EHRs and Compliance: Is HIM at the Table?

As I travel around the country meeting with hospital executives and HIM professionals, I often ask whether or not they believe HIM is “at the table,” working with hospital leadership to plan and implement organizational strategy. More often than not, the answer is yes. There are many reasons for this.

Government initiatives. Many initiatives (e.g., ACO creation, pay-for-performance, quality measures reporting, ICD-10) are driving senior leadership to recognize that recently implemented EHRs often contain unreliable data. As a result, HIM professionals are being called upon to evaluate the impact of poor EHR design on the physician documentation shortfall. HIM is leading efforts to design templates and queries to enhance physician workflow and support documentation and compliance requirements. What’s more, executive leadership is frequently looking to HIM to spearhead “copy and paste” guidelines to maximize patient safety and improve compliance. Increasingly, organizations are funding software tools to identify documentation patterns that detect “copy and paste” issues that could lead to inaccurate coding.

Billing and coding risks. In addition to the obvious patient safety concerns, unreliable data introduces billing and coding risks. Recently, reports of cloning or upcoding, which some investigators claim has cost Medicare and Medicaid billions of dollars, have caused EHRs to come under scrutiny. HIM is taking the leadership role in making sure conditions are accurately coded and in governing the integrity of the coded data. This requires that HIM consistently apply the same official coding guidelines, conventions, and definitions. The growth of software tools such, as computer-assisted CDI and coding, reflect the understanding of how important complete physician documentation is to minimizing compliance and audit exposure.

Data integrity. With the introduction of ACOs and other reform initiatives, data is captured from across the continuum of care for data mining, analysis, and reporting. Codes generated by ambulatory clinics, physician offices, and home health matter now more than ever before.  An HIM Director whose hospital is participating in an ACO shared with me a recent scenario where a patient was seen for CHF across multiple care settings (primary care physician, specialist, hospital, home health). Each location assigned a different CHF code, even though the diagnosis was the same. Scenarios like this have resulted in this HIM Director being elevated to a data governance role, and the ACO is now in the process of hiring additional HIM professionals to focus on data integrity and compliance across the continuum.

Lack of interoperability is a barrier to enhancing clinical decisions and improving compliance. Laboratory data has been relatively easy to exchange because good standards exist (LOINC) and are widely accepted. Important information such as problem lists and medication lists, however, are not easily transmitted because existing standards have not been uniformly adopted. HIM has long been involved with terminology and classification systems and is now being recognized as having the expertise to help support and extend interoperability throughout the continuum of care.

Without a doubt, the proliferation of data generated by EHRs highlights the importance of data governance and data integrity in healthcare. HIM professionals deserve to be at the table, lending our voices and expertise to solving the challenges and opportunities that EHRs and compliance present, now and in the future.

Ann Chenoweth is Director of Industry Relations and Market Research with 3M Health Information Systems.

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