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some finance and clinical executives, information governance (IG) may come off
as a somewhat academic concept that is better suited for the legal, health
information management (HIM), and IT wonks in their organizations. Yet leaders across
the enterprise have much to gain by optimizing information in the same way they
strive to enhance patient safety or improve quality—with a systematic framework
of policies and procedures that are continually reinforced and updated so they
become part of the culture, says Robert Smallwood, IGP, managing director of
the Institute for Information Governance.
IG programs provide a coordinated approach to help organizations optimize the
value of their information assets while reducing privacy and security risks and
ensuring legal and regulatory compliance.
information governance is about knowing what your information holdings are,
where they are stored, and governing them properly based on their level of
sensitivity or confidentiality,” says Smallwood, who has authored several IG
the general business sector, IG has been largely viewed as a strategy to cull
unnecessary and duplicate files that bloat an organization’s storage footprint.
In health care, IG offers several benefits that are particularly useful as
organizations move toward value-based payment. For example, IG helps generate
cleaner data that can be used to streamline service delivery, reduce costs, and
spur innovation, Smallwood says. After a merger, IG can help the restructured organization
get a better handle on information assets that are widely diffused across the
also can help promote organizational alignment and foster collaboration among traditionally
siloed functions such as quality and the revenue cycle. “One of the aims of
information governance programs is to leverage information as an asset across
the organization,” Smallwood says. Ideally, IG programs should foster
information sharing that promotes improvements in overall population health as
well as the financial health of the hospital, health system, or health plan.
many healthcare organizations entered 2018 with more-mature IG programs than
they had just 12 months ago, hospitals, in particular, still lag behind other
sectors in their level of IG maturity. A 2017 survey of primarily provider
organizations by the American Health Information Management Association (AHIMA)
found that the top three barriers to making progress with IG are awareness and
understanding of the concept, budgeting/funding issues, and communication/cooperation
across silos (click on the exhibit below).
all stakeholders within an organization on board—and determining who is in
charge—can be a major challenge, says Melissa Martin, who spent 18 years as
associate vice president of privacy and HIM and chief privacy and HIM officer
for West Virginia University Medicine, Morgantown, W.V.
have to get past whether this is owned by HIM or IT or business analytics and
bring those groups together so you can move forward with information
governance,” says Martin, who is also a past president and chair of AHIMA.
recommends not getting caught up in the term information governance but instead focusing on developing the
framework around security, privacy, records management, and data integrity in
general. “It’s already occurring in some organizations, but successful
information governance programs pull it all together and break down the silos
between different entities and departments in their organization,” she says.
the same time that WVU Medicine was preparing to roll out a shared electronic health
record to all of its hospitals, Martin and her team developed an
enterprise-wide IG steering committee with leaders from HIM, IT, business
analytics, hospital billing, physician billing, and other areas. But the
initiative picked up even more momentum when the committee engaged clinicians
in efforts to bring quality reporting under the IG umbrella. Working together,
leaders at WVU Medicine created policies and procedures on data quality and
storage, records retention, privacy and security, and other areas.
her role as assistant vice president for the new WVU Heart and Vascular
Institute, Martin (pictured at right) continues to apply her IG acumen. “It became pretty clear
when I stepped into this role that we still had plenty of work to do on
information governance,” she says. For example, creating the new service line
meant pulling together the data from two academic departments—not just on the
main campus but from sister hospitals as well. Collection and integration of information
from disparate sources was essential to help service line leaders, business
analysts, and the finance team create financial pro formas to determine which
heart services to offer where, as well as how to price them.
Medicine’s enterprise-wide IG framework has continued to be helpful as the
service line has grown. “We’ve had a number of acquisitions over the past year,
and without the ability to pull together that information from those areas, it
would have been difficult to get approval from our board to acquire practices
or develop clinics in certain rural areas, which is extremely important to our
overall mission,” Martin says.
hospitals have been slow to embrace IG, health plans tend to be further along
on the IG journey, says Matt McClelland, a member of the Information Governance
Initiative’s advisory board and former manager of the information governance
office at Blue Cross Blue Shield of North Carolina, where he oversaw
traditional records management, file analytics, e-discovery, and other areas.
of the main benefits of IG is the ability to comply with external regulatory
pressures, whether those are audits or litigation,” McClelland says. “When
you’re dealing with large amounts of unstructured data, a robust information
governance program allows you to know what you have, know where it is, and know
the relevance to any kind of investigation, litigation, or audit and provide
that in a timely manner.”
