Healthcare Mergers and Acquisitions have a Profound Impact on the need for Information Governance (IG)

James White

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One of the more significant healthcare trends we see today is the consolidation (Mergers & Acquisitions) of hospitals, physician groups and insurance companies into larger integrated systems. The goal of this activity have been focused on: increased market share, increased financial stability, better service to the patient and community needs and procurement of additional services. It has been well documented that these goals have been reached in some organizations but at the same time many others have failed to achieve these goals in the timeframe they originally expected.

Mergers and acquisitions are very complex in nature and carry forward many unintended consequences that are not discovered in performing due diligence. In my 39 years as a health information professional I have been involved in several M&A’s and in most cases due diligence does not come with much time to perform it. I usually was given only enough time to find high level “red flags” as it pertained to my area of responsibility—Health Information Management. Trust me, M&A’s can bring much “unwanted baggage” into play which must be dealt with in a go forward process. Several key areas that are important to review in any M&A activity that will have a significant impact on your Information Governance programs are as follows:

Enterprise Master Patient Index (EMPI)

The EMPI is without question one of the most critical data bases in a healthcare environment. All data collected ties to the EMPI and inaccuracies (duplicates, overlays, overlaps) have negative patient care as well as financial impacts. It is estimated that the error rate in the EMPI is in the 8-10% range. As an HIM professional that is entirely unacceptable and we should drive that rate down to less than 2%. When you merge or acquire an organization you inherit their EMPI and with it all errors. It should be a priority for all HIM professionals to be actively engaged in understanding why errors occur and put software and processes in place to improve the integrity of this data. Become an expert in this area and be proactive. Don’t just accept what reports are given to you by your EMR or IT&S teams. Understand the process and audit your EMPI on a regular basis just like you do for your coding department.

Record Retention and Storage

All mergers and acquisitions will come with legacy electronic and paper information. I can tell you from past experience much of the information you “inherit” is information you did not have time to review during the due diligence process. You will now own multiple record retention policies that may or may not have been enforced. You will find patient records that have been kept in unsecured locations and let’s not forget about all those “shadow” records (both paper and electronic) that literally come out of the closets. You will need to do a complete assessment of your new inventory. This is an opportune time to consolidate your paper information inventory and evaluate lower cost storage options. Historically records have been kept on site which is usually very valuable real estate that could be used for other revenue generating purposes. Information Governance is so critical to making this newly acquired information a valuable asset for your organization vs a major liability and additional expense.

EHR Data Quality

We all understand that the EHR has dramatically changed the landscape not only in healthcare but our profession. In the M&A process you most likely will be dealing with legacy electronic patient care systems that will be entirely different than the ones you may be familiar with and use. It is important to understand the electronic data that you have inherited. Many organizations have not done a very thorough job in data mapping and identifying the actual owner of the data. All this information must be understood and properly cataloged in order for it to be used as a strategic asset. In addition we all know that the EMR has created unintended consequences with processes such as cut and paste and copy forward of information. All these issues need to be addressed in order for the EMR to serve as the valuable tool it should be and Information Governance is the process that starts this journey.

Disclosure Management

No one in your organization should ever question which department has more experience and expertise in this function—it’s health Information professionals. With M&A comes the responsibility to provide all the information you have acquired plus your existing information in a HIPAA compliant and customer focused way. Release of information has become an extremely complicated process in many organizations due to the rapid grow of electronic information along with the hybrid environment. Many M&A’s have also involved newly acquired physician office practices. HIM should be responsible and manage all disclosures for their organization because we are the experts.

Mergers and Acquisitions will continue to occur at an accelerated pace in 2017. Put your information Governance process in place now so that you will be ahead of the challenges and address these key issues in a proactive way.

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