Virginia Health Information Management Association

Virginia Health Information Management Association Enterprise Information Governance: An Imperative Role for HIM Dan Rode, MBA, CHPS, FHFMA, FAHIMA VaHIMA Annual Conference 2016

Objectives – Let’s Focus On: Understand the context in which enterprise information governance (EIG) is growing; Understand the concepts of EIG; Understand the roles and leadership that health information management professionals can provide to organizations undertaking EIG; and, Understand some initial steps that a HIM professional could take to initiate EIG. VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Agenda Perspectives and the Environment Data/Information – the New “Bottom Line” The Fusion of Healthcare Organization's Information Barriers to Healthcare “Big” data Enterprise (Data and) Information Governance – What? Who – The HIM Role Resources Questions and Comments VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Glossary ACA – Accountable Care Act (“Obama Care”) PPACA – Patient Protection and Affordable Care Act ARRA – American Recovery and Reinvestment Act of 2009 AHIMA – American Health Information Management Association ARMA – American Records Management Association International EIG – Enterprise Information Governance HIPAA – Health Insurance Portability and Accountability Act of 1996 HITECH – Health Information Technology for Economic and Clinical Health HL7 – Health Level Seven International (standards development organization) IG – Information Governance IHTSDO – International Health Terminology Standards Development Org. (SNOMED-CT ) Meaningful Use – Incentive Program for EHR/HIE use under ARRA-HITECH NCVHS – National Committee on Vital & Health Statistics ONC – Office of the National Coordinator for Health Information Technology OESS – CMS Office of Electronic Standards and Security OIG – Office of the Inspector General (IG) of HHS VBP – Value Based Purchasing from Deficit Reduction Act of 2005 (DRA) X12 – Accredited Standards Committee –X12 (ANSI Accredited) VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Environment Medicare compliance Quality Initiatives (external – internal) Audits Continuum of Care / Continuity of Care ACA-Accountable Care Organizations Pandemics Research and population health needs Cost of healthcare Transparency Reimbursement reforms Comparison shopping VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Environment Competition Provider system mergers Insurance system mergers Managed Care Continuum of Care / Continuity of Care ACA-Accountable Care Organizations Cost of healthcare Pricing E-Discovery Consumer demands VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Environment Electronic health record systems Standards – transaction and semantics Technology development Informatics and information systems Communication systems Information analysis Cybersecurity – Phishing ARRA-HITECH Interoperability VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Perspectives and Environment Triple aim: Improving the patient experience of care (including quality and satisfaction) Improving the health of populations Reducing the per capita cost of healthcare VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Perspectives and Environment “Big Data” Data integrity Analytics Action Information Survival VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Data/Information – the new “Bottom Line” Migration of Health Data Realms Clinical Data – Ours Clinical Data – Theirs Administrative Data Operations Analytical Clinical/Administrative Business Costs Purchases Personnel Time VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Other Ancillary Data VaHIA-Annual Conference 2016 Central Supply Data Admissions Registration Data Salary & Time Data Purchasing Cost Data HR Data Rx Data Data/Information – the new “Bottom Line” RevenueCycle Data Clinical Data EHR Dan Rode & Associates 2016

Data/Information – the new “Bottom Line” Technology and New Data Concepts Claim and billing – revenue cycle systems Finance systems Electronic health records or electronic medical records Third party transactions and clearinghouses Clinical ancillary systems New EHRs HIPAA Transaction Standards Operating Rules (business rules) Classifications, Terminologies, and Meta Data VaHIA-Annual Conference 2016 3/4 Dan Rode & Associates 2016

Data/Information – the new “Bottom Line” Standards and Interoperability Paper Format Standards Uniform billing (UBs & UCs) JCAHO (now Joint Commission) Other forms Classification (ICD / CPT / NCPDP ) ANSI – ACA X12 Transaction Standards (N) Health Level 7 International (HL7) Logical Observation Identifiers Names and Codes (LOINC) Terminologies (e.g. SNOMED- CT ) ONC Standards and Functions ONC Interoperability VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Confluence of clinical, administrative, and business/operations information Clinical Data & Information VaHIA-Annual Conference 2016 S Administrative Business And B Operations Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Confluence of clinical, administrative, and business/operations information Clinical Data & Information S Administrative Business And B Operations HIPAA Designated Record Set VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Confluence of clinical, administrative, and business/operations information Clinical S Data & Administrative Information VaHIA-Annual Conference 2016 Business And B Operations Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Confluence of clinical, administrative, and business/operations information S Administrative Business AndB Operations Clinical Data & Information VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Confluence of clinical, administrative, and business/operations information Outside D/I S Administrative Business And B Operations Clinical Data & Information VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Internal Possibilities Organization (Corporate/Enterprise) Information Health records (and data) EHR Ancillary service records MPI Admission/Registration related information Revenue Cycle information Financial Costs - supplies Revenues, et al. Expenses - personnel Duty rosters Personnel Information Other reports and records VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information Other “Internal” Possibilities “Shadow” records Associated physician practices or clinics Network/System Physicians Pre-acute entities Post-acute entities Existing statistics and other reports “Meta” data VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information External Necessity Population health Health Department CDC Pharmacy practice Research Environmental Agricultural et al. Competition Compare reports Quality Media VaHIA-Annual Conference 2016 Big Data Dan Rode & Associates 2016

