Ahimajournal 2014 10 DL

OCTOBER 2014
Digging Out
from Data
Hoarding
USING GOVERNANCE TO MANAGE

INFORMATION ASSETS AND PREVENT
DIGITAL DATA AVALANCHES
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Welcome
TO THE DIGITAL EDITION OF THE
JOURNAL AHIMA
OF
Where is Your Organization Hiding the Data?
This months video extra shines a light on three places HIM

professionals can look for hoarded data.
2014 AHIMA
Convention Guide
San Diego, CA | September 27October 2
Read All About It!
Follow the news from the AHIMA Convention

Monday, September 29 | Tuesday, September 30 | Wednesday, October 1
Visit www.ahimatoday-digital.com
Remember, you can always access tips and help
from the Help tab in the menu tray on the left.
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Contents October 2014
Cover
24
Digging Out
from Data
Hoarding
Using Governance to
Manage Information
Assets and Prevent
Digital Data Avalanches
By Mary Butler
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Vol. 85, no. 10

Features
Departments
30
10
By Sofia Empel, PhD
12
The Way Forward

AHIMA Develops Information Governance
Principles to Lead Healthcare Toward Better
Data Management
36
Tracking HIEs Ever Evolving Operational

Models
Emerging Health Information Exchange
Market Still Sorting Out Its Business and
Governance Models
By Kathy Callan, MA, RHIA; Jan Fuller, RHIA, CPHIMSS, FAHIMA;

Lou Galterio, MBA, FHIMSS, CHIME, CP; Beth Just, MBA, RHIA,
FAHIMA; Kimberly Reich, MBA, MJ, PBCI, RHIA, CPHQ, FAHIMA;
Christine Steigerwald, MBA, RHIA; Mary Lou Turner-Combs, RHIA;
Sheldon H. Wolf; Julie Dooling, RHIA, CHDA; Annessa Kirby; and
Harry Rhodes, MBA, RHIA, CHPS, CDIP, CPHIMS, FAHIMA
44
Slow to the Information Governance

Starting Line
First-of-its-Kind Survey Tracks Healthcares
IG Efforts, Shows Most Organizations Are
Behind
Presidents Message
IG Allows Organizations to Embrace
Information as an Asset
Bulletin Board
18
Word from Washington

New Coordinator Reshapes Direction
of ONC
23
Inside Look
The Time for Information Governance
is Now
86
Calendar
87
Keep Informed
By Chris Dimick
50
Leading Your Facility Through the ICD-10

Delay Storm
By Kelli Horn, RHIT, CCS
In Addition
54
2014 AHIMA
Convention Guide
14_October.indd 3
88
Volunteer Leaders
92
AHIMA Career Center
96
Addendum
The Comparative Cost of
Inadequate Protection
9/16/14 2:49 PM

Working Smart
60
Navigating Privacy and Security

Law Changes Patient Access
to Clinical Lab Reports
By Kelly McLendon, RHIA, CHPS
66
Standards Strategies
Driving Standards Toward
Interoperability with PHR
Functionality
By Kim Osborne, RHIA, PMP
64
68
e-HIM Best Practices

The Risks and Results of
Data Spoliation
Quality Care
Informatics Harnesses
Healthcares Wild, Rich Data
By Ron Hedges, JD
By Lou Ann Wiedemann, MS, RHIA, CPEHR,

FAHIMA
Coding Notes
Quizzes
76
AHIMA members may earn continuing

education credits by successfully completing
the following quizzes in this issue.
By Janet Franklin, RHIT, CCS, CCS-P, CHC
34
The ABCs of HHS-HCCs
80
Reliable Coded Data Require a Reliable Coding

Process Framework
By Judy A. Bielby, MBA, RHIA, CPHQ, CCS, FAHIMA
Practice Brief
70
Information Governance Offers a Strategic

Approach for Healthcare
The Way Forward

Domain: Performance Improvement
42
Tracking HIEs Ever Evolving Operational