There are many reasons to celebrate Health Information Management professionals but perhaps one often overlooked is their ability to adapt to the ever-changing healthcare industry and its ever-evolving regulatory requirements.  Over the course of the last five years, the Health Information Management industry has undergone significant transformation. Initiatives such as EMR transition, ICD-10, and Meaningful Use have stolen the limelight, but it’s important to acknowledge the underlying   goals of each of these initiatives: privacy and security. 

Just a few years ago, the government released the HITECH Act, to promote the adoption and meaningful use of health information technology.  The act called for an overhaul to our health information infrastructure and strengthened the civil and criminal enforcement of HIPAA rules.  As a result, Health Information Management professionals were forced to change the way they work, think, communicate, and interact – in fact, thanks to the new rules, their organizations’ reputations and wallets depended on it.  Only three short years later, the government followed up with the release of the HIPAA Omnibus Rule.

The intent of the Omnibus Rule is to provide greater clarity and accountability around the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules.  However, with its call for patient access to electronic health information, direct liability for business associates, and a tiered penalty structure for non compliance, amongst other things, the Omnibus Rule, does much more.  It essentially changes the game. The rule forces Health Information Management professionals to, once again, re-evaluate and adapt systems and processes to align with more clearly defined regulatory requirements.  It also makes one thing very clear: the regulations may continue to evolve but the focus on privacy and security is here to stay.

In this new world, of heightened security and maturing definitions of “what good looks like,” the aptitude of Health Information Management professionals’ to quickly adapt and cleanly execute has become critical to each healthcare organization’s ability to comply and, ultimately, survive in today’s competitive environment.  Whether re-engineering processes to fully realize EMR transition efficiency gains, positioning the organization to meet meaningful use requirements and achieve government incentives eligibility, or thwarting the threat of PHI breaches and associated monetary penalties, Health Information Management professionals have been, and will continue, to be the foundation of the healthcare industry’s information evolution.    

Recommended Resources to learn more About HIPAA’s Omnibus Rule check out AHIMA’s details analysis.

Unfortunately, many labs worry moving these irreplaceable assets could put them at risk – and rightfully so.  Any time you take fragile inventory and physically move it, there are risks. But the answer isn’t to close the door on offsite storage and, in turn, forego its many benefits.  Rather, you simply need to take the appropriate steps to identify those risks and mitigate them accordingly. To do this, you’ll need to zero in on one very critical component when evaluating your vendors: the transportation process.

Think of it this way, whether riding a bike or driving a car, we put safeguards in place to protect some of our most irreplaceable assets while in motion. We have helmets for our heads, seat belts for our loved ones – why wouldn’t we give the same level of consideration to the way in which we transport irreplaceable slides and blocks?  Extremely fragile, highly valuable, and often irreplaceable, it only makes sense to ensure your offsite storage vendor has pathology-specific safeguards in place to facilitate the secure handling of slides and blocks.

Here are a few key items to keep top of mind when evaluating your storage vendor:

• Pathology-specific operating procedures: Make sure your vendor uses pathology-specific standardized operating procedures to ensure the secure handling of your fragile assets.  These procedures should clearly take into account the sensitive nature of the assets and incorporate safeguards that address every phase of your assets lifecycle including the inbounding, retrieval, refile, and storage processes.
• Identify protocols unique to the type of inventory move required:  Keep in mind, your vendor should be able to clearly identify protocols designed to stabilize and secure assets specific to the type of move required.  For example, a bulk move of inventory and standard request for retrieval are inherently different.  One requires a mass move of large cabinets and containers while the other demands the timely retrieval of a small subset of slides and/or blocks.  Your vendor should be able to accommodate both types of requests and clearly articulate the processes in place to protect your slides and blocks in each scenario.
• Pathology-specific transport containers:  Should a slide or small group of slides need to be retrieved, the use of pathology-specific transport containers can ensure these fragile assets arrive 100% unscathed and intact.  It’s important to note that a transport container is not the same as shipping envelop or box.  A pathology specific transport container should be made of a durable, shock-absorbent external shell and include a storage tray uniquely tailored to prevent slides from bouncing or breaking while in transit.

All these things considered, you’ll be able to gain the easily scalable storage capacity you need – without the burden of managing these time consuming upgrades- and being realizing the multitude of benefits that come with offsite storage.

For more best practices visit our Pathology Storage Management page.

