Centers on June 14, 2010. Foothold Technology is prepared to handle the transition to new service categories, codes, and billing rules.
Click here to learn more about APGs and AWARDS.
HL7 - Health Level Seven Interational

"Level Seven" refers to the seventh level of the International Organization for Standardization (ISO) seven-layer communications model for Open Systems Interconnection (OSI) - the application level. The application level interfaces directly to and performs common application services for the application processes. Although other protocols have largely superseded it, the OSI model remains valuable as a place to begin the study of network architecture.
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