The Fusion of Healthcare Organization's Information External Sources and Resources Local and State Health Department Local data programs Health Information Exchange Centers for Disease and Prevention (CDC) Centers for Medicare and Medicaid Services (CMS) Agency for Health Research and Quality (AHRQ) HHS Office of Civil Rights (OCR) National Institute for Standards and Technology (NIST) Associated research projects and studies – public and private Federal Reserve Internal Revenue Service VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Barriers to “Big” Data Cultural Lack of Interoperability – internal and external No standards – free text Unknown data, information, records Lack of consistent standards Transaction standards Classification standards Terminology standards Other vocabularies Various versions VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Barriers to “Big” Data Meta Data - the data behind the data Time created Received (order or report) Date Personnel involved (input or access) Source (functionary, external physician, patient, etc.) Batch (supply or Rx) Bar code Billed Paid VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Barriers to “Big” Data Policies and Procedures Policies: Hospital, clinic, practice, ancillary service – access/disclosure Documentation System data and information requirements Patient consents or authorizations Research Retention VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Barriers to “Big” Data Policies and Procedures (continued) Procedures: Acquisition and storage of data Technology Software and systems purchase, design, location, etc. Current strategic plan Organization VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Barriers to “Big” Data Privacy and Security HIPAA / HITECH policies and practices State laws and regulations – policies and practices Other privacy and security requirements Existing consent and authorization structure Breach experience VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Barriers to “Big” Data Identifiers Master Patient Index (MPI) – application and inclusion System identifiers (enterprise or HIE) Numbers v attributes Congressional Appropriations Denial VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Let’s Establish Enterprise (Data and) Information Governance Why What Where Control Details & Attributes Integration Identifiers Integrity Change Organization Who VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and) Information Governance – What? Data Identification and Design What data or information is needed to accomplish what objective? Priorities (pilot or strategic plan) VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and) Information Governance – What? Data Identification and Design Where is the data or information located? Originator and controller Department or system(s) Other sources E-Mails Text Messages Laptops, Tablets, Smart phones Paper Other mobile devices VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and) Information Governance – What? Data Identification and Design (continued) What are the attributes of the data or information? Version, syntax, vocabulary, meta data How is it collected and stored? Potential for conversion VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and) Information Governance – What? Data Identification and Design (continued) How can data or information be integrated to achieve the objective? Not at all Short term Long term What is the ability to cross match the data or information using identifiers or meta data? VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Data (documentation) Integrity What/who is the source of the data? “Credentials” of the originator System ability to convey to storage or similar location Audit history (training, ongoing authentication, problems) Storage mechanism VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Data (documentation) Integrity Data or information transformation Coding Classification systems Terminology systems Other conversions Disclosure systems and requirements Conversions VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Systems Design – Functional and Informative What changes need to take place in the enterprise to permit current or future abilities to collect, integrate, analyze, and maximize the enterprise data and information to the fullest? How will this affect each system or data source? How will the enterprise manage necessary conversion of systems and ongoing development and maintenance? VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Integration of Policies and Procedures What procedures, systems, or processes will need to be changed to accomplish initial and long-term data and information governance? What policies will have to be changed to reflect the changes in procedures, systems, or processes. VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Integration of Policies and Procedures (continued) What contractual and procedural changes are needed with personnel and external sources of data or information? What “contractual” and procedure changes are needed with patients or consumers? Financial Requirement VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Integration of Policies and Procedures Compliance (internal and external) Auditing (internal and external) e-Discovery Other external requests or requirements VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Modification and Ongoing Management What organizational changes (beyond just procedures) are necessary? Management structure Chief Information Officer EIG Committee HIM/HIT Integration Relationship with entity board of directors Auditors Department or functional area integration System/ software selection, implementation, and design VaHIA-Annual Conference 2016 1/4 Dan Rode & Associates 2016