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Most laboratories strive to ensure all slides and blocks related to a single procedure remain together as a single accession, however errors are not uncommon. Manual and legacy tracking processes often limit visibility. And for the many labs storing slides and blocks onsite, it’s difficult to prevent people from circumventing process and helping themselves to the inventory. As a result, it’s difficult to keep track of who is accessing what. You’re constantly questioning, “Who checked out what slides? If and when they’ve been returned? And , if they have, whether or not they’ve been placed back in the correct location?” Whatever the cause and however you frame it, at the end of the day misplaced slides and blocks equate to lost time, wasted resources, and, let’s not forget to mention, a huge headache for laboratory managers.

The best way to alleviate this challenge is to store the healthcare assets in a space that physically prevents unauthorized access. Offsite storage is an ideal option. Offsite not only precludes individuals from helping themselves to the slides and blocks – which, inadvertently, creates errors in your inventory log or management system – but also offers the opportunity to implement and enforce process standardization. This is important because to accurately track and manage your inventory, you’ve got to ensure each slide and block checked out is accurately logged. Of course, this could be done onsite, but how much time and effort would you have to allocate to managing both the people and processes involved in doing so successfully? And, keep in mind, this would be on top of all of your other core responsibilities. For offsite storage vendors – or at least the good ones- standardization is built into the foundation of their business and programs.

The reality is many laboratories feel onsite means more control and better access. Yet what we forget is that for many laboratories storage is just one small cog in the wheel of many responsibilities. In the realm of organizational goals and priorities, it can quickly become very difficult to dedicate the time, resources, and space necessary to most efficiently manage the ever-growing volumes and demands of sample storage. That’s the value a third- party vendor can provide. With dedicated focus on storage, day in and day out, a third- party vendor can not only provide the space and environmental controls you need to properly store your slides and blocks, but also the best practice expertise and advanced technologies necessary to eliminate inefficiencies from your storage management program.

This very concept is the conundrum of specimen sample storage. A majority of labs continue to manage samples onsite today based on the underlying assumption that onsite equates to better control and access. Yet the reality is, in today’s laboratory environment, access and control are far less related to the location of the physical assets and far more influenced by the quality of the controls, the consistency of the processes , and the capabilities of the technologies used to manage them. Who better to identify and optimize best practices for storage management components than a vendor who is uniquely focused on providing and optimizing specimen storage 100% of the time, each and every day?

For more best practice tips and tricks for your laboratory samples, go to our Pathology Storage Management page.

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When patient information resides in multiple formats — and when your physical records constantly move from location to location — there is a higher likelihood of a privacy or security breach. And should you experience a reportable breach, it can do irreversible damage to your brand, shrink the confidence in the community that you serve and cost you a lot of money and pain. Therefore, you’ve got to find a way to reduce that risk. The best way to do that is by working with a HIPAA -compliant partner that can help you develop a compliance plan to convert your records into a single format, using proven workflows and a secure chain-of-custody that minimizes the chances of a breach.

Why am I suggesting partnering? Well let’s be honest. The transition to the EMR is a new process and with new processes come unknowns and unexpecteds. The industry as a whole is going through this together and learning simultaneously. As a result, many transitions start with a phase one implementation that is closely followed by a phase two optimization based on key learnings, mistakes and challenges uncovered in phase one. However, by working with a partner who has participated in multiple implementations in a variety of facility types, you’ll gain the insight necessary to build a direct route to optimization; insight as to what works and what doesn’t as well as what to look out for to avoid a painful transition.

For example, an experienced information management partner, can help you address and consider the following:

• How will you manage the redundancies and inconsistencies common in paper-based legacy systems?
• How will you design, implement and control the complex workflows of a hybrid environment?
• How will you store electronic records in a way that makes them accessible, compliant and affordable?
• Will you be able to maintain retention and destruction schedules that meet regulations and your own requirements so that you store only the records you need to store, whether paper or digital?

Though seemingly straightforward, these are highly complex questions that when left unaddressed or improperly addressed can have serious implications on productivity, compliance and most importantly the quality of your organization’s patient care. Leveraging a partner’s in depth of understanding of the broader issues, you can avoid commonly overlooked pitfalls that drive up cost and risk while ensuring your organization maintains secure, timely access to all necessary patient information throughout the transition process.

For more information about how you can achieve painless compliance while managing your transition to the EMR, refer to our HIPAA Primer Series below. This series offers you in-depth insights into proven best practice policies and procedures that not only meet but exceed HIPAA requirements.

