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Exhibit A

Exhibit B The Business Case for Comprehensive EHR Standards

Background and Support

The HIPAA-inspired investigation being performed by NCVHS is timely and reflects similar processes going on around the world. For example, the National Health Service in the United Kingdom has recently published a manifesto detailing a comprehensive informatics approach for the next decade that deals with many of the same issues:

“Better care for patients, and improved health for everyone depend on the availability of good information, accessible, when and where it is needed.”

“To provide… the most modern tools to improve the treatment and care of patients and to be able to narrow inequalities in health by identifying individuals, groups and neighborhoods whose health care needs particular attentions.”

“To ensure that patients can be confident that … professionals caring for them have reliable and rapid access, 24 hours a day, to the relevant personal information necessary to support their care.”

“To provide every … professional with on-line access to the latest local guidance and national evidence on treatment, and the information they need to evaluate the effectiveness of their work and to support their professional development.”

--- “Information for Health – An Information Strategy for the Modern NHS”, U.K. National Health Service, September 1998

Similarly, the Joint Commission on the Accreditation of Health Care Organizations has increasingly identified information as a key tool:

Information as a Key Resource

“[A provider] organization’s provision of health care is a complex endeavor that is highly dependent on information. This includes information about the science of care, the individual patient, the care provided, the results of care, and the performance of the organization itself. Because many individuals and departments within the organization provide care, their work must be coordinated and integrated. Because of this dependence on information and the need to coordinate and integrate services, health care organizations must treat information as in important resource to be managed effectively and efficiently. Managing information is an active, planned activity.

“Information management is a function - a set of processes and activities - focused on meeting the organization’s information needs. Its goal is to obtain, manage, and use information to enhance and improve individual and organization performance in patient care, governance, management, and support processes.

“Information management processes [are the focus] of organization-wide planning to meet internal and external information needs.”

--- JCAHO

The Business Case

There is a strong independent business case for establishing “uniform data standards for medical record information and the electronic exchange of such information”. Properly executed, such standards could be expected:

• To provide a trusted information source and resource. This is particularly important from the perspective of key stakeholders: patients, health plan members, providers, practitioners/caregivers, payers, accreditation and oversight agencies, public health agencies, researchers, and others.
• To facilitate the right information to the right people, when and where needed. Timely, accurate information serves as the basis for the best possible care.
• To ensure standards of clinical practice, service and performance.
• To ensure trusted record stewardship, for health records and their companion records:
  • Master patient/member registry/index;
  • Patient (member) health record: individual; family; group
  • Provider operations (business) record: organization, business unit;
  • Practitioner service record: individual; group.
• To ensure trusted health record stewardship, for:
  • Data at rest (data stores);
  • Data in transit (communication);
  • End to end data flows: source to consumer, longitudinal chain of custody, front-end (point of service) to back-end (e.g., repository) to third party.
• To ensure privacy and confidentiality protections for subjects of health records, both individual and organizational.
• To ensure the rights, privileges and responsibility (accountabilities) of health record subjects.
• To ensure health record access is limited to authorized individuals with a “need to know”.
• To ensure access is granted according to the security and access control policies and procedures of the controlling health record steward.
• To ensure disclosure of health record content is according to permissions granted by applicable patients, health plan members, individual and organizational providers, practitioners, caregivers and others in accordance with controlling legal and regulatory requirements.
• To provide lifelong, longitudinal, individual electronic health records. Properly constructed, such records will be patient centered, designed to be responsive to patient needs, and not constrained by/to organizational and business unit boundaries.
• To promote optimum care delivery, both reactive (to existing health conditions) and proactive (preventative, wellness).
• To provide population based health record derivatives for clinical research.
• To ensure on-line immediate, secure access to health records. 24 x 7 x 366 (and post Y2K) availability.
• To integrate information seamlessly across the clinical continuum: preventative/wellness, home health, ambulatory, acute, emergent, and long-term.
• To ensure information clarity and integrity: legibility, accuracy, consistency, continuity, completeness, context, and comparability.
• To ensure accountability:
  • Of individual persons, of business units, of organizations;
  • For provision of health (care) services;
  • For access to, or duplication of, health record content;
  • For authorship, transcription and/or verification of health record content;
  • For disclosure of individually identifiable health record content;
  • For transmission and/or receipt of health record content;
  • For translation of health record content (e.g., linguistic translation, coding scheme translation).
• To coordinate the expertise of multiple clinicians, sometimes over great distances.
• To enable best business and clinical practices based on national, regional and local guidelines.
• To provide decision support tools, both clinical and operational.
• To ensure immediate access to clinical guidelines, best practices, medical literature and other information resources
• To improve the effectiveness of clinical care.
• To optimize operations and efficiencies in the health delivery process.
• To reduce redundancies and duplications.

The industry had been slowly awakening to the opportunities represented by the accomplishment of this important task. Thus both the mission and the timing of the NCVHS Sub-Committee in this area is particularly auspicious.