In today's data-driven healthcare environment, managing legacy data has become a significant challenge as organizations implement new clinical and financial information systems. Moreover, the demand for new and historical data means ensuring proper data integrity, retention, disposition, availability and compliance -- critical components of information governance (IG).
Organizations are struggling with pressing questions related to their data needs: Retain or retire legacy systems? Convert all data to a new system? Migrate and archive certain data to a centralized third-party solution? How to ensure access to meaningful clinical and financial data while meeting mandates for access and retention? Quality data is needed for measuring quality care and financial metrics. Healthcare leaders must mitigate potential risks of legacy systems, which may include increased costs, operational inefficiency and lost revenue.
Risks and Right Decision Making
When implementing a new system, the inevitable push to go live according to deadlines often takes precedence over determining what to do about legacy systems. Fear of losing vital information is a big factor driving the decision to retain old systems -- and redundant data -- despite the risks:
• Increased cost of retaining information you can't access or support.
• Difficulty responding to requests -- need to update technology to retrieve data and make it available.
• Inconsistency in use and access to data in different systems -- corrections made in new system may not match data in legacy systems.
• System failure and loss of vendor support -- consulting costs to resolve issues, maintain data access.
• Overall operational inefficiency and lost revenue.
Organizations must decide what information to retain, how to maintain it and how to properly dispose of it when the data is no longer needed. Making decisions to keep or decommission legacy systems involves aspects of information governance to determine the following:
• Who the stakeholders are.
• What systems you have.
• What data is in each system.
• How data is used.
• Where and how long to store it.
While compiling this type of report can be challenging -- especially for large health systems -- it is absolutely necessary. Once the decision is made to decommission a system, organizations must follow regulatory statutes and internal guidelines to ensure the ability to access and retrieve information throughout the retention period.
A Collaborative, Proactive Approach
Creating a proactive plan for managing legacy systems is essential. Don't wait until your facility activates a new system to decide what to do about legacy data. HIM professionals can lead a "grassroots approach" by engaging IT and executive leaders to help convey the importance of IG to all stakeholders involved.
SEE ALSO: Information Governance Adds Value to Resource-Restricted Healthcare Organizations
If starting an IG program seems daunting amid competing priorities, begin with a collaborative "work group" so oversight decisions about legacy data are made among all stakeholders, not in silos. Gaining traction around common concerns is important, particularly related to value-based care-providing quality care while reducing costs. For example, engage your CIO about IT support costs to maintain multiple legacy systems, which in some cases are estimated at more than $2 million per year.
Judicious management of restricted resources is crucial. To initiate or strengthen governance practices, here are steps to consider:
• Assemble an oversight team -- include legal, compliance, clinical, financial, IT, HIM, privacy and security as part of a grassroots approach. Identify and engage all stakeholders.
• Take an inventory of systems -- determine what data you have, where it is, how it's used, when systems went live and when you stopped entering data.
• Understand how clinicians are using data -- convert what is clinically relevant while trying to avoid accessing multiple systems.
• Consider regulatory research, audits and other reasons for retaining older data. Review your legal health record policy to ensure adherence to your organization's requirements.
• Conduct a cost analysis -- identify technology implementation/maintenance costs based on various options (retain, migrate, archive, retire). Identify hidden costs such as additional staff training and IT support for aging systems. Determine potential cost savings.
• Consider a repository or archiving option that allows real-time access to all data during the conversion process.
• Ensure easy access to documentation from legacy system vendors.
• Adhere to retention requirements -- make decisions and recommendations based on regulatory mandates and internal policies and procedures to ensure compliance.
• Establish a manageable governance process with ongoing input from stakeholders.
HIM Leadership -- a Catalyst for Change
Bringing the right people to the table at the right time to proactively manage legacy system decisions sets the stage for positive outcomes. HIM professionals have the expertise and leadership ability to weave in the IG components during the collaborative process.
As year 2017 unfolds, we'll focus on real-world experiences and lessons learned from organizations that are gaining ground with IG practices. Under HIM leadership, small steps in the right direction can serve as a catalyst for evolving an IG team that eventually expands across the enterprise.
Guidelines for Retention of Healthcare Information
Here are guidelines for a retention program, according to AHIMA's IG Principles for Healthcare based on a lifecycle approach-monitoring information from inception to final disposition. Organizations should maintain information for an appropriate time, considering legal, regulatory, fiscal, operational, risk and historical requirements. Create a retention program that ensures the ability to:
• Properly retain all relevant information, as organizations create and store vast amounts of mostly electronic data.
• Retrieve and access all types of stored information throughout its retention period, including clinical and nonclinical information, regardless of storage medium.
• Control information volume through a retention program that defines what information to retain, how long to maintain it and how to dispose of it when it is no longer required.
• Create and maintain an information retention schedule that specifies what information must be retained and for how long.
• Make retention decisions based on the type of information and the organization's legal, regulatory, fiscal, operational, clinical, role/mission and historical requirements.
Mary Beth Haugen, MS, RHIA, is the founder and CEO of Haugen Consulting Group and Haugen Academy. She has more than 30 years of experience in the healthcare industry. Mary Beth is active on the AHIMA Leadership Advisory Panel, AHIMA's Academic Task Force and is the current co-chair of CHIMA's Education Committee. She previously served as a board member for AHIMA and the AHIMA Foundation, and as a member of AHIMA's EHR Practice Council. She also serves on Regis University's HIM Program Advisory Board. Mary Beth received the CHIMA Distinguished Member Award in 2009. Haugen Consulting Group is the proud recipient of the 2015 CHIMA President's Award and 2015 Colorado Company to Watch. Mary Beth earned her bachelor's degree in Medical Records Administration from Saint Louis University and received her master's degree in Health Services Administration from Regis University in Denver.