Imagine you're a member of a very forward-thinking information technology department in a behavioral healthcare organization, and you have just activated an electronic record at your largest site. After numerous meetings and exhausting planning and preparation, the site finally is paperless. Yes, you are feeling pretty good about yourself as you begin to take your bows and accept congratulations on a job well done, but then you realize that the celebration may be a bit premature. In fact, the real work of effectively managing the electronic record and using the resulting data is just beginning.
These are lessons we learned as part of developing an electronic record at the Gateway Foundation, a Chicago-based provider of substance abuse and mental health treatment. At nine sites Gateway deployed a fully automated electronic record that includes point-of-service scanning (scanning documents into the record at the time of service), document management, and electronic signature. At some point during the implementation, we realized that the electronic record would have a significant impact on information management as we moved from being paper-based to paperless.
After an internal assessment of our information management needs, and with the assistance of an industry-recognized information management expert, Gateway developed a comprehensive governance plan to address health information management. The plan included creating a committee to address record compliance and deficiencies, a health information management committee to promote continuity of the electronic record and information exchange, and a new position to coordinate health information management services across Gateway's multidisciplinary integrated healthcare system. Important to all of this was effectively linking staff resources across the organization to improve health information management.
Although electronic records are being activated in hospitals at an ever-increasing rate, they still are relatively new to behavioral healthcare organizations, which spend so much time and resources obtaining technology that record management or planning for such is left for after the fact. Behavioral healthcare organizations eventually realize that managing health information with an electronic record requires reengineering staff roles or responsibilities and even business processes. As traditional health information management functions continue to become “virtual” and not department focused, the key to successful record and data management is to effectively link staff resources that impact the record.
One of the first steps is to identify which staff members or roles are involved in entering data into the record, often including clinicians, system analysts, quality management analysts, business office staff, and policy-procedure administrators. The next step is to identify staff members and roles involved with data extraction, which likely include many of the staff and roles involved with data entry as well as the corporate compliance officer, security officer, program services analyst, and health information manager.
Organizations with multiple sites are faced with solving the centralized vs. decentralized information management challenge. Centralized resource management may be less challenging if only one source is responsible for managing the information (e.g., a health information manager). Essentially, the tracking and measuring of compliance aren't as complicated when functions are centralized.
Decentralized management, which Gateway employs, requires a different approach. Gateway leverages clearly defined roles and responsibilities, along with comprehensive policies and procedures, to manage information. Prior to deploying the electronic record, Gateway adopted a decentralized approach because each site/facility is responsible to address certain record-related duties.
The value of developing sound policies and procedures is clearly indicated with decentralized information management. Although a policy might dictate what has to be done, the actual “how to” may be open for interpretation. Therefore, several processes may make monitoring and change management difficult.
Many organizations that don't have health information managers have to determine who really is responsible for managing records or data. With the number of roles involved with managing data, determining who is responsible may not be easy. The key to success lies with effectively linking roles and responsibilities.
Many staff members have their hands in information management, with responsibilities such as:
Access/log-in security (staff involved in information services and corporate compliance)
Application management, enhancements, upgrades (staff involved in information services, corporate compliance, policies and procedures, quality management, clinical operations, and program services)
External auditing (staff involved in corporate compliance, quality management, and information services)
Change management (staff involved in information services, policies and procedures, and quality management)
Data extraction (staff involved in program services, information services, and clinical operations)
Form creation (staff in all departments)
Internal auditing (staff involved in quality management, policies and procedures, and clinical operations)
Billing data (staff in accounts receivable, information services, clinical operations, and program services)
Releasing information, record retention (staff involved in clinical operations and corporate compliance)