Information-blocking compliance is like a jigsaw puzzle. It’s got many different pieces requiring collaboration across Information Technology (IT), Health Information Management (HIM), paperwork, privacy, legal, medical, and nursing. This complexity alone would make complying difficult.
But now consider that the puzzle pieces keep constantly changing. Over time, software changes. Internal paperwork changes. Regulations and contracts change. Employed and independent doctors change, and so do nurses.
So, putting the pieces together once is just a temporary solution. Next week, next month, next year, another piece is going to change – leaving you to lead your cross-functional colleagues in a game of catch up. It’s a chronic, rather than an acute, challenge that calls for continual attention from leaders across your organization.
Establishing an oversight team
Like most complex regulatory issues, Compliance can provide excellent leadership but needs partnership from a team of involved leaders. An information blocking oversight team should include the following roles:
- A Compliance Department member.
- Project Manager – If your organization is large enough, you’ll have a project management department, and one of its members can lead the team. If not, then maybe someone from HIM or IT, which are most directly involved with recording and sharing patients’ health information.
- HIM representative – who by definition is most directly involved with the health information that’s gathered and stored.
- IT representative, for expertise on your system for electronically storing and sharing that information. This team member will also know about new upgrades, plugins, etc., that will change the way your data system functions.
- A Registration Department representative. Registration is responsible for processing the intake forms that supply your HIM systems with patient and demographic data.
- A Legal representative, for questions involving contracts and risks.
- A Physician Liaison – Your Chief Medical Officer or Medical Department Head combines administrative skills with the perspective and ability to bring the other physicians on board.
- Nursing and Clinical Department leaders, who bring the same admin and leadership skills to their departments.
Having broad representation ensures your program involves the right players from the start. It also helps equip those leaders to communicate policy, procedure, and systems changes to their teams. These champions can help embed a culture of transparency and compliance across functional areas.
Managing the information blocking oversight team
Once you’ve picked your team, it’s time to establish your goals and norms. To facilitate a productive working dynamic, decide together how often to meet and for how long. The very first meeting is the time to brainstorm what, specifically, needs doing and by whom. Each team member can identify and take ownership of compliance problems in his or her own area. If there’s overlap, team members from the departments involved can work together.
From your brainstorming, the team should be able to develop a plan for your ongoing compliance efforts. That way, the whole team knows their roles, and each is accountable to the others to move forward. YouCompli offers task management and reporting features that can help keep compliance efforts on track, even with multiple players. See how YouCompli helps you manage your compliance workflow.
Accounting for information blocking compliance across the organization
One benefit of working as a cross-functional team from the beginning is that you can plan for all the different components of information blocking compliance. The very matrixed to-do list of an oversight team looks something like this:
- Software compatibility – If your HIM uses multiple platforms, what effect will upgrades in one have on its ability to work and play well with the others? If there are problems, what workarounds will solve them?
- Completeness – Patients’ Electronic Medical Records (EMR) cover most of their health information – but not all of it. Physical therapy and radiology, for example, use different software to document clinical care, so feeding their information into the main EMR may require workarounds. Some of those may be very low-tech, like printing out the information and scanning it into the main EMR. Make sure your policies and procedures account for this. (Widely applicable model policies and procedures from YouCompli can help get you started.)
- Education and training – The best compliance policies are worthless if the people who deal with patients and their records don’t understand them. Your team should decide who needs to know which rules and how to apply them, and who does the training. Don’t forget your employed and independent physicians. Draw up a list of frequently asked questions and information for everyone on staff that interacts directly with patients. That way, they’ll know how to respond to patients’ EMR requests.
- Exceptions – Make sure you have a written policy on how to respond to information requests that fall under the CURES Act’s information-blocking exceptions. And make sure everyone who works with patients understands the policy and knows how document denials of access in the patients’ EMRs.
Like I said up front, information blocking compliance is especially tricky. The rules and the technology change so frequently. But by starting with a collaborative team, you can future-proof your efforts. When changes do come, you’ll have the right people in place to solve for the changes and to embed new practices throughout your organization.
Model policies and workflow management are just two features of the YouCompli solution that can help you stay on top of information blocking and regulatory change management. Request a demo today!