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When is the PHR the LHR ? PRESENTED B Y: Joan Beach CHW Privacy Official The Privacy Symposium Sixteenth Annual National HIPAA Summit August 20, 2008 Cambridge, MA When is the PHR the LHR? The Personal Health Record What is a Personal Health Record (PHR)? • A personal health record (PHR) is a confidential and easy-to-use tool for managing information about your health. A PHR is usually an electronic file or record of your health information and recent services, such as allergies, medications, personal medical facts, and doctor or hospital visits that can be stored in one place, and then shared with others, as you see fit. You control how the information in your Personal Health Record (PHR) is used and who can access it.¹ • Email messages ¹ Available at http://www.medicare.gov/PHR/Overview.asp 1 When is the PHR the LHR? What Components are valid? • Continuity of Care Record - CCR ¹ Problems Encounters Family History Functional Status Social History Plan of Care Allergies/Alerts Payers Medications Medical Equipment Immunizations Advanced Directives Vital Signs Health care providers Results Non-professional caregivers Procedures ¹Developed by American Society for Testing and Materials (ASTM) 2 When is the PHR the LHR? • Standardized Format – HL7 Reference Information Model (RIM) – Continuity of Care Document (CCD) • – • Similar to CCR with an additional Identifier Agreement reached to work with ASTM (XML) to combine CCR & CCD Common Platform Components (CPC)¹ – – Functional Requirements (Elements) Technical Requirements (Architectures) ¹Availabe at www.PojectHealthDesign.com 3 When is the PHR the LHR? User Community • Consumers – Increased Mobility – Computer and Internet Acceptance • Graying of America • Insurance Companies – Kaiser Permanente – My Health Manager • https://members.kaiserpermanente.org/kpweb/toc.do?theme=myhealthmana ger_members – Aetna – SmartSource (CareEngine) • https://www.aetna.com/member/ 4 When is the PHR the LHR? Vendors • Google Health – Sharing Information – “Google Health contains a directory of third-party websites that are capable of securely sending information to Google Health. These websites (which may include your medical provider) may give more information about certain conditions or extend the functionality of Google Health in other ways. By creating a link to these websites, you give them permission to send you information such as medical records, prescription histories, or test reports. – You can approve access for some of these websites to view your health information. If a website accesses your health information and stores a copy of your information, that copy will be governed by that website’s privacy policy. Others at that facility – like an on-call doctor – may be able to view your information. Google is not responsible for the content, performance, or privacy policies of third-party websites. “ 5 When is the PHR the LHR? Vendors, cont. – Microsoft HealthVault PHR - http://www.healthvault.com • Connection with Hospitals – iHealth Record - http://www.ihealthrecord.org/ • Allscripts • Google Health • Regulatory Agencies – Medicare PHR Recommendation -myPHR.com (AHIMA) - http://myphr.com/ 6 When is the PHR the LHR? Value of the PHR • To Consumers PLUS Desire for Control of Healthcare MINUS Don’t forget the healthcare professionals knowledge is still key Establish & Maintain Goals Manage who is allowed Access (family members, providers, insurers) Relationships change. No assurances information was not saved by others or printed into hard copy. Use discretion when permitting access. Allows for Accumulation or a variety of healthcare resources Increase exposure of PHI to thirdparties. Awareness of data security is key. Test Results available Providers & Insurers must participate Centrally located Limited access to Internet regularly 7 When is the PHR the LHR? Value of the PHR • To Providers PLUS MINUS Reduce Unnecessary OV New Task- Email Reduce Phone Calls 24/7 Expectation Prescription Refills Ongoing Family History Requires Frequent Review for new details Appointment Management Requires Practice Management Application Integrated Record Validation of Health Status Required:” Can I trust the information as fact?” Data Retention requirements: “ What happens when the Patient disassociates?” 