• HIPAA-Compliant Solutions for Health Information Challenges
• Proven, Trusted and HIPAA-Compliant Media Management
• The HIPAA-Compliant Approach to EMR Transition
• Records Management HIPAA-Compliant SolutionsThat Keep Your Compliant

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Unfortunately that’s the exact situation many healthcare organizations find themselves in today. A majority of your resources and energies are focused on making the explosive volumes of data entered into your EMR system more accessible and useful, meanwhile piles of inactive paper records sit idle waiting for their retention period to expire. Look I get it.  With so many pressing initiatives and so few resources, who has time to re-evaluate and re-organize legacy processes?  But the reality is, you don’t go back and redefine your approach to and policies around paper, you’re doing yourself and your organization a huge disservice.  The large paper archives you continue to maintain not only put a huge financial strain on your overall health information management budget but create an additional point of risk and exposure.  Furthermore, the fact that they are even still available often hinders EMR adoption. After all, why would your physicians bother learning to navigate the new EMR if they can still access the physical file fairly easily?

So what do you do?  Here are a few quick tips about how you can minimize your dependence on paper, accelerate your transition to the EMR, and drive down costs while you’re at it.

Centralize – and If you Can Get It Offsite, Even Better!

Centralization.  Often misconceived as an ugly word, centralization is a critical component of running a smooth hybrid environment – and accelerating your realization of the EMR’s benefits.  In order to streamline workflows and drive down costs you first have to know what you have, how it’s used, and what it’s costing you to manage it.  And that’s not just in your department or facility but across all departments and facilities in your organization.  By evaluating your program holistically and centralizing the storage and management of it, you will better position yourself to leverage economies of scale and standardize across the entire organization. This results in significant cost and process efficiencies.

To my next point, if you can centralize off site, even better. Why?  Two reasons.  One, consistency and two, adoption.  The reality is it’s hard to break bad habits and force the adoption of new ones when you can’t physically control and track behaviors.  By moving your records offsite, you force all employees to follow the same protocol to gain access to the records.  And, you give yourself a means by which you can track ordering and usage.  Many offsite models offer online inventory management systems that enable you to run reports on who is retrieving paper records and with what frequency. This allows you to understand the usage patterns and challenges impeding the adoption of the electronic record.  With this knowledge you can develop a strategic plan to alleviate any roadblocks and train any specific individuals impeding adoption.

Redefine Your Retention Policy – and Forever Doesn’t Count!

Holding on to records longer than required results in unnecessary risk, cost, and ultimately becomes a huge strain on your organization.  We all know why it happens.  With so many variables that must be considered – is it pediatric? is it mammography? when was the last date of visit? – the healthcare industry just may be the single most difficult industry to manage retention.

The only way to combat this complexity it to know what you have and the only way to do that is through indexing.  Easier said than done, I know, especially when you dealing with a hodgepodge of legacy archives and processes. But if you can put in the leg work to clearly define your policies and index you inventory in a standardized, legally defensible way, the effort will pay off tenfold. Not only will you drive down the cost of your overall program but you will free up significant space, budget and resources that can be diverted to other more critical tasks – such as EMR transition or revenue generation.

Adopt One Form of Delivery and Distribution – and that’s Got to Be Electronic!

The longer the physical records are available, the slower EMR adoption is going to be.  The reality is to get to a place where you are fully electronic; you need to minimize dependency on paper. That means transitioning the delivery of the physical record to the exception rather than the rule.  So how do you do that with while managing a hybrid mix of physical and digital records?  Of course, your electronic records are already in the system. But for those records requested that are still in hardcopy format, you simply need to scan them upon request.  Rather than retrieving the physical file and delivering the hard copy; retrieve the physical file, scan it into your ECM system, and retrieve it from your EMR.  This fosters a learned behavior and reinforces the EMR as your single and comprehensive source of information across the organization.

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It’s a topic I could easily spend hours discussing. However, at the risk of oversimplifying, it seems there are three clear and noticeable changes in the way the industry thinks about disaster recovery. One: Considerations are larger. Two: Expectations are higher, and finally, downtimes have simply got to be shorter. Let me explain.

• Considerations Are Larger: The information infrastructures in hospitals are larger and more complex than ever. Records are captured and stored in all in all formats – physical and digital – and, as result, organizations today must manage a myriad of highly complex workflows and an intricate network of IT systems and communication channels to ensure this information is securely protected yet readily available. That means in order to ensure the continuity of care, recovery plans now need not only to address how to protect and restore the information itself but also how to protect and enable the internal and external infrastructures required to transfer, access, and evaluate this information in the event of a disaster.

