Developing a protocol for disclosing protected health information can be complicated because of the communication involved and many employees with access to PHI, especially for large health systems, according to an article in the Journal of AHIMA. Instituting an enterprise-wide strategy can be helpful before expanding a health system to include more facilities, providing new members with clear outlines of how to treat PHI disclosure, according to the article.
Here are eight tips suggested by Collette Zeiour, health information management director at East Jefferson General Hospital in Metairie, La., who wrote the article.
1. Standardize information release processes. Staff members may handle PHI disclosure differently, which can lead to a variety of levels of disclosure, some appropriate and some not. To standardize the process, a health system should implement a standardized process and communicate with the staff to create a consistent workflow and ensure appropriate standards across the enterprise, Ms. Zeiour wrote.
2. Address workflow challenges. Separate departments in a hospital or health system may keep discrete tracking records, which must be centralized before implementing a standard process. All providers and staff should also be able to access a list of pending requests to keep everyone on the same page.
3. Examine technology differences. In larger health systems, some practices may use different EHR systems or other software. The differences may necessitate various disclosure procedures, including some locations using paper. Thus, the assisting vendor needs to evaluate when to pick up paper-based disclosure requests. Performing location visits to all practices and evaluating workflows allows evaluators to ensure that processes are compatible with all members of a health system, Ms. Zeiour wrote.
4. Get leadership on board in advance. Communicating with staff and physicians is much simpler if a hospital or health system’s leadership is united with one plan. Having executive leadership can convey urgency and the importance of the process as well as encourage staff to take it seriously.
5. Consult with IT staff about potential problems before implementation. There could be a potential hangup in a process that would not be obvious to a hospital executive not trained in IT. Bringing in the IT department before implementation to work through issues in workflow can help identify and correct problems before they even arise.
6. Prioritize communication and training after implementation. A team will need more communication and check-ups during the initial implementation to ensure that everyone is comfortable with the new process. Even after everyone is comfortable with the new policy, administration should still offer venues for feedback to provide ongoing monitoring of how well the policy is operating.
7. Offload and centralize PHI disclosure management tasks as much as possible. Removing the majority of the burden from providers frees them up to do other tasks. Implementing an enterprise-wide approach with more tasks centralized to a management office and offloaded to a vendor can eliminate potential confusion and errors and mitigate risks.
8. Manage tracking and reporting capabilities. Tracking when records are released is key to making sure the protocol is working properly. If a recipient says he or she did not receive the document, a health system needs to be able to track down the document and determine why it was not received. Tracking is a priority, and the features must be evaluated when determining a policy.
