Enabling Patient Access in a Pandemic

Enabling Patient Access in a Pandemic

By Linda Kloss

The tragic surge in coronavirus cases and deaths continues through the long hot summer. Healthcare systems are fully focused on caring for pandemic victims and the health of our communities. We witness heroism every day in lives saved, new treatments, and compassionate attention to peoples’ needs. And we are proud to have health care as our life’s work. While we may not directly treat a person’s illness, we know that managing their health information is an essential element of managing illness and promoting health, including public health.

We are in a time of profound personal and professional uncertainty. Decisions require continually adjusting assessments of risks about how to protect ourselves and our families and in making sound business decisions.  There have been furloughs and layoffs due to shifting patient care services and workloads. Work from home is the new normal for many more in HIM. Workflows and procedures have been redesigned to adapt to physical distancing. Long days and nights of work and uncertainty.

Against this background it is great to learn about an innovation that offers demonstrated benefit now and will also be an important bridge to a new era. That innovation is the Verisma Request App (VRA). Reggie Abadsantos, RHIT, HIM Operations Supervisor, NCH Healthcare System, Naples Florida was guest speaker at the July 15 webinar “App-Based Release of Information Comes of Age.”[i] NCH implemented VRA in 2018 to improve patient satisfaction with a convenient and secure web-based  method to  obtain their health records.

With VRA and a centralized ROI workflow firmly in place, Reggie described how NCH quickly adapted to physical distancing and work from home without missing a beat in patient access. When walk in services were abruptly suspended in March, patients were redirected to the web App.  Patients could use their smart phone, tablet, laptop, or desktop to request their medical records; and like any App, it is available 24/7. VRA enables the request, authorization, and authentication process, creating a complete record that feeds the release of information management software and triggers the release. NCH consistently averages a 24 to 48 hour turnaround in fulfilling patient requests!  This performance level was not disrupted as NCH responded to COVID-19 and the volume of requests via VRA increased sharply.

Serving an elderly population, Reggie reports that having reduced paper and fax processing, team members are freed up to help patients who may need telephone assistance in walking through the use of the App. For people who wish to pick  up a physical copy of their health record or imaging, NCH offers a curb-side delivery service.  These unique ways to serve patients are consistent with NCH’s 2018 service goals for VRA.

We spotlighted NewYork-Presbyterian Hospital’s journey with VRA last October before New York City was the epicenter of the pandemic.[ii] We revisited NYP’s experiences in April in the midst of the surge. Like NCH, NYP was able to send staff home, close walk in service, yet continue to enable timely patient access.[iii] In fact, in the past 2 months, 20+ health systems comprising over 1500 sites of care, are now live with VRA to mitigate the impact of closed request services and work from home.    Further, the rate releasing e-records rather than paper, has significantly increased. VRA fulfills the requirements of HIM for completeness, security, compliance and cost-effectiveness. And when integrated with a comprehensive ROI workflow platform, it creates a seamless record of the request and its fulfillment.

Times of great challenge bring innovation.  Apps are no longer disruptive technology, but their application to Release of Information is! VRA’s value was well demonstrated as a popular adjunct request route prior to the pandemic. The pandemic has shown that VRA is the right technology for the time and for the future.  Health systems report that they will rethink walk up services, paper requests, faxing, and release of paper documents when physical distancing is no longer needed. They have learned we can do a better job in enabling patient access while strengthening business goals such as patient satisfaction, compliance, and cost effectiveness. Release of Information will never be the same…it will be vastly improved.

[i] www.Verisma.com:  July 15, 2020 webinar “App based Release of Information Comes of Age”

[ii] www.Verisma.com:  October 30, 2019 webinar “There’s an App for That! Connecting People with their Health Information”

[iii] www.Verisma.com:  April 29, 2020 webinar “COVID-19 Response:  Emerging Best Practices for Health Information Disclosure Management- Part 2”

App-Based Release of Information Comes of Age

App-Based Release of Information Comes of Age

Date: July 15, 2:00 pm – 3:00 pm EST

Presenters:

Reginald Abadsantos, RHIT
HIM Operations Supervisor, NCH Healthcare System

Panel of HIM and ROI Leaders

Linda Kloss, RHIA
Kloss Strategic Advisors, Inc. and Regulatory Policy Leader, Disclosure Management, Verisma

NCH Health System, Naples FL is a true pioneer in the use of Web-based App technology to support record request and release processes.  Implemented in 2018, NCH deployed Verisma’s Request App™ (VRA) to improve service to patients. NCH Health System is a large regional health system that also supports an older “snowbird” patient population living part of the year in Florida and often needing access to their health information from afar. It experienced rapid uptake VRA and strongly positive customer satisfaction feedback.

