By Mark Vreeland, Executive Director, Advisory – Healthcare, Ernst & Young LLP
With the Patient Protection and Affordable Care Act being implemented in stages through 2020, there has never been a more critical need for effective information governance at health care organizations in the United States. A powerful information governance program—one that sets forth clear structures, policies, processes and controls for managing data and information as business assets—offers significant benefits to health care organizations working to meet the new rules and requirements of health care reform.
Information governance allows for consistency of information to be used for analysis and reporting. It establishes the first line of action for data quality, metadata (the intersection between business definitions and physical data implementation) and master data management (a structured approach to managing specific data domains as master data associated with core business entities). Effective governance enhances enterprise agility by allowing for easier migration. It improves the customer's experience, lowers management costs through reducing data redundancy, offers impact analysis across the organization for change requests, and enhances the organization's ability to analyze and report on enterprise information.
On the flip side, the absence of a strong information governance program can pose serious risks to a health care organization, particularly as provisions of the Patient Protection and Affordable Care Act take effect. Inconsistency in reporting and analytics can lead to noncompliance with reporting requirements of the Act. Noncompliance, in turn, could trigger substantial financial penalties for the organization.
An example of insufficient information governance at one organization
Recently, while assessing a health care payer’s analytical environment, our team discovered an anomaly that is all too familiar among payers: no one person or group at the client was solely responsible for compiling per member, per month numbers. In fact, various groups were using different definitions of PMPM and producing conflicting counts for analysis and reporting. As a consequence of a lack of governance over PMPM, the organization had inconsistencies across a number of reports and analytics. In the health care industry, PMPM is a hugely significant calculation—it affects 40 to 50 different analytical functions. So when PMPM numbers are reported incorrectly or inconsistently, the various analytical functions that rely on these numbers will be out of kilter and the situation could lead to noncompliance with reporting requirements.
Fortunately, at this organization, we were able to help them implement a program that addresses proper governance over PMPM calculations. The payer now relies on its actuary group alone to define PMPM for internal use and external reporting. This is just part of the organization's broad new effort toward a significantly upgraded information governance program.
But that's just one organization. Too many others in the health care industry are needlessly at risk because they remain stalled in an early, fairly undeveloped stage of information governance and lack momentum toward a fully realized, mature and highly effective governance program.
A framework for effective information governance
Successfully managing enormous amounts of data and creating actionable information from that data are daunting challenges for most health care organizations. Yet these challenges become far more manageable when approached under the guidance of a carefully designed framework for effective information governance.
What does such a framework look like? It consists of three main disciplines that together support the entire life cycle of information at the organization: the Business Information Discipline, the Systems and Network Discipline and the Information Asset Discipline. Each has its own unique combination of people, process and technology. And each is supported through a defined metadata management strategy.
The Business Information Discipline
The Business Information Discipline (BID) defines the data and information necessary to support the operational goals of each department, business unit or division within the organization. Roles and responsibilities within the BID vary based on the size of the organization, but certain roles are central to the discipline. One such essential role is the Business Information Steward (BIS). Typically, each department, business unit or division has its own BIS. This individual is responsible for the quality of data content within his or her own area and decides who will be permitted to create, read, write, update or delete such data. The BIS also defines acceptable values, domains and definitions of codes and determines how data will be made available to other areas within the organization (either as raw data directly from files and databases or through predetermined access routines).
The Systems and Network Discipline
The Systems and Network Discipline (SND) defines the system roles and network analyst roles within the information environment. This is the discipline with the largest concentration of technical resources, each having a degree of stewardship responsibility. For example, application analysts and developers are tasked with understanding business requirements, creating meaningful applications to meet these requirements and designing the presentation of information. Network analysts work to ensure that the network can handle the volume of data or information being requested. Database administrators oversee the physical environment for data storage and provide for ongoing access to, and timely retrieval of, data. Production support, a responsibility shared by the business and IT groups that support the business environment, is another technical resource under the SND umbrella.
The Information Asset Discipline
The Information Asset Discipline (IAD) is responsible for creating, maintaining and delivering information asset management for the organization. IAD outlines governance implementation, stewardship roles and general management of information.
Health care reform is law, and legislative efforts to repeal the law or make major changes to it face extremely high hurdles, including the President's veto authority. In the meantime, organizations must respond to the law and adapt their business models to comply with its requirements, all the while continuing to monitor reform-related legislative changes and regulatory guidance. The framework I've outlined offers an excellent roadmap to help health care organizations take on the considerable challenge of meeting the law's reporting requirements.
The views expressed herein are those of the author and do not necessarily reflect the views of Ernst & Young LLP.
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