Leading the Way to Information & Data Governance – Part 2

LESLIE: We are continuing our discussion HIM Leading the Way to Information & Data Governance – Part 1 on the challenges of information and data governance with Melissa Martin, RHIA, CCS, chief privacy officer and director of Health Information Management for West Virginia Hospitals (WVUH). Melissa painted a vision of how HIM professionals can continue their role as health information stewards by transforming the role of HIM Departments toward Data Governance.

PATTY: We learned from Melissa how she began by working from the information management plan that had been developed by a multidisciplinary group to comply with JCAHO standards several years ago, and how she transformed her old Medical Record Committee into the Legal EHR Committee, expanding it with members from Quality, Compliance and Legal. She cautioned that Information and Data Governance, the rules and processes for how all data in the organization is collected, stored, protected, and used is not a responsibility of the Information Technology (IT) department, but rather is the responsibility of the administrative departments and business units that collect, maintain, manage and use information. Melissa’s IT department at WVUH has been a tremendous support in delineating responsibilities and by encouraging Melissa to manage the data governance activities.

MELISSA: Thanks for the recap. We ended our last discussion with a promise to talk about some of the serious data quality issues with EHRs as well as the Information Governance Dashboard that we developed at WVUH to facilitate the monitoring of data quality. Identifying and correcting data quality issues are at the heart of the data governance activities. Some data quality problems follow us from the paper record world and are well-known to HIM professionals, i.e., duplicate patient numbers. Some data quality problems are more difficult to solve in EHRs, such as content that is entered into the wrong patient’s record. It is complicated to remove the wrong information and get it into the correct patient’s record. It can create a serious patient safety issue for both patients if the information cannot be corrected quickly, as both records remain inaccessible for a period of time while they are being corrected.

LESLIE: What about the copy/paste issue? Do you have concerns about such functionality?

MELISSA: Yes, very much so. There are a number of problems with the use of copy/paste, and no easy way to recognize when notes have been copy pasted or forwarded. We have a policy requiring that the source be cited when you copy forward, but if the policy isn’t followed, it is hard to know. Auditing the records is important, but, the challenge of auditing the EHRs is they are built with smart text and smart links, like expanders. It takes a lot of time to audit the record for integrity, limiting how much auditing can actually be done. It is near impossible to read the EHR like a story. It is hard to make sense of the progress notes when the documentation is so redundant, or when just a couple of words were changed a copy forward section making hard to see the difference. Typically we notice the copied section while we are coding the records; sometimes copied notes are noticed by payers when they are auditing the records.

PATTY: What kinds of problems do payers’ auditors find?

MELISSA: An example is a progress note might say a patient is on a ventilator when it was actually removed several days prior, but the copy/paste note was not corrected to reflect the change.

LESLIE: Can the copy/past functionality be turned off?

MELISSA: That solution is under review, but there are considerable differences of opinion, with some physicians asserting it adds very little to no value and clutters the records, while others do value this functionality and want to keep it.

PATTY: What other activities in your HIM department fall into the realm of data governance?

MELISSA: We are responsible for updating templates in preparation for ICD-10, reviewing them by service line and updating for specificity and other measures. Making sure that the EHRs are designed to collect the correct data at the right time clearly falls into data governance and is an activity squarely in the HIM domain of expertise.

LESLIE: Good point, Melissa. The EHR is the primary data source, not only for direct patient care, but for so many other important healthcare data needs, there may be nothing more important in data governance than assuring that the data collection tool itself is up to date and functioning properly.

MELISSA: Agreed, but it is also a time-consuming, on-going activity that involves IT resources make changes to the systems, and those resources may be spread thin.

PATTY: Melissa, you mentioned to me that you put an Information Governance Dashboard in place about a year and a half ago which took the Legal EHR Committee to a new level in measuring information that they considered important.

MELISSA: Yes, a dashboard is an important resource for the committee to measure the success of the data governance activities and determining priorities for remediation or new initiatives. For now, we track rates for duplicate patient numbers, cloning (copy/paste) for number of cases audited, inpatient incomplete record delinquency, outpatient closed encounters delinquency, CDI queries, CDI agreement, and CDI coverage. We also monitor the use of the EHRs by patients accessing the portal, as well as health information exchange rates among care-givers between various WVUH sites.

LESLIE: So what is next for you and WVUH on the information governance journey?

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HIM Leading the Way to Information & Data Governance – Part 1

Keep an open mind and take one step at a time.

MELISSA: Now that we are fully live with our EHR I am actively implementing two-phase plan. A few of the activities in phase-one include “cleaning information”, i.e., assuring that all accessible information is up to date and accurate within the EHR; and making sure that all analysis is automated or at a minimum done concurrently. I also want to change the title of the Legal Health Record Committee to the Information Governance Committee, changing the charter, evaluating the current membership roster and determining what other departments need to be involved. And, I plan to make improvements to our MPI processes and improve our dashboard as the committee identifies additional items it wants to monitor. In phase two I want to involve more departments in the data governance activities, such as the Center for Quality Outcomes, Decision Support, HIE, and WVHIN, HR, Finance, Employee Health and Student Health, which I am sure will result in many more data quality improvement initiatives.

PATTY: With everything moving so fast, there is so much to keep up with. I don’t know how you do it.

MELISSA: Yes, the days fly by but the work is energizing and rewarding. Events like the recent AHIMA Data Integrity Summit help me stay current with the latest issues and solutions, and the motivation to keep at it.

LESLIE: Thank you Melissa for sharing your Information and Data Governance journey with our readers and good luck to you as you move forward.

Leslie Ann Fox is chief executive officer and Patty Thierry Sheridan is president, Care Communications Inc., Chicago. You can follow Leslie and Patty on their Twitter accounts, @FoxatCARE, and @pattytsheridan. Leslie and Patty invite readers to send their thoughts and opinions on this column to lfox@care-communications.com or ptsheridan@care-communications.com.

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