• Separating Professional and Hospital Records

    Oct 31, 2012

    By John D. HalamkaHalamka, John

    How can providers share data while maintaining separate records for regulatory purposes?


    The Centers for Medicare & Medicaid Services (CMS) has long required that hospital and professional records be separable so that, in the case of audits or subpoenas, it is clear who recorded what. However, as patient-centered medical homes and accountable care organizations (ACOs) form, the lines between professional and hospital practices are becoming increasingly murky.

    At Beth Israel Deaconess

    Today, the Beth Israel Deaconess Medical Center ACO continues to expand into the community, adding owned hospitals, affiliated hospitals, owned practices, and affiliated practices. Our strategy to date has been to use our home-built inpatient and ambulatory systems at the academic medical center, a proprietary system in the community hospitals, and a second vendor-provided system in the private ambulatory practices that are part of our ACO.

    We share data among these electronic health record (EHR) applications via private and public health information exchange (HIE) transactions-viewing, pushing, and pulling (see the sidebar at the end of this article).

    Data Sharing Challenges

    The challenge with emerging ACOs is that professionals are likely to work in a variety of locations, each of which may have different IT systems and each of which serves as a separate steward of the medical record from CMS's point of view.

    Our clinicians are asking the interesting question, "Can I use a single EHR for all patients I see regardless of the location I see them?" Our legal experts are studying this question. I can imagine several answers:

    • For facilities we own and control, we can tag every note created by every professional with a facility code, enabling us to separate out those records created at a given location in the case of audit or subpoena.
    • For facilities that are affiliated but not owned, clinicians can use their favored EHR, but at the end of the encounter, they must create a paper or digital copy of the record and place it in the hospital record of the location that is the steward of the data from CMS's perspective.

    Since it is unlikely that every inpatient and outpatient facility that we acquire or affiliate with will have the same health information systems and EHR applications, it is not realistic to create one physical shared record across all sites. Instead, data sharing through the HIE, metadata tagging as to the facility/professional that owns each record, and policies regarding what must be done at each site seems like the logical way to go.

    John D. Halamka, MD, MS, is CIO, Beth Israel Deaconess Medical Center, Boston, and chairman of the New England Healthcare Exchange Network (jhalamka@caregroup.harvard.edu).

    This column is reprinted with permission from his blog, Life as a Healthcare CIO.

    Sidebar: Health Information Exchange Models

    View. A website or web service enables authorized patients, providers, or payers to view data in plain text or HTML.

    Push. An EHR sends data to another EHR via the Direct Project standard.

    Pull. An EHR queries a master patient index/record locator service to identify a patient and the patient's records. The EHR then queries all the data sources to assemble a comprehensive medical history.