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HIM and Meaningful Use
By David Yeager

Now that the notice of proposed rulemaking for meaningful EHR use has passed the comment period, it won’t be long before healthcare organizations know which benchmarks they’ll need to reach to qualify for meaningful use payments. As they work to meet those benchmarks, input from all departments will be crucial. And although it is sometimes overlooked, one area that will be particularly important is HIM.

“HIM professionals are uniquely qualified to either drive the change or support the workflow changes that will be necessary for the implementation of HIT in terms of the data flow, ensuring data integrity when it comes to interoperability of EHR modules or EHR systems, even leading the implementation efforts,” says Allison Viola, MBA, RHIA, director of federal relations for the AHIMA. “And I think oftentimes there’s so much focus on the IT perspective that there’s not much attention given to the need for HIM professionals when it comes to the actual data that’s housed in these EHRs.”

To avoid an unmanageable workflow, Rose T. Dunn, MBA, RHIA, CPA, FACHE, chief operating officer of First Class Solutions, Inc, recommends that HIM professionals become intimately involved with the EHR selection process. Initially, she says, HIM professionals can help validate that EHR implementation candidates contain structured fields for each of the data elements that must be captured. It’s also important, she adds, “to encourage the EHR selection committee to begin identifying who on the clinical team will be responsible for entering data elements in those fields to ensure that data is routinely collected during the assessment and treatment process.”

The data entry issue may end up being particularly relevant to HIM departments. “With all of the clinical quality measure and the HIT functionality measure reporting that is required, I would envision that HIM professionals will be the ones collecting the data, compiling the data, or doing the actual EHR reporting on those measures,” says Viola. And Dunn notes that the notice of proposed rulemaking identifies certain necessary elements for reporting percentages, such as computerized physician order entry denominators, that will most likely need to be captured manually.

Release-of-information requests and privacy monitoring are other matters that will have a significant effect on HIM professionals. New requirements that information be available within 48 hours, rather than the 30 days currently mandated by HIPAA, could create a monumental challenge for HIM departments.

“They indicate that upon 48 hours, we will be able to provide procedural information, discharge summary, and a list of diagnoses,” says Dunn. “Well, within 48 hours after discharge, the physician often has not completed his discharge summary, which will be one of the sources of the diagnoses that will need to be entered for coding. Coding often is not done within two days after discharge.”

Privacy monitoring will be no less of a challenge. “For those of our professionals who hold the privacy title and responsibility, I think we’ll need to step up privacy monitoring and educational activities,” says Dunn. “And we’ll have to update a number of policies, especially the privacy notice.”

Dunn says the proposed rule will encourage people to request an accounting of disclosure regarding their health information. The accounting has been expanded to include disclosures for treatment, payment, and operations that had previously been excluded. “I anticipate there will be an increase in the demand for them. I think in stage 3 [of achieving meaningful use] the privacy role and security role are going to geometrically explode because you’ll need to be able to monitor those accesses [of a patient’s medical record],” she says. “You need to be able to explain the rationale to the patient as to why this information is being shared with healthcare facilities and providers that the patient doesn’t know, especially in any sort of HIE [health information exchange] environment among multiple facilities or within a regional scope.”

Be Proactive
While it may seem obvious to the HIM community that they need to be heavily involved in the meaningful use process, it may not be so clear to an organization’s decision makers. Viola says it’s imperative for HIM professionals to educate senior leadership about HIM’s value. Without significant HIM input, she fears that organizations and patients will not receive EHRs’ full benefits.

“I’m concerned that without HIM professionals at the table as part of this process, EHRs or EHR modules may be implemented incorrectly,” says Viola. “And I’m concerned that it will frustrate providers and they’ll tend to stay away from HIT implementation when in fact it could enable better outcomes, better care, improved data, and the integrity of the data.”

Dunn and Viola agree that HIM managers need to be proactive in addressing meaningful use. Otherwise, they risk becoming an afterthought. Dunn believes that by calling a meeting of stakeholders and decision makers, the HIM manager can identify the critical challenges, have a strong influence on the organization’s approach, and help identify the next steps to take.

“And if they haven’t done that, then HIM may be left out,” says Dunn. “The IT, nurse informaticians, or other clinical folks might take control of the process.” And although taking the lead on issues that affect entire healthcare organizations may be outside many HIM managers’ comfort zones, it is a necessary step.

“This proposed rule will impact HIM professionals for years to come,” says Viola. “Do the outreach now so that when organizations start planning committees or other task forces, they’ll remember that they need to engage an HIM professional.”

— David Yeager is a freelance writer and editor based in Royersford, Pa.