In this quality-driven healthcare environment, hospital mergers are commonplace. Sometimes one or more hospitals merge directly. In other cases, hospitals merge together under one corporate umbrella that may include many other facilities. When these types of mergers occur, data integrity and information governance are critical. HIM professionals are often at the center of these changes, ensuring data accuracy and explaining the information implications of consolidation to patients.
Hospital mergers present HIM with many opportunities to serve as patient advocates, providing education about HIPAA, information exchange, and more. Below are four concepts with which HIM must be familiar as the healthcare landscape continues to change and evolve.
1. Patient education about mergers. Should patients be notified of these mergers as they occur? The current trend is to add a statement to the privacy notice that lists organizations that are affiliated with the covered entity. This way, patients are informed in the event that formal mergers do occur. Questions may still arise at the time of the merger, but at least patients are given the heads up.
2. Patient authorization for multi-entity access to protected health information (PHI). Integrated delivery systems—in conjunction with their compliance and legal departments as well as clinicians—must decide whether they will require a signed authorization allowing access to PHI. However, if signed consent is required, what happens when a patient refuses to authorize multi-entity access? In some cases, clinicians may be unable to treat the patient without all of the necessary information to care for him or her.
3. Enforcement of operational procedures. Controls must be applied at the point of entry of the healthcare system and subsequently adhered to during each and every encounter.
4. Mis-releases of information. HIM must be able to quickly identify any individuals who are accountable mis-releases. In addition, mis-releases must be thoroughly reviewed by a team of experts to determine the root cause of the incident.
Is your organization part of merger? If so, what types of HIM-related questions arose during that merger or as a result of the merger? More integrated delivery models are here to stay—and HIM needs to be at the forefront of conversations related to health information challenges in these models and systems.
Editor’s note: For more information about HIM implications of integrated delivery systems, refer to Ethical Health Informatics, Third Edition, published by Jones & Bartlett Learning, a chapter of which was written by Karen Gallagher Grant.