EHR Integrity Management

Excellens Health System (Excellens) made an organizational commitment to the EHR well before HITECH and meaningful use incentives. The system grew through consolidation first within a city and then the surrounding catchment areas until today it covers half the state. A unified EHR was part of its organizational design from the outset. Senior clinical and administrative leaders understood that information would be one key to achieving clinical and organizational excellence. At the time, interoperability across EHRs was costly to achieve, if it could be achieved at all. As Excellens began consolidating independent physician practices through acquisition or affiliation agreements, it made the difficult decision to require physicians to use the standard EHR and other technology solutions. For affiliated practices, data-sharing agreements are in place.

Until three years ago, each hospital in the Excellens system had its own HIM department, and the departments worked at achieving greater uniformity by mak-ing uniform service and technology decisions such as those for transcription and release of information. The dual goals of greater uniformity and cost control led to consolidation of HIM across the system in 2012. Today Tom Palmaris, RHIA, serves as vice president of EIM for Excellens. The corporate EIM team also consists of three senior directors in charge of HIM “”operations such as release of information and life-cycle records management functions, clinical coding and revenue cycle, and EHR functions, including an EHR integrity team. In addition, the systems privacy officer reports to Tom.

The EHR data integrity team is responsible for correcting, amending, retracting, and deleting information in the EHR in accord with policy and to support the integrity of the record. Although it is the responsibility of providers to take care to enter only correct information into the EHR, when an error is made or detected, there is a standard procedure for correcting, amending, or retracting. The team provides training and advises on the proper application of the procedure. Correction requests are also submitted to the team using a Web request or, for an emergent situation, a phone helpline procedure.

The EHR integrity team investigates and resolves issues referred to the team. As needed, the EHR integrity team may call in IS if there is a contributory software issue, or it may complete an incident report if it is felt that this is something that IS should track. In addition to referrals, the EHR integrity team deploys audit processes to detect errors or missing data and uses this information to explore ways to improve accurate capture through soft-ware modifications or through additional training or coaching. This new procedure has been widely recognized as a valuable service. Recently the integrity team has been assigned responsibility for managing corrections, amendments, retractions, and deletions of the patient information made available through Excellens’ patient portal.

Questions

1.Data quality is one of the principles of fair information practice. Identify three ways in which data quality is an ethical consideration. Possible responses include: (a) Poor data quality puts patients at risk of harm because needed data is not available when needed or no””accurate. (b) Correcting poor data is more costly than designing systems to facilitate its accurate capture in the first place. (c) Poor decisions may be made based on data quality problems that may not be fully understood by decision makers.

2.How would you make the case for establishing an EHR data integrity unit for a hospital? Possible responses include: (a) Track the incidence of and types of data quality problems identified using the current ad hoc approaches and estimate the true exposure and associated costs. (b) Align political support for creating the team from clinical leaders, legal, and IS. (c) Secure approval to conduct a pilot test of a coordinated error correction system and pilot test it to build support for expanding it to the entire health system.

3.In addition to the EHR, what other critical health system information systems require a high level of data quality and robust data quality management? Possible responses include: (a) The personal health record or patient portal. (b) The health information exchange protocols including initial exchange and the process for correcting previously exchanged information later found to contain an error. (c) Coded data submitted on claims for healthcare payment.

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