• Expectations Are Higher: Innovations and advancement in information technology today have bred new expectations – higher expectations. The notion that physical transportation or geographic limitations hinder ones access to information or services is long gone and far forgotten. In today’s world, businesses have two options – give it to me fast or give it to me now. That’s the reality – and it’s simply magnified in healthcare. Customers want and expect 24/7 service. But patients? Well, patients need it – and not just when the weather is good or the process is easy. 24/7 service and care is required and, to provide that, you need to ensure multiple stakeholders, across multiple locations have simultaneous and continuous access to all the information they need, when they need it, regardless of circumstance.

• Downtimes Have Got to Be Shorter: With organizations relying so heavily on electronic information, there is simply no room for downtime. Access has got to be immediate because today often electronic copies are the only copies – and moving forward that will become ever-increasingly true.  The days of people printing a hard copy for “safety’s sake” are swiftly becoming a memory. It’s not cost-effective.  It’s not green. And thanks to the advancements in data backup and recovery technologies, often, it’s simply not necessary.  Today electronic files are backed up as electronic copies. That means, in the event of a disaster, you are going to need ready access to your electronic information – not because it’s more convenient but because, more than likely, it’s the only kind of information you’ve got.

Like any big transition or change, EMR has created a ripple effect. It’s not happening in a bubble. It’s not an isolated change. It’s intensely intertwined with other systems and processes within your organization – including the disaster recovery planning process. Health IT is quickly advancing and we are already seeing the implications. Yes, today considerations are larger, expectations are higher, and there is a need for downtimes to be shorter. But keep in mind, this is just the beginning. As the EMR and the industry continue to evolve, so will the expectations and infrastructure demands that define the term disaster recovery.

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But let’s not forget, the requirements in place are not without good reason. It’s not process for the sake of process. Rather process for the sake of protection. The privacy and security of each patient’s sensitive information is at stake. Just one file can contain full name, social security number, date of birth – not to mention more private details such as health history, medical ailments and treatment delivered. Fallen into the wrong hands, this information can be devastating – or, quite frankly, just plain embarrassing.

As you know, these repercussions extend beyond the patients. Healthcare organizations themselves face significant ramifications should they encounter a privacy or security breach. And when I say significant, I mean SIGNIFICANT. Not only are their names subject to being publically splashed across what I like to call the “HIPAA Wall of Shame,” but they face considerable financial penalties. As a matter of fact, one of the largest settlements for a HIPAA violation to date amounted to $2.25 million – and that’s not including any civil money penalties that may or may not have followed.

So what am I getting at here? Compliance can be painful. You know it. I know it. We all know it. But what we cannot forget is just how far reaching and devastating the consequences non-compliance can be. Noncompliance puts your patients’ private information at risk, it puts your brand’s reputation at risk, and it puts your organization’s wallet at risk. All these things considered, maybe it is “HIP” to be compliant after all – and maybe we owe all those who dedicate themselves to ensuring it a big thank you.

In honor of HIP week 2012, let’s take a moment to thank those who go to such great lengths to manage sensitive health information securely and in compliance with many ever-evolving regulations. To all those involved, from HIM to the healthcare providers to Health IT – thank you, thank you, and thank you.

Looking for ways you can improve the safety and security of your patient information? Check out this HIPAA Best Practice Checklist.

The problem is, there is a still a lot of confusion in the market as to what constitutes a “true” VNA.  The market is riddled with me-too vendors making bold claims of neutrality when in fact their solution may not be “truly” vendor neutral at all.  Buzz words like “DICOM Archive” and “Super-PACS” are quickly thrown out but seldom clearly defined leaving you to decipher, “What classifies a true Vendor Neutral Archive?” and “What does good look like?”

The good news is there are resources out there to help guide you through your “due diligence” process. Articles such as “What is a Vendor Neutral Archive” clearly outline the capabilities and functionalities that characterize a truly neutral vendor archive.  Admittedly the reading can be a bit technical – a.k.a. painful – but it is without a question worth it.  With a better understanding of what a VNA should be able to deliver and the functionality required to make that happen, you’ll have a clear benchmark in which you can compare and contrast the various VNA solutions out there.  What’s more, you’ll be better prepared to ask vendors the type of questions necessary to expose the strengths and weaknesses of their solutions.  After all, HIMSS 2012 is in Vegas – what better time to call a vendor’s bluff?

