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EHR Implementations and the HIM Department
By Matt Rohs

The HITECH Act was created to modernize the healthcare industry by promoting and expanding the adoption of EHRs by 2015. However, many healthcare organizations have not done their homework before plunging into EHR implementations. In a rush to take advantage of the federal EHR financial incentives, hospitals are forgetting to determine what EHR implementations actually entail, such as two- to three-year implementations, lapses in data availability, glitches during software upgrades, and a learning curve for all staff to become knowledgeable of new applications. Given the many aspects of EHR implementations, hospitals may be in for more than they expected.

These long and multifaceted implementations will place further burden on many departments in healthcare organizations, including the HIM department. The added work associated with an EHR implementation may even compromise the proper and timely release of private patient information. As healthcare organizations try to get their EHRs up and running quickly, they need to keep in mind that the release-of-information (ROI) process must be carefully managed.

EHRs and the Complex ROI Process
Consisting of 32 specific steps, ROI is a complex and highly regulated process that can carry fines of up to $1.5 million from HIPAA and other regulatory violations if not adhered to properly. The ROI process is further complicated by multiple databases, state and federal regulations, and patient privacy laws that must be addressed by those handling the ROI requests. In addition to EHR implementations, medical record audits—including recovery audit contractor (RAC) requests—will add an extra burden to the ROI process and the already-overburdened HIM department. Health and Human Services estimates there are already approximately 55 million medical record requests made per year, a number that will rise with the expansion of the RAC program this year.

Since each patient record request is unique and demand is high, it may be too much for an HIM department to handle while going through rigorous and time-consuming system changes such as an EHR implementation. An HIM professional’s role is even more significant because meaningful use drives EHR adoption, placing more emphasis on every decision made by the HIM department.

Although there are efficiencies that will accompany EHRs and related technology, the transition from paper-based systems to paperless systems can be difficult. If  done incorrectly and not by a trained, certified HIM professional who has a true understanding of the changing state and federal legislations, huge financial and legal penalties may be imposed on a hospital. Given the timeline, the complexity of EHR implementations, and the need to meet meaningful use criteria, hospitals could greatly benefit by outsourcing parts or all of the ROI function to qualified HIM professionals.

EHRs Can’t Do It All
The addition of new regulations is meant to protect patients, but what if HIM professionals don’t have the time and/or resources to keep up with new rules and regulations, and technology implementations? Even with EHR technology in place, HIM departments must be staffed with specialists who possess the necessary knowledge and expertise to complete each medical record request correctly and in a timely manner.

Certified HIM professionals may help hospitals significantly reduce the risks (financial and otherwise) associated with ROI. Outsourcing the ROI function to skilled professionals could also help hospitals complete certain meaningful use criteria. Other new ROI requirements as defined by the American Recovery and Reinvestment Act (ARRA) consist of specific, complex tasks, including the following:

• Accounting for disclosures: ARRA requires that healthcare facilities using EHRs provide accounting or auditing trails of all record disclosures. This represents a major change from current HIPAA laws, which exempt disclosures for treatment or payment purposes and routine operations. To thoroughly account for such disclosures, HIM professionals will now have to mind the “minimum necessary” provisions of HIPAA, which state that only information necessary for an action to be carried out must be disclosed.
• Out-of-pocket costs: This gives patients the right to prevent the disclosure of health information to their own insurance plans if they paid for a treatment out of their own pocket. Again, complying with this specific request would involve human oversight, as EHRs typically cannot automatically differentiate between payment methods.
• Electronic copies of electronic records: Providers are now required to give patients electronic copies of their health records upon request. However, these documents must be produced in specific formats and only certain information may be reproduced. To comply with this law, HIM professionals must intervene to ensure only the correct information is copied and released, or heavy fines may be imposed.

Though EHRs are important clinical tools that significantly enhance the quality of patient care, they do create some difficult situations once they enter the HIM world. HIM departments must be staffed with highly trained specialists who possess the necessary knowledge and expertise to complete each request correctly and in a timely manner. One way to guarantee this is to consider outsourcing the ROI function to a HIM outsourcing-specialty company with trained, certified professionals who can handle the entire ROI process for your organization.

— Matt Rohs is president of the Association of Health Information Outsourcing and vice president and general manager of the release-of-information services division at HealthPort.