Most Recent Updates:
CTAMFT Advocacy Chair, Jaime Rodriguez, and committee members continue to work to represent MFTs in the questions, concerns, and clarification of all things CONNIE.
What has been done?
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CTAMFT Advocacy Chair has participated in multiple meetings per month since early 2023 with CONNIE staff, OHS (Office of Health Strategy), fellow mental health state association representatives and stakeholders regarding the statutes, laws, mandates, concerns and questions regarding CONNIE.
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CTAMFT Advocacy Chair is engaged with (BHIC) an interprofessional behavioral health coalition to bring unity and consensus to the representation of mental health providers participating in CONNIE.
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CTAMFT’s lobbyist is engaged with a group of medical and mental health lobbyists seeking legislative clarification and changes that better suit mental health privacy laws and best practices.
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CTAMFT Advocacy Chair has been nominated to a seat on the HITAC (Health Information Technology Advisory Council) in order to represent MFTs license specific requirements and development of CONNIE policy, procedures and regulations by OHS.
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As always we are keeping all MFTs aware of the legal mandates, requirements and changes in regards to CONNIE participation.
What is coming up?
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CTAMFT hopes to be appointed to HITAC in order to officially participate in the development of CONNIE policies, procedures and regulations in a manner in which MFTs, and the clients we serve, are protected and served in the most effective way.
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CTAMFT will continue to work with the BHIC, other mental health coalitions and state associations in order to provide representation and recommendations of our field of expertise.
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CTAMFT Lobbyist will continue to cooperate in the examination and adjustment of state statutes around CONNIE.
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CTAMFT will monitor and comment on any and all proposed policies, procedures and regulations developed by OHS in regards to CONNIE.
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CTAMFT will continue to keep you updated about any and all legal obligations of MFTs in Connecticut in regards to CONNIE compliance.
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Facilitate awareness and information about CONNIE, it’s mandates and recommendations to all Mental Health providers and clients in Connecticut.
What do I need to do?
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At this point, there are no further legal obligations other than completing the “commit the connect” form on the CONNIE website. This mandate does NOT require any provider to sign the contract or begin on boarding process at this time. Simply completing the one “commit to connect” form is the only step all MFTs or mental health providers who are currently treating clients in Connecticut, or are located in Connecticut while treating clients out of state, are required to do.
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Stay up to date with CTAMFT’s social media, this CTAMFT CONNIE page, and Advocacy Chair, Jaime Rodriguez, at advocacy@ctamft.org for further legal statutes, mandates, recommendations, upcoming calls to action and changes.
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Please support CTAMFT’s Advocacy Committee by sharing this information with fellow MFTs and non MFT mental health providers.
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Also remember, your membership dues go a long way to support the work of CTAMFT’s Advocacy Committee Chair and committee members volunteer work on CONNIE and other important MFT advocacy initiatives, so please become or renew your CTAMFT membership and encourage other MFTs to be a member of CTAMFT.
What do MFTs need to know?
Connecticut law (CGS §17b-59e) requires that, by May 3, 2023:
(1) each health care provider with an electronic health record system capable of connecting to, and participating in, [Connie] shall apply to begin the process of connecting to, and participating in [Connie]
and
(2) each health care provider without an electronic health record system capable of connecting to, and participating in [Connie] shall be capable of sending and receiving secure messages.
For additional information regarding CONNIE, please visit the CONNIE website: https://conniect.org
For an ongoing updated blog, by privacy and healthcare attorney Dena Castricone:
https://dmclawllc.com/2022/12/14/connie-cts-health-information-exchange-and-providers-obligations-to-participate/
FAQs
What does it mean to be compliant with the law?
To remain compliant with the law, all licensed providers must, on or before May 3rd, 2023, begin the connection process with CONNIE. This can be done by completing the CONNIE connection form here. We are recommending a conservative approach to this effort as the mental health professions work together to address ongoing concerns. After completing the registration form you will be contacted by Connie to begin the process of connecting and uploading client information. DO NOT GO BEYOND REGISTRATION REGARDLESS OF HOW OFTEN YOU ARE ASKED TO SHARE INFORMATION.
I haven't heard anything about CONNIE, nor have I been contacted by CONNIE. Does this mean I am exempt?
CONNIE has indicated they have reached out to providers about connecting. CTAMFT is aware many providers are reporting they have yet to hear about or be contacted by CONNIE. Regardless of whether or not you are contacted by CONNIE, as a licensed provider you are required to know and follow the law. This means you will need to comply with the law mandate to start the process of connecting by May 3rd, 2023.
What does the process look like?
The process has several steps and requires providers sign legal documents. CTAMFT recommends careful consideration before signing these documents, as many are legal documents. We recommend you consult with legal counsel should you have concerns or need additional support determining best steps for you and your practice.
How do I know if my EHR is compatible? (and what to do if it is not)
Many of the common EHR systems of therapists (Simple Practice, Therapy Notes, etc.) are not listed under Connie's compatible/connected systems. To see the list, click here.
At this time, OHS/CONNIE is requesting for providers to contact their EHR systems to request they make appropriate changes to connect with the system. Our understanding is that this is a request, but not a requirement for your EHR system to be compatible by the May 3rd deadline.
For those who's EHR remains incompatible/unable to connect with CONNIE, it is our understanding you will be treated as a provider "without an electronic health record system capable of connecting to, and participating in CONNIE". This does not mean you are exempt from complying with the mandate.
Any provider in this category must have (or implement) the capability to send and receive secure messages. These providers will need to set up a direct email address through CONNIE to meet the connection requirements and to communicate information with other providers. Providers without an EHR will NOT be required to transmit records to CONNIE.
What does this mean for my records?I'm worried about client confidentiality/HIPAA.
We are too! Which is exactly why CTAMFT has been participating in meetings with OHS and other interdisciplinary workgroups to help identify and address concerns. Currently CTAMFT has participated in a joint effort to request a delay in the implementation for mental health providers until these concerns are addressed and questions are answered. Until we hear otherwise, we must assume the May 3rd, 2023 date is the date in which one needs to be in compliance.
How are MFT records protected?
CTAMFT recommends taking a conservative approach to sharing any information in CONNIE. Current Marriage and Family Therapy statutes, it is a violation to share client communications and records without written client consent. Additionally, where more than one person in a family is receiving therapy, this consent should be obtained from each family member. There are exceptions to the statute however Connie does not fall under these exceptions. You can find this statute here: https://www.cga.ct.gov/current/pub/chap_899.htm#sec_52-146p
What happens if I don't comply?
CTAMFT is unsure of the consequences from non-compliance. However, OHS has indicated this may be tied to licensure. This means, for providers who have not complied with the mandate, they may experience difficulty or an inability to renew their license. Again, there have been no clear answers to what happens if you do not comply.
What should I tell my clients?
This should be an individual practitioner/practice and client decision. What we do know is clients/patients either opt fully in or fully out of CONNIE. This means, clients cannot choose what information is shared amongst providers. Either all providers in the CONNIE system can exchange information on a patient or none of that patients information is shared in CONNIE. Clients will need to make a decision that is best for them; however you/your practice cannot make the decision to not participate to the extent in which you qualify.