Give the article a read and let me know your thoughts. And, if you’re interested in learning more, simply stop on by Iron Mountain booth #2558 to speak with me in person at HIMSS 2012.  And be sure to follow me on Twitter @MichellePaster and use the hashtag #HIMSS12 to follow the event.

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1. Negative Perception is Dispelling: It’s not just talk anymore. Early adopters (like Regional Medical Center in Memphis, Desert Radiologists in Las Vegas, Maria Parham Medical Center in North Carolina, and Rockford Memorial Hospital in Illinois) are continually proving the benefits of cloud technology in terms of accessibility, cost savings, and enhanced disaster recovery. What’s more, both the technology and the vendors (at least the good ones) have evolved. There are cloud storage solutions in the market today that are uniquely tailored to address healthcare-specific needs, particularly the requirements of HIPAA. As a result, misperceptions around data’s vulnerability or the lack of security in the cloud are dispelling.
2. The data boom is in full swing: Knee deep – or perhaps neck deep – in EMR transition healthcare provides are seeing exponential data growth that is becoming otherwise unmanageable using traditional archiving methods alone. The pains today are no longer prophesized, they are being realized. The complexity of managing the hybrid, or in some cases, the fully electronic environment, requires Health IT managers to update legacy processes and technology that supports them if they are to continue to meet accessibility, backup, and disaster recovery requirements.
3. Budgets are shrinking and cost cutting initiatives are growing: In today’s market, money is tight. With so many critical initiatives to support – ICD 10 Transition, EMR transition, and ACO development- healthcare organizations, much like everyone else, need to identify ways to do things better, faster, cheaper. Once dismissed as a costly solution to implement, people are beginning to realize that the long term year over year savings associated with cloud storage more than justifies the upfront expense – not to mention frees up some of your much needed resources to focus on the multitude of other critical business initiatives you’ve got on your plate.

We want to hear from you! How has your perspective of the cloud shifted in the last few years? And, do you anticipate any change in the tone or direction of cloud-based conversations at HIMSS 2012 this year? Jump into the discussion in the comments field below.

Going to HIMSS 2012? Learn how to Make Medical Data More Useful when you visit Iron Mountain at booth #2558 during the HIMSS 2012 Conference. And be sure to follow me on Twitter @MichellePaster and use the hashtag #HIMSS12 to follow the event.

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One can’t help but to question, if everyone is talking about it, why isn’t everyone using it?  My guess is that much like any new technology; cloud storage is a victim of the risk adverse buyer.  Many see value in adopting the technology but prefer to wait for early adopters to weed out the bugs and troubleshoot the problems. That way, when they finally do decide to implement it, they are getting the more refined, more efficient version.  It’s hard to argue with that strategy – but I’ve always liked a good argument so you can bet I’m going to try.

Take a look at the flip side.  The longer healthcare providers wait to adopt cloud storage, which will inevitably become the norm in the healthcare industry, the longer they will forego the benefits. And, let’s not forget, the technology has matured vastly in a very short period of time. Providers are using it today and already realizing significant benefits in the form of cost savings, improved accessibility, and enhanced disaster recovery. All that considered, is there really any significant benefit to being a laggard or late adopter?  I’d have to argue no.

I’m not alone in my thoughts on this.  In fact, a recent InformationWeek article featured Ken Rubin, VP of Healthcare Division at Iron Mountain, addressing this very idea.  In the article, Rubin candidly recognizes healthcare CIOs’ apprehension to adopting cloud services but continues on to strongly encourage CIOs to take a second look at the technology. Why? He believes that with consideration of 5 Key Criteria healthcare providers can not only begin realizing the benefits of the cloud today, but can do so while meeting HIPAA regulations. If you agree with Ken’s train of thought, as I do, then there would be no reason to wait. You’d simply be prolonging the time it takes to reap the rewards of cloud technology, and increasing the costs and headaches associated with managing your ever-growing volume of data in between.  But I suppose that’s the question, isn’t it? Where do you stand on the matter?  For those planning to attend HIMSS 2012, how seriously are you considering the adoption cloud storage for your organization?  If you aren’t, what is it most holding you back?

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Going to HIMSS 2012? Learn how to Make Medical Data More Useful when you visit Iron Mountain at booth #2558 during the HIMSS 2012 Conference. And be sure to follow me on Twitter @MichellePaster and use the hastag #HIMSS12 to follow the event.

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