Exploring Driver #1 of the “5 Things You Must Know Now About Release of Health Information

By: Linda Kloss, MA, RHIA, FAHIMA

Healthcare systems are reporting a 40+% increase in the volume of requests for protected health information in the first half of 2017 as compared to the same timeframe in 2016.  This is a 40+% increase over already high volumes of requests from a growing list of requesters.  Volumes will continue to increase particularly as patients are becoming more involved in their health and understand that they can and should have current versions of their health records.

The process for fulfilling requests has also changed very dramatically over recent years as EHRs have largely replaced paper records. For decades, HIM referred to the function of disclosing confidential patient information as “release of information” or R-O-I (too often requiring differentiation from the more commonly understood ROI, return on investment). A more precise and contemporary term is “disclosure” defined under HIPAA as the release, transfer, provision of access to, or divulging in any other manner of information outside the entity holding the information. While HITECH did not change this definition, it does change the accounting of such disclosures for organizations using an electronic health record, which now includes most healthcare organizations.

Verisma is leading the way in approaching R-O-I as disclosure management because this is what it must be in the world of electronic information; a different ball game than release of paper documents.  In the R-O-I world, we thought in terms of pages of information.  Pages were the basis for calculating the work effort and per page fees were hotly contested by state legislatures as interested parties sought to keep per page fees down while hospitals sought fair reimbursement.  Those days are long gone.

In a typical EHR, the effort associated with producing an export for disclosure includes the effort required to determine the parameters of the information to be disclosed, apply the minimum necessary standard when applicable, ensure that there are no restrictions on the information’s release that requires additional permissions, identify source systems for the requested information, compile the extract, and produce the information in the format that is usable by the patient or other requester.

By any measure, electronic disclosure management represents a step up in complexity and requisite skills when compared to the old record copy days.  This is particularly true as patients and others request longitudinal information and the volume and complexity of health information itself in electronic records continues to expand.

Volume and complexity is one of five drivers transforming health information disclosure management.  With regard to this driver, healthcare organizations should consider the following:

  1. Do we know enough about how the types, volume and content of requests are changing?
  2. How well is the process for creating extractions from the electronic record understood and standardized?
  3. Do we understand the compliance pitfalls and have audit trails for Business Associates providing support for disclosure management?

In our next post, discussion will center around Drivers #2 ROI Process Variation Across a Health System is Costly and #3 ROI Process Variation is Risky of the “5 Things You Must Know Now About Release of Health Information.” We welcome you to share your comments and questions with us at solutions@verisma.com.