What NCH could not anticipate was the key role VRA would play in a time of COVID-19, enabling paperless request processing and electronic release despite workflow and disruptions due to work from home and other adaptations. This is a lesson that many of our health systems clients have come to appreciate as the use of VRA has now grown to over 1,500 sites of care. While the Office of the National Coordinator for Health IT (ONC) announced rules supporting patient access to their health information, it was pioneers like NCH and others who have built the story of how the right technology at the right time can transform a process long overdue for disruption.

In this Webinar, you will learn from NCH’s firsthand experience with use of VRA for release of information. You will also learn about the goals and experiences of other health systems using VRA. The essential technical, integration, security, and functionality requirements for an ROI app will be discussed as will implementation considerations. Presenters will describe the importance of teamwork among HIM, CIO, compliance and others working together to deploy Web technology to update what is often an outmoded fundamental building block for ROI.

Learning Objectives

  • Learn from health systems’ experiences in implementing and using apps for release of information to patients and third parties,
  • Describe realized benefits and impact of use of apps for release of information on improved customer services, productivity, and cost management,
  • Understand the federal policy environment that encourages the use of apps to improve access and disclosure of protected health information, and
  • Review the technology and privacy and security requirements for release of information apps.

 Approved for 1 AHIMA CEU Credit for Information Protection: Access, Disclosure, Archival, Privacy and Security

VIEW RECORDING

Verisma Announces Opening of Three New Regional Training and Support Centers of Excellence

Verisma is excited to announce its continued expansion across the country with the grand opening of three new Regional Training and Support Centers of Excellence in Florida, Ohio, and Wisconsin to further support the demand and rapid growth from new and existing clients. These strategically placed regional offices led by our expert team of Client Operations Directors, professional trainers, HR management and oversight teams will enhance our comprehensive training and national operations management efforts, and provide even greater consistency and reliability in service quality and outcomes to our clients.

Verisma has always been dedicated to collaborative partnership, and these new hands-on training centers, in addition to our New York, Virginia and Colorado corporate locations, will help us continue to deliver on that commitment and our promise to putting patients first.

HIPAA Privacy Policy – Adapting and Evolving

HIPAA Privacy Policy – Adapting and Evolving

By Linda Kloss

The Verisma disclosure management community was fortunate to be briefed last week by Timothy Noonan, JD, Deputy Director for Health Information Privacy at the HHS Office for Civil Rights (OCR). OCR administers and enforces the Health Insurance Portability and Accountability Act (HIPAA) and compliance with HIPAA’s Privacy Rule is a central focus for release of information professionals. His webinar update covered three very timely and important topics:

  • Recent privacy-related COVID-19 guidance and bulletins
  • OCR’s Right of Access Initiative, and
  • Developments regarding the Right to Direct health records to a third party.

Mr. Noonan had been scheduled to address Verisma’s 4th Annual Disclosure Management Summit in early May, cancelled due to the COVID-19 pandemic. The Webinar provided an opportunity to cover COVID-related guidance and as Noonan noted, it was a first opportunity this year for OCR to address its Right of Access Initiative.  (The webinar archive is available from Davy Simanivanh at DSimanivanh@verisma.com).

 COVID-19 Guidance

We are grateful to Mr. Noonan and the team at the Office for Civil Rights for its rapid fire response to COVID-19 in issuing seven (7) guidance documents in about the same number of weeks. The guidance helps front line care givers, first responders, public health officials, privacy and compliance officers, and health information professionals by clarifying common Privacy Rule questions such as sharing patient information without authorization with family and friends and public health.  Guidance expands flexibility, where needed, to get essential (read ‘minimally necessary’) information to those who need it to care for people in a time of crisis.

Guidance also addresses challenges relating to rapid expansion of telehealth, the ramp up of community-based testing, and media and film crew access to protected health information in a public health emergency.  Guidance outlines limits to enforcement discretion where good faith efforts by covered entities and business associates to fully comply with the Privacy Rule are a barrier to supporting critical public health and health oversight needs. If you haven’t already done so, visit the HIPAA and COVID-19 Web Page and become familiar with the guidance and its cautions.[1]

Right of Access Initiative

OCR is responsible for teaching covered entities and business associates and educating communities about the Privacy Rule (and other areas of civil rights).  It is also responsible for investigating complaints to determine whether they constitute violations.  Often areas of violation can be resolved by education coupled with a corrective action plan. Generally, the agency encourages corrective action and such encouragement produces change. For areas of egregious violation or failed corrective action, OCR has enforcement authority.

Mr. Noonan reported that OCR recieves over 26,000 complaints each year on some aspect of HIPAA and that complaints regarding Right of Access violations are increasingly common. He emphasized that the Right of Access is the “cornerstone of the Privacy Rule.” Accordingly, in February 2019, OCR announced that Right of Access violations would be a priority for HIPAA enforcement and two enforcement actions were announced in late 2019.  (Verisma addressed these in its December 17, 2019 Webinar: Turning Up the Heat! HHS Initiates Access Enforcement)  Mr. Noonan reminded us that the enforcement actions taken represent demonstrated systemic non-compliance. Effective release of information is characterized by policies and procedures that advance an individual’s Right of Access, including the right of individuals to exercise their privacy preferences and assert their information rights.

