By Rita Bowen, VP, Privacy, Compliance and HIM Policy, MRO
Twitter: @MROCorp
On September 1, 2018, the Journal of AHIMA published MRO’s article “Enterprise-Wide PHI Disclosure Management—Why Information Governance Matters,” featuring a virtual roundtable with health information management (HIM) leaders from MRO client organizations Ardent Health Services, Ochsner Health System and WellSpan Health.
As moderator of the discussion, I had an opportunity to explore valuable insights gained from their experiences along the journey to enterprise-wide Protected Health Information (PHI) disclosure management. Here is a summary of common challenges they faced and successful strategies guided by Information Governance (IG) principles.
Common Challenges
As integrated health systems grow through partnerships and acquisitions, one of the most significant challenges is managing multiple points of PHI disclosure during the Release of Information (ROI) process. Keeping up with evolving regulations requires evaluation of ROI requirements including ongoing review of policies and procedures with a goal of establishing standardized, compliant processes across the enterprise. This has become even more critical with the rise in small breaches, often due to errors in ROI.
With any major process change, some resistance can be expected. Not everyone will be on board to hand off ROI responsibilities. Reluctance to make the transition to enterprise-wide disclosure is often related to loss of control and personal touch, particularly in physician practices. Communicating the benefits to all departments and practices is critical to the success of a centralized, enterprise approach.
Six Successful Strategies—People, Processes and Technology
Overall, the combination of policies and procedures supporting legal medical record content, consistent record retention and standardized workflows enables the implementation of enterprise-wide PHI disclosure. Establishing compliant ROI practices aligned with IG concepts must be a top priority to reduce liabilities and protect patient information.
Here are six strategies for HIM professionals to initiate, support or sustain enterprise-wide PHI disclosure management:
- Engage executive leadership, including compliance, privacy and legal teams. Present a business case for enterprise-wide ROI, with emphasis on the benefits of centralization including cost savings, compliance and patient satisfaction.
- Proactively address PHI disclosure management in the acquisition and partnership strategy. Create a consistent approach to managing any ROI transition.
- Consider your available human, technical and system resources. Evaluate the ability to implement a model that is self-sufficient, outsourced or a combination of the two options.
- Create an enterprise-wide inventory of health records/designated record sets. Include the format, locations and retention timeframe.
- Determine the right balance of onsite versus remote management. Create a standard list of common documents requested by patients as a guide to onsite processing.
- Establish a collaborative relationship with your ROI vendor partner. Work together to develop and sustain a PHI disclosure management process. Having a dedicated ROI team supports the commitment to provide accurate and timely records to customers and patients.
This article was originally published on the MRO Blog and is republished here with permission. See original article to download a PDF copy of the full Journal of AHIMA article.