health plans also embrace IG because such programs can help protect their
organizations against security threats, including breaches that occur at providers
and other business partners. “By reducing your footprint through good
information governance practices—such as only keeping what you need to keep and
only sharing certain information with partners—you can build walls around what
needs to have walls,” says McClelland, who works with health plans that have varying
levels of IG maturity in his current role as a principal consultant with
also can help health plans and other organizations minimize information like
files and emails that need to be migrated to other platforms, and thus help to
contain costs. “Most organizations are dealing with at least hundreds of
terabytes of unstructured data that is on network shared drives and email, and
most of that has not been managed very well,” McClelland says. This includes
redundant, outdated, and trivial information, also known as ROT. For this
reason, most organizations embarking on IG should use a file analytics tool
that will scan content like emails, slide decks, and Word documents that have unstructured
data (e.g., text, numbers, videos) to determine its age, its key users, and
whether it is duplicated elsewhere in the organization.
his 10 years working on IG at Blue Cross Blue Shield of North Carolina, McClelland
developed what he believes is a four-step process for moving forward that
applies to hospitals as well as health plans.
Gain the authority to do the work. IG requires an executive champion to
drive the program forward as well as a director or vice president to run the
day-to-day operations and align the program to the goals of the organization. Some
organizations also are creating a chief information governance officer role,
although such titles are not common in health care. In other organizations, the
CIO, HIM director, privacy director, or another leader might take on the key
Develop the foundational components
of the program. These
components include retention schedules and electronically stored information (ESI)
maps, which depict the flow of information in an organization. Other key pieces
include standards, policies, data and records inventories, disaster recovery
plans, and educational programs for staff.
Create goals and targets. McClelland recommends establishing
roadmaps that span one, three, and five years. “Be reasonable about what you
can and cannot achieve,” he says.
Execute on the plan but be patient. Recognize that an IG program is
constantly evolving and does not have to achieve everything at once. Leaders
might choose one particular area of focus, such as regulatory or privacy, at
sure where to start? Experts offer the following advice to leaders who are interested
in developing enterprise-wide IG programs.
Assess your organization’s IG
maturity. Both Martin
and McClelland suggest looking at AHIMA’s IG Adoption Model (IGAM). In
December, the Office of the National Coordinator for Health Information
Technology (ONC) released a patient demographic data-quality framework that
endorsed the model, which includes 10 organizational competencies such as IG
structure, strategic alignment, and data governance (view a PDF of the model).
Smallwood believes the IGAM is a useful tool but
also points to the IG Process Maturity Model (IGPMM) from the Compliance,
Governance and Oversight Council (CGOC). The IGPMM was originally developed in
2012 and rates organizations on 22 key IG processes. It was updated in 2017 to
include an emphasis on legal, privacy, information security, and cloud security
issues. “Perhaps the best approach is a hybrid one, combining relevant aspects
of both maturity models to customize the assessment for a particular
organization’s needs and IG program goals,” Smallwood says.
Determine what resources you need.
leaders may perceive that funding is a barrier to developing IG programs, a
basic IG framework does not require a major investment and often can leverage
internal resources, Martin says. Cross-functional partnerships also can help
leaders make the most of limited funds and staff to advance IG, McClelland
Give clinicians a reason to
Poor IG across a
physician practice, hospital, and affiliated post-acute provider can lead to
inconsistent data quality in an organization and may affect the quality of
care. Clinical leaders may be more likely to get involved if they understand
that IG programs can help them deliver better care, McClelland says.
Engage human resources in
developing a formal kickoff as well as continued training. Consider launching an IG program
with an enterprise-wide security awareness or privacy training event, Smallwood
says. Ongoing staff education might include monthly IG tips presented in an
employee newsletter or brief quizzes on issues like privacy and security.
Use metrics to audit your IG program’s success. An IG
project to promote cleaner data to reduce medical errors might aim for a 5 or
10 percent reduction after 12 months, Smallwood says. Another project under the
IG program umbrella might be to clean up shared drives and major information
stores to eliminate ROT and reduce the storage footprint, setting a goal to at
least stop or slow the growth of electronic storage costs—or, more
aggressively, to cut costs by 10 to 15 percent.
IG is underutilized in health care, that trend is shifting as more
organizations begin to recognize the benefits, experts say. As adoption of IG
programs grows, leaders should not get overwhelmed in their early efforts to
manage information more strategically across the enterprise.
a project and just get started,” Martin says. “Then you will see that framework
really come to life.”
Ramos Hegwer is a
freelance writer and editor based in Lake Bluff, Ill.
for this article: Melissa
RHIA, CCS, CHTS-IM, assistant vice president, WVU Heart and Vascular Institute,
Morgantown, W.V.; Matt
consultant, Doculabs, Inc., Raleigh, N.C.; Robert
managing director, Institute for Information Governance, San Diego.
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