Right to Direct Health Records to a Third Party

One of these rights is to direct health records to a third party. Mr. Noonan reviewed elements of the January 2020 lawsuit settlement that vacated previous OCR policy limiting fees for authorized provision of health records to third parties—such as law firms and life insurance companies.  Mr. Noonan reiterated that this policy revision does not affect the individual’s right to access their protected health information.

The Health Insurance Portability and Accountability Act (HIPAA) is a multi-part law enacted by Congress in 1996.  Its privacy provisions went into effect over 17 years ago, at a time when health information was largely stored on paper and population health and patient engagement were not yet central strategies for health improvement.  In 2018, OCR issued a Request for Information (RFI) on areas where the Rule might be improved.In 2018, OCR issued a Request for Information (RFI) on areas where the Rule might be improved.  Now, a Notice of Proposed Rulemaking (NPRM) based on feedback obtained through the RFI is under internal review.  Mr. Noonan encouraged our community to read, reflect, and comment on the NPRM when it is published in the Federal Register, most likely later this year.  While privacy rights are enduring, how they are best protected must evolve to be relevant.

[1] https://www.hhs.gov/hipaa/for-professionals/special-topics/hipaa-covid19/index.html

A Future Anchored in Integrity, Access, and Connection

A Future Anchored in Integrity, Access, and Connection

By Linda Kloss

Health information remains a critical part of the current and future healthcare environment and is no less important in the midst of a global pandemic” stated Dr. Wylecia Wiggs Harris in opening remarks on last week’s webinar entitled Integrity, Connection, Access: A Framework for the Future. Dr. Harris, CEO of American Health Information Management Association (AHIMA), shared the principles and assumptions that shape AHIMA’s 2020-2023 Enterprise Strategic Plan via Webinar instead of delivering the keynote address at Verisma’s 4th Annual Disclosure Management Summit cancelled due to COVID-19.[i]

The Strategic Framework bridges HIM’s legacy, today’s crisis, and tomorrow’s imperatives. Dr. Harris emphasized three grounding principles undergirding the Framework: Integrity, Access, and Connection.  These sustaining principles are reimagined for what Dr. Harris described as a time when AHIMA and health information professionals need to “show up as transformational leaders.” She noted that the health information professional may be more important in the pandemic and post pandemic world.

In a world where people are more engaged in their health and health care and where health is finally understood to be broader medical services, Dr. Harris stressed that AHIMA’s Strategy is “People-Centric “ and that health information professionals must always remember that their work is uniquely important because  “Health information Is Human Information.” In fact, we have seen this play out in recent years as health information professionals proactively help people gain access to their health information in portals and health information exchanges. More recently, the use of request Apps is transforming patient access and release of information specialists are stepping into new roles of supporting innovation in access.

Dr. Harris and I discussed how the Framework’s grounding principles of Integrity, Access, and Connection might guide transformational improvement in access and disclosure management. The table shows examples of desired outcomes for some well-known areas of vulnerability and those in need of transformational change.

Principle

Examples of Desired Outcomes

Integrity

·    QA processes confirm that the right information is released and that there is a record for accountability.

·    QA processes confirm that the release complies with minimum necessary rules and there is a record for accountability.

·    Authorizations are complete and valid and they are convenient to execute.

Access

·    People have access to their digital health records through a secure web App with rigorous authentication.

·    Paper request and release processes are replaced by smart technology.

·    Release of Information staff help patients and third party requestors learn to use e-tools.

Connection

·    Release of information processes are standardized across health systems.

·    Centralized access to “complete” record from ambulatory and acute care encounters.

·    Workflow technology with compliance prompts and rigorous security supports end-to-end processes.

AHIMA’s initiatives will be guided by the Framework in the years to come. The guiding principles are also useful in anchoring needed change in access and disclosure management and in other HIM domains such as  coding, revenue cycle, EHR management, privacy, data analytics.

What’s required is a commitment to achieving measurable improvement.  As reported in our recent blogs about HIM leaders’ responses to COVID-19, there is currently momentum for modernizing outmoded processes and a spirit of empowerment for transformational change.  Dr. Harris summed this up so well for us, “When surrounded by uncertainty, we must be crystal clear about what grounds us, what will guide our decisions, what will help us navigate our new norm.”   

Once again, we congratulate Wylecia Wiggs Harris and the AHIMA Board of Directors for its compelling Vision and Framework and we thank Dr. Harris for sharing it so eloquently with the Verisma community.

[i] American Health Information Management Association.  2020-2023 Enterprise Strategic Plan.
http://bok.ahima.org/PdfView?oid=302888