8 When is the PHR the LHR? Value of the PHR • To Insurers¹ PLUS Reduction in Medical Errors MINUS All parties involved in care must participate in PHR Key to prevention and maintenance of chronic conditions Conduit to provide wellness and other If access cannot be limited to program announcements specific health information individual privacy rights in jeopardy Portability from one insurer to another Fear of premium adjustment ¹ http://www.ahip.org/search/default.aspx 9 When is the PHR the LHR? Value of the PHR • To Regulatory Agencies¹ PLUS MINUS Availability of records during a Disaster Standards for accumulating information must be followed or value is diminished Resource for Public Health – Background information related to certain disease categories Fear governmental agencies will have “too much” information about individuals Development of Health Risk Appraisal Consumer concerns may be used for consumer health management for purposes of Research without consent ¹ http://www.insurance.ca.gov/0400-news/0100-press-releases/0070-2008/release040-08.cfm 10 When is the PHR the LHR? Proxy PHR Users • Determination Requirements – Varies from State to State – Documentation is not always required – Verification prior to communicating • Ownership of Relationship – Consumer is the ultimate owner • Maintaining current relationship access – Insurers, Providers may share Responsibility if integrated 11 When is the PHR the LHR? Electronic Messaging within the PHR • Patient to Provider / Provider to Patient – Secure Messaging capabilities (iHealth) • Encrypted • Patient education for appropriate use – non-urgent only – Clinic vs. Acute Care Setting – Establish Reporting Periods • Patients with chronic conditions can report to the provider on a pre-arranged schedule – Prompt Response is key • Billable Services – Patient Education • Must understand when a communication becomes a “Visit” • Ability to Refuse – Insurance Verification – Patient Pay – Accounts Receivable Management 12 When is the PHR the LHR? – EXAMPLE LHR Data Viewing Source Systems ADT Demographics (IDXtend/ FlowCast) Laboratory (Cerner Classic) Pathology (PathLogics ) Pharmacy (Extreby) Radiology I n t e r f a c e Partial Electronic Health Record Clinical System Repository CIS ALLSCRIPT/ TouchWork (RadNet Emageon PACs) Transcription H&P, OP Reports, Consultations, Clinic Notes (MedQuist) Paper Documentation / Optical Archiving Front Cover Summary/Med List Handwritten Clinic Notes Handwritten Progress Notes Handwritten Nurses Notes/ Orders Handwritten Ancillary Notes Laboratory-Anatomical Laboratory-Clinical Diagnostic Imaging Other Handwritten Documentation Hospital Records Consents Advance Directives Outside Record Online Data Entry Current State= CIS On-Line Clinical Documentation E-Sign CPOE Assessment Nursing Notes Vital Signs Ancillary Notes Physician Clinic Notes Hybrid Legal Health Record H-LHR Paper/ Optical Imaging ALLSCRIPT/ TouchChart Stand Alone Applications Home Health (Misys) Elysium (Data Repository) 13 When is the PHR the LHR? – EXAMPLE LHR + PHR Data Viewing Source Systems ADT Demographics (IDXtend/ FlowCast) Laboratory (Cerner Classic) Pathology (PathLogics ) Pharmacy (Extreby) Radiology I n t e r f a c e Partial Electronic Health Record Clinical System Repository CIS ALLSCRIPT/ TouchWork Online Data Entry Current State= CIS On-Line Clinical Documentation E-Sign CPOE Assessment Nursing Notes Vital Signs Ancillary Notes Physician Clinic Notes (RadNet Emageon PACs) Transcription H&P, OP Reports, Consultations, Clinic Notes (MedQuist) Paper Documentation / Optical Archiving Front Cover Summary/Med List Handwritten Clinic Notes Handwritten Progress Notes Handwritten Nurses Notes/ Orders Handwritten Ancillary Notes Laboratory-Anatomical Laboratory-Clinical Diagnostic Imaging Other Handwritten Documentation Hospital Records Consents Advance Directives Outside Record Hybrid Legal Health Record H-LHR iHealth Health Profile Prescription Requests Email Messages Validation Paper/ Optical Imaging ALLSCRIPT/ TouchChart Stand Alone Applications Home Health (Misys) Elysium (Data Repository) 14 When is the PHR the LHR? Concerns • Technology Compatibility – Not all EMRs are Built the Same! • Once a patient “connects” with a provider information is considered “available”. • Knowledge of information that is not utilized elevates risk for liability – PHR includes allergies not included in the clinicians chart – Clinician accepts PHR connection – Prescribed medication causes and adverse event • AB1298 – Who is responsible when a Breach occurs 15 When is the PHR the LHR? Ongoing Dialog • “World Wide Web” = World Wide Access • Ownership = Does it mean Responsibility for Data Security? Confidentiality? Integrity? Availability? • Do Consumers perceive the PHR as a value added experience? “When consumers are comfortable with an activity, such as they were with searching for cause and treatment information, their perceived effectiveness is higher, their trust is higher and their likelihood to exhibit desired behavior is higher—all by significant margins. Sites that expect end users to perform activities that are less familiar than healthcare information searching are going to have to be simpler and easier to use.”¹ ¹”The Consumer Experience of Online Healthcare” available at: www.changesciences.com 16 When is the PHR the LHR? Conclusions • No Clear Standard – Entities must analyze value to current business – Model of the LHR “Hybrid” • Keep it Simple – Consumer Awareness of liability – Manage partnerships : How many PHR flows can a Covered Entity manage? 17