Enterprise (Data and)Information Governance – What? Necessary Education and Training HIM – IT “integration” Senior management buy-in and support Enterprise education – why are we doing this? Ongoing communication Departmental or functional education Training of affected personnel or functional area feedback Patient / Consumer education VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Education and Initiation Getting started EIG underway? Yes – join the effort No – begin the effort Beginning the effort Can you educate for a organization-wide effort Yes – begin No – start an internal effort Internal effort MPI EHRs VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Education and Initiation Beginning the effort Can you educate for a organization-wide effort Yes – begin No – start an internal effort Begin the organization effort Education Prepare a SOPPADA with colleagues VaHIA-Annual Conference 2016 Subject Objective Present Situation Proposal Advantages Disadvantages Action Dan Rode & Associates 2016

The HIM (Your?) Role – Leadership (AHIMA) You have the background VaHIA-Annual Conference 2016

The HIM (Your?) Role – AHIMA IG Principles You know the principles Accountability Transparency Integrity Protection Compliance Availability Retention Disposition VaHIA-Annual Conference 2016

The HIM (Your?) Role – Initial Planning Familiar HIM Data Concepts Stewardship: Access Integrity Protection Health information management HIPAA requirements Legal requirements Confidentiality VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Organization The EIG Team(s) [organization] Chief Information Governance Officer HIM and IT EIG Council (suggested) Executive Sponsor & CIGO HIM/IT Medical and Nursing staff Finance Human Resources Legal Privacy and Security Officers / Compliance Officer Internal Auditing Officer VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Organization (continued) The EIG Team(s) [organization] EIG Council EIG Committee or Workgroup Long-term (e.g. records or systems committee) Short-term workgroup: EIG representative Functional area / department / unit representative(s) HIM IT – systems and software Vendor(?) Information auditor / documentation specialist VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Auditing What information can be gained from existing and past audits? Internal or external What work has been done previously to determine data integrity and system integrity? Has a security audit been performed for this sourer material? What audits are now necessary? Future? Audit staff Coders QA staff IT staff VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Initial Planning In Your Department Do we start with the EHR/EHRs? What can be analyzed from existing data or information? Are there parallel systems data (e.g. pharmacy or finance) that can be analyzed? What Medicare (or Medicaid) information could be compared? Can basic work be done using ICD-10-CM or ICD-10-PCS? Are their other facilities within your system that can be used for comparison? Have all inputs to your EHR been audited? (Documentation integrity) Is there feedback from internal or external audits that can be reviewed for potential errors and information? Based on this experience what can come next? VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

The HIM (Your?) Role – Initial Planning In Your Department Do we start with the EHR/EHRs? Whose on the team? HIM IS/IT Privacy Revenue Cycle? Subject department? VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Resources American Health Information Management Association www.ahima.org/infogov America Records Management Association International www.arma.org CMS Research and Data Site www.cms.gov/Research-Statistics-Data-and-Systems/Research-Statistics-Data-and-Systems.html Council for Affordable Quality Healthcare (CAQH) www.caqh.org Health Data Consortium (Health Datapalooza) www.healthdataconsortium.org VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Resources Health Information Management and Systems Society (HIMSS) www.himss.org Information Governance Initiative www.iginitiative.com Office of Civil Rights (OCR-HHS) http://www.hhs.gov/ocr/privacy Office of the National Coordinator for Health Information Technology (ONC-HHS) www.healthit.gov VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Resources Books and Journals: Strategies for Electronic Document and Health Record Management Darice Grzybowski, MA, RHIA, FAHIMA Enterprise Health Information Management and Data Governance Merida Johns, PhD, RHIA via AHIMA Books Implementing Health Information Governance Linda Kloss, MA, RHIA, FAHIMA via AHIMA Books VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Resources e-Publications: EHR Intelligence www.ehrintelligence.com Government Security Enews www.govinfosecurity.com Healthcare Law Today (Foley & Lardner LLP www.healthcarelawtoday.com Health HIT Smart Brief www.smartbrief.com Health IT News www.digital.halldata.com VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Resources e-Publications (continued): Health Information Security www.healthcareinfosecurity.com HealthIT Security www.healthitsecurity.com Information Management www.information-management.com VaHIA-Annual Conference 2016 Dan Rode & Associates 2016

Questions, Comments Dan Rode, MBA, CHPS, FHFMA, FAHIMA Dan Rode & Associates 6405 Stonehaven Court Clifton, Virginia 20124 T: 703-946-9388 E: danrode [email protected]