VITL Welcomes Comments on Updates to Secondary Use Policy

April 11, 2024


VITL is considering updates to our Policy on Secondary Use of Protected Health Information on the VHIE by Health Plans and Accountable Care Organizations (“Secondary Use Policy”), and we would like to hear input from our participating health care organizations about the proposed changes. This current policy was last updated in 2021, and allows Payers and ACOs to use Vermont Health Information Exchange (VHIE) data for Treatment, Payment (excluding post-payment audits of services rendered), and Quality Review purposes. The proposed version, available on our policies page, includes a number of substantive changes:

  • Expands how Payers and ACOs can use VHIE data, specifically to allow additional Health Care Operations Quality Assessment and Improvement activities, including:
    • Outcomes evaluation and development of clinical guidelines (not research);
    • Patient safety activities;
    • Population-based activities relating to improving health or reducing health care costs;
    • Protocol development; and
    • Case management and care coordination.    

The draft policy includes a table (Appendix A) that outlines what will be allowed. Use of the VHIE data for Treatment and Payment activities will remain unchanged.

  • Specifies that the policy applies to data accessed on the VHIE, through our provider portal, as well as data provided from the VHIE, for example as a report, extract, or data feed.
  • Clarifies that data provided from the VHIE to be used by “authorized users” in addition to staff, such as use of the data by participating providers.
  • The updates also include some housekeeping and consistency items, that do not substantively change the intent of the policy. 

We have posted both a clean copy and a marked-up version of the new policy so you can easily identify the differences. If you have any questions or would like to provide feedback about the proposed policy, please reach out to us at Comments will be collected through May 8th, 2024, with the goal of VITL Board approval of the policy later in May.