Hospital and physician group consolidation is increasing the heterogeneity of EMR systems under one roof.   New hospitals want to integrate the clinical data with other hospital systems, and create patient monitoring solutions and dashboards.

Health plans as well as hospitals can benefit from a well thought out integration strategy.

Electronic Health Records (EHR) or Electronic Medical Records (EMR) integration approaches depend on the strategy and priority in exchanging patient information between various healthcare applications, and the standards available:

Standards and approaches for EMR and EMR Integration

• HL7 – A set of standards for structuring and exchanging clinical data. ASTM is an alternative standards group and both have their own vested interests and objectives.
• HL7 CDA – XML-based exchange model for clinical documents (for example, progress notes and discharge summaries)
• CCR – Continuity of Care Record – is an XML-based standard focused on organizing a transportable set of information about a patient’s health care that is accessible for both patients and clinicians.  The CCR was created by ASTM International, Massachusetts Medical Society (MMS), HIMSS , the American Academy of Family Physicians (AAFP),  American Academy of Pediatrics (AAP), and other health informatics vendors. It was designed to contain the most relevant and timely core health information about a patient.  It has been adopted by healthcare application vendors, including Google for its Patient Health Record.
• CCD - this combined Continuity of Care Document – A blend of the CDA and CCR standards as a result of harmonization of standards in 2007.  Currently, CCD is being phased into EMR certification standards by CCHIT. It is an HL7 standard whereby a patient’s current clinical context is expressed in the framework of the Clinical Document Architecture.
• ELINCS – EHR-Lab Interoperability and Connectivity Specification  – A standard for lab test results
• EMR Vendors – Depending on the vendor, both proprietary and standards based specifications integrating with data fields in the vendor specific application

Integration Strategies and Best Practices

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Some health care organizations are now looking for “…A good ICD-10 project manager…” to lead the ICD-10 effort.   This appears for some to be budget driven.  Rather than retain an outside consulting firm, some health care companies want a project manager who can deal with the regulatory, payor and provider contracting, physician outreach experience, medical policy, IT, EDI, medical coding, process impacts, revenue cycle, predictive analytics, workflow, data warehouse, business intelligence, and other areas of this complex mandate while costing less than an outside consulting firm.

There are three issues with this approach.  First, we know of no project manager in health care who brings all of these competencies together as one resource.  ICD-10 hasn’t been implemented yet by anyone, and usually a project manager’s role is in part driving to a delivery schedule, not having the regulatory compliance skills for example to know if that schedule is cutting corners and putting the health plan or hospital system at risk.

Second, all of the expertise to successfully transition to ICD-10 does not usually reside within any single payor or provider.  ICD-10 tends to bring new responsibilities to already busy stakeholders, operational, medical and IT resources who are needed to keep the business running.  ICD-10 organization strategy would suggest first determining where you have weaknesses and hiring to those weaknesses, or seeking these resources from outside consulting firms if needed.

Third, organizations that want a project manager and sometimes an inexpensive one at that, risk a much bigger reimbursement or regulatory impact if they get ICD-10 wrong.  For example, health plans who fail to comply risk fines of up to $1.00 per covered life per month.  Hospitals risk a shift of reimbursements that may not be in their favor.  For example, one $800 million hospital we work with determined that it could easily see a minimum of a one percent (1%) reimbursement risk or $8.0 million if ICD-10 is implemented without proper planning.  That cost is so high that the risk that the hospital system would be exposed to called for a different approach.  The hospital has determined that micro managing their recruiting and worrying about saving $15.00 per hour on the right project manager without putting together a team with internal and external competencies would be  a costly mistake.

One of our clients told us that they didn’t need a review of HIPAA 5010 and ICD-10 impacts on their dental insurance business because dental wasn’t covered under HIPAA.  We politely asked if they had heard of the 837D EDI transaction, specifically for dental.  Given that it is an EDI eligibility transaction, their dental business is absolutely regulated under HIPAA.   The corporate attorney for the client as well as the HIPAA expert legal counsel for the client somehow missed this point, clearly stated in Title II of the HIPAA regulations.  While dental was a small part of the overall business, the health plan would have been putting their primary multi-billion business at risk of serious fines had they gone ahead with their plans based on their internal assumptions.

Our approach has been to provide “PMP+P” – project managers with PMP certifications PLUS a team of experts who are fractional resources that can be called upon by the project manager and the client for the expertise needed in the competencies to deal with ICD-10 implementation.   One good project manager can help.  A PM backed by experts is better and more cost effective than worrying about the pennies or on the other hand completely outsourcing something that in the end health plans and providers themselves will be accountable for.  We think this is the best ICD-10 implementation approach.

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