Compared with other industries, the healthcare industry might be a Johnny-come-lately to information governance, but provider organizations are increasingly recognizing the importance of IG and are taking concerted efforts to adopt a strategy for success.
According to the American Health Information Management Association, IG is an organization-wide framework for managing information throughout its lifecycle and supporting the organization’s strategy, operations, regulatory, legal, risk, and environmental requirements.
Kathy Downing, AHIMA’s senior director of information governance, contends that traditional data and information management strategies are not keeping pace with the needs of healthcare organizations, and that IG is no longer a luxury but an imperative that the industry cannot afford to ignore.
“Credit card companies and banks have had information governance programs in place for 10 years already,” says Downing. “They’ve had the big data problem longer than we’ve had. Now, healthcare is really come up against the challenges of big data with electronic health records.”
In particular, she argues that IG is essential to organizations’ successful health IT initiatives, such as EHR implementations, data analytics, privacy and security, as well as information sharing. With the adoption of EHRs, advances in HIT and an increase in regulations, it’s more important than ever for organizations to take legal and regulatory needs into consideration when building an information governance framework. However, Downing is quick to add that IG needs to be broadly supported, noting that, “We do not think it’s an IT project.”
A 2015 AHIMA survey of more than 1,200 respondents found that 32 percent made no progress on IG, while another 24 percent indicated that it’s not yet an organizational priority.
“Information governance is something that healthcare must embrace in order to manage and leverage the data that is coming in now,” Downing says.
Last year, AHIMA released an IG framework for helping healthcare organizations govern information based on eight comprehensive principles— accountability, transparency, integrity, protection, compliance, availability, retention and disposition. Called the Information Governance Principles for Healthcare, Downing says the principles can be applied to a variety of healthcare organizations, such as health payers.
Downing encourages organizations to use the framework as they start or refine their own information governance programs based on these principles, which are intended to be interpreted and applied depending on an organization’s type, size, sophistication, legal environment and resources.
“Organizations really need to get an executive sponsor, whether that’s their CIO or CFO. Hopefully, the board is asking for that because IG is part of corporate governance,” she says, adding that building an information governance program from the ground up can take three to five years. “Someone at the executive level supporting you is critical, as is a multi-disciplinary committee approach, and then maintaining it for the long run. Your IG strategy has to align with your business strategy.”
Earlier this year, AHIMA launched the Information Governance Adoption Model to help organizations implement and develop an IG program. The model consists of 10 core competencies and creates a framework for adopting information governance based on an established body of standards, best practices and legal and regulatory requirements specific to IG in healthcare.
AHIMA’s new subscription-based assessment tool, IGHealthRate, enables organizations to determine their maturity level in adopting information governance, through providing measurements, benchmarks and coaching to continue to improve their IG programs. Ultimately, the goal for organizations is to achieve IGAM Level 5 validation, which means information governance has been integrated into their overall infrastructure and business processes.
Seth Katz, president of the Missouri Health Information Management Association and assistant administrator of information management and program execution at Truman Medical Centers in Kansas City, says his organization is trying to move down that IG path. “It’s a long journey, but we started a couple of years ago and are pushing through because we know the value information governance can bring,” Katz says. “It’s a culture change, and a long-term strategic initiative.”
Truman first decided to adopt an IG strategy as it was going live with its EHR system in 2010 and wanted to focus on the real-time availability of data that is meaningful, actionable and trustworthy. “We had all this data that we were collecting electronically, but the question was: what do we do with it to drive change and better performance?” asked Katz. “It’s not just about EHRs but the flow of information to coding, billing, and other parts of the organization. As we go to value-based care, it’s all about the data and quality outcomes.”
In addition to effectively sharing and using the data organization-wide, Katz makes the case that providers need to also ensure that they properly secure, retain, and maintain their information which is as much a strategic asset to driving change as an organization’s property and people.
Data retention is a particular challenge when it comes to health IT, he points out. “There’s a lot of questions and uncertainty about retention going into the future when we have all this data—it’s not like paper-based records.”
At Truman, he notes that IG is a Health Information Management-led program. According to Katz, HIM is a natural fit to take a leadership position in information governance because HIM is a “neutral player that touches different organizational areas such as IT, finance, and the clinical side.”
The two-hospital health system has so far achieved AHIMA’s IGAM Level 3 validation. “AHIMA really has some great tools that organizations should take advantage of as they look to get started in information governance,” recommends Katz. “As an organization, you have to figure out where you are today on the IG scale by scoring yourself and figuring out where you want to go.”
Stephanie Luthi-Terry, director of enterprise HIM integration/eHIM business solutions at Allina Health in Minneapolis, Minn.—another Stage 3 IG organization—says her healthcare system started to formally discuss adopting an information governance strategy three to four years ago.
According to Luthi-Terry, as part of that initial discussion Allina clearly identified in an organized fashion where it had IG gaps. “That discussion came from an HIM perspective, which received approval from our senior leaders to go ahead with a ‘non-invasive’ approach” she says. “We don’t have a formal IG program office but HIM ownership of the information governance process here. It all flows through HIM.”
Allina has taken a multi-disciplinary committee approach to IG by creating an enterprise-wide Electronic Medical Record Council, a large group composed of clinical, HIM, risk, quality, compliance, and other stakeholders from throughout the organization.
“We have standing subcommittees and ad-hoc committees that come out of those subcommittees and each are charged with specific work efforts,” including retention and disposition for the lifecycle of Allina’s growing information that includes patient, systems, and business records, says Luthi-Terry. “As we moved into our subcommittee structure through the EMR Council, the foundation for that lifecycle management piece was established.”
When it comes to successfully implementing information governance, it is critical to align an organization’s IG initiatives with its overall corporate strategy. “We know that it’s not cost-effective to have varying processes and procedures, which also increases inefficiency,” concludes Luthi-Terry. “At an enterprise level, information governance certainly makes sense.”
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