LESLIE: Today we speak with Melissa Martin, RHIA, CCS, on the challenges of information and data governance. Melissa is the chief privacy officer and director of Health Information Management for West Virginia University Hospitals (WVU Hospitals), a 531-bed tertiary care system that has been nationally recognized as a level 1 trauma center and received the Magnet recognition for nursing. WVU Hospitals includes Ruby Memorial Hospital, WVU Children’s Hospital, Jon Michael Moore Trauma Center, Chestnut Ridge Hospital and University Healthcare. WVU is also a member of the West Virginia United Health System.
PATTY: I think health information management leaders have a golden opportunity today to influence the information governance agenda. It’s a time when senior leaders know information governance is important, but they are dealing with competing priorities. In the absence of a regulatory mandate, information governance is slow to become top of mind.
LESLIE: I often hear the terms information governance and data governance used interchangeably. Is there a difference and is it important to make a distinction?
PATTY: These terms are often used interchangeably. I try not to split hairs about it because I think the meanings of these terms are often dependent on one’s perspective and their own role within an organization. In general, I think of information governance as a policy framework that guides an organization’s behaviors around data creation, quality, storage and access. The framework includes data governance. AHIMA explains the differences in this way: Information governance (IG) is the responsibility of executive leadership for developing and driving the IG strategy throughout the organization. IG encompasses both data governance (DG) and information technology governance (ITG).
Data governance is the responsibility of the business unit. It is the policies, processes and practices that address the accuracy, validity, completeness, timeliness and integrity of data (data quality).*
LESLIE: I have always thought that it’s important to understand healthcare language and definitions, especially around complex issues, so we are all talking about the same thing.
PATTY: To the extent we can be clear about language in our discussion we should!
LESLIE: I want to also reinforce that HIM professionals have always been the stewards of health information regardless of the information format. This includes working within our organizations to set and implement health information management policies and procedures including rights and responsibilities, which is the focus of any good information governance strategy.
MELISSA: Being a health information steward today is substantially bigger than pre-electronic health record (EHR) because the expectations for information and data governance encompass all data within the healthcare system, even data captured, accessed, and stored outside of the EHR.
PATTY: How did your organization begin to address information governance?
MELISSA: It’s a challenge particularly in a health system environment like ours that includes teaching and community-based hospitals and physician practices. Given our focus on teaching, research and quality we have a culture that values information and leveraging data assets. We also work in a multidisciplinary way as often as possible, which helps to get buy-in across the organization. For example, a taskforce developed and implemented the JCAHO information management standards, which is a set of policies and procedures that we leverage today as the foundation for our information and data governance strategies.
PATTY: That is a great idea Melissa. It makes so much sense to leverage an existing information management plan as part of your overall information governance framework.
MELISSA: We developed a broad detailed plan and worked with the information technology department to implement it. The plan outlines the avenues in which we get information, where we get it, and the rules and regulations around it. Although the information management plan was developed originally in response to complying with JCAHO Information Management (IM) standards, today, in the absence of information governance regulation, we continue to use it as a springboard for our information and data governance strategy. Our information management plan has been widely shared across our health system and has a lot of support to date across departments.
PATTY: If an organization wanted to dust off their JCAHO IM policies as a place to start, where do you recommend they begin?
MELISSA: I suggest they first identify what they want to govern. The plan likely already outlines much of what needs to be governed. Then you just need to fine-tune the plan and put rules and more structure around it, primarily to account for more data outside of the health record itself. As I said, information and data governance is not just about the EHR anymore but all the data collected and stored within a health care system.
LESLIE: Tell us a little bit about the HIM department Melissa.
MELISSA: There are 170 employees in the HIM department and we are growing quickly. For example, I will request approximately 20 additional coders in preparation for ICD-10. I work closely with four managers: two coding managers, a transcription manager and a manager who oversees registries, master patient index integrity, release of information and other core HIM functions. Most recently, three employees have evolved from MPI coordinator positions to data integrity positions. They perform MPI data corrections and auditing on copy paste/forward, and identity theft. For me this is just the tip of the information iceberg and the beginning of the department’s transformation toward data governance.
PATTY: What do you see as next steps in the department’s transformation?
MELISSA: I recently received approval and funding to conduct an information governance and data governance audit. I am starting with an assessment so that I have a better sense of gaps in our governance programs as well as an appreciation for what we have in place already. I think we have many practices in place but just don’t have contemporary labels for what we do to ensure integrity and act as health information stewards on behalf of the organization and the community we serve.
LESLIE: Sounds like a good idea to start with an assessment. Everyone probably has bits and pieces already. Do you have an example of something you have already changed?
MELISSA: The old medical record committee for example is now known as the Legal EHR committee. We recently added a few additional members and broadened our agendas beyond the EHR. The committee is led by a physician and includes among its members individuals from Quality, Compliance, and Legal. We have expanded our focus beyond medical records to include all data.
LESLIE: What is the role of the information technology (IT) department in information governance?
MELISSA: The IT leaders in our system appreciate that information governance is not an IT project and also don’t see it as an IT responsibility. However, I understand that in some organizations gearing up for information governance planning, the organizers look to IT for leadership or support, and it is not unusual for decisions to be made without the involvement of HIM and other key stakeholders. My hardest lesson learned is that HIM wasn’t involved early enough in the decision making, and we didn’t sense ownership in the early stages of discussion. It’s very hard to implement data governance after the fact. If HIM had been involved in the early stages of planning for example, we could have addressed the pros and cons of copy paste/copy forward and provided guidance on managing electronic problem lists and medication lists. We have a strong focus on the legal record throughout the system, yet we trained people how to use copy paste/copy forward without taking into account the impact to data quality and the legality of such practices. EHR training focused on functionality and not always on data quality or compliance.
PATTY: I would like to take a deeper dive into the copy/paste, copy/forward issues, but we are getting to the end of our conversation for today. Shall we continue next month?
MELISSA: That would be great. I can also share with your readers information about our data governance dashboard, and we can debrief on the highlights of AHIMA’s Health Integrity Summit too.
LESLIE: That sounds like a great plan. But before we end for today, Melissa, what advice do you have for our readers on leading the way to information and data governance?
MELISSA: I would say keep an open mind and take one step at a time. Information and data governance is a natural progression and we don’t need to be afraid of what we might not know. The same principles that have guided the HIM profession are still relevant today – a focus on the design and capture of information, how we manage, store and protect the content of health records and how information is used and reported.
Leslie Ann Fox is chief executive officer and Patty Thierry Sheridan is president, Care Communications Inc., Chicago. You can follow Leslie and Patty on their Twitter accounts, @FoxatCARE, and @pattytsheridan. Leslie and Patty invite readers to send their thoughts and opinions on this column to lfo[email protected] or [email protected].