The following is a guest article by Deborah Hsieh, Chief Policy & Strategy Officer at Ciox.
Focus on interoperability for health data systems has increased recently given multiple proposed Department of Health and Human Services’ regulations addressing how health data is shared. Healthcare providers are a primary source of health data and should be aware of how to prepare for these new regulations. While each hospital has its unique approach to managing its health data and sharing of that information, there are actions all hospitals can take to prepare for heightened expectations for health data interoperability.
1. Connect business and policy conversations in the hospital
When you think of policy conversations, you might expect most of the activity to happen in the Government Affairs office. However, new regulations will have long-lasting and far-reaching business consequences. There is a need for business administrators affected by the regulations to also be informed. Ask for an update on the discussions that are occurring at the state and national level. Consider what the consequences could be for you. Understand how information about regulations is being disseminated throughout the organization. For example, are there impacted departments that are not included? Help advise your Government Affairs team so that they can represent the potential impact of regulations comprehensively in external discussions.
2. Plan jointly with IT and Health Information Management to be prepared for any changes
Release of health information (data) is a complex task that is dependent on how health record systems are designed and implemented. However, there is often limited proactive or collaborative planning between IT and HIM departments. The proposed regulations promote a new data exchange standard, Health Level 7 (HL7) Fast Healthcare Interoperability Resources (FHIR), as well as other elements of certification for electronic health record systems. Forward-thinking health systems will recognize the interdependent relationship between HIM and IT and proactively plan for how systems may change and how that may affect user processes.
3. Map existing sources of patient data and revisit document retention policy
According to HIMSS Analytics, the average hospital has 16 different electronic health record (EHR) systems, not to mention other health data repositories like separate databases for images, paper records in offices, paper records in storage and even microfiche records. As the health data sharing process is more highly scrutinized, make sure you know where your health data records are stored and develop a process for how to access and release the data in a timely manner.
Given that health information is stored in multiple departments governed by different processes and policies (e.g., business office, radiology, HIM), there should be a centralized perspective as well as consistent guidelines and escalation procedures. This will give patients a standard and reliable experience across the facility and/or full health system. You may also consider whether your facility’s document retention policy is due for a review. Many facilities have updated their policies, subject to state laws, to more accurately reflect what health data is most relevant for improving quality of care and having an impact on healthcare costs.
4. Ensure compliance has processes in place to account for both state and federal regulations
In-depth knowledge of compliance requirements is critical for health information management, especially given the combination of federal and state regulations. This complexity may increase with proposed regulation as federal regulations become more complex, and hospitals may need more extensive documentation throughout the release of information process. Compliance departments will be well- served to ensure they are prepared to advise frontline workers and potentially put new procedures in place to confirm federal and state compliance. This may also include incorporating regulatory preparations in your technology and service vendor evaluation process, reviewing contracts to ensure appropriate language is in place to address changing compliance needs, or establishing an ongoing dialogue with your vendors to ensure their plans are aligned with changing regulations.
Traditionally, health data has been considered particularly sensitive and there has been careful language in regulations like HIPAA to protect its limited and wise release. As regulators envision an ecosystem with unfettered access to health data, hospitals will need to consider how they are fulfilling their responsibilities to protect patient data while also releasing it. There may also be a need to educate patients, so patients are aware their health data is no longer protected once it’s released to third parties who are not covered entities and understand the accompanying ramifications of that lack of protection.
Hospitals who act now and are proactive about planning for interoperability will benefit not only from being better able to comply with the proposed regulations once they are finalized, but also from being able to better address patient needs in a changing environment for healthcare data privacy. There are ample opportunities for hospitals to be more engaged in policy discussions, particularly given the high impact regulations can have for workflows and processes, and the critical role hospitals play in helping protect the privacy of patient data.
The move to interoperability and broad sharing of health data is inevitable as both the administration and patients themselves are demanding easier access to their medical information. It is important that hospitals identify forward-thinking vendors, associations and other networking organizations to partner with, to ensure their voices are heard and patient rights are protected. Taking these steps is critical even if the proposed rules aren’t implemented – to enable data sharing for research, development of treatments and other applications and, ultimately, to improve quality of care for patients.
Ciox, a health technology company and proud sponsor of Healthcare IT Today, is dedicated to significantly improving U.S. health outcomes by transforming clinical data into actionable insights. Combined with an unmatched network offering ubiquitous access to healthcare data, Ciox’s expertise, relationships, technology and scale allow for the extraction of insights from structured and unstructured clinical data to create value for healthcare stakeholders. Through its HealthSource technology platform, which includes solutions for data acquisition, release of information, clinical coding, data abstraction, and analytics, Ciox helps clients securely and consistently solve the last mile challenges in clinical interoperability. Ciox improves data management and sharing by modernizing workflows and increasing the accuracy and flow of information, while providing transparency across the healthcare ecosystem and helping clients manage disparate medical records. Learn more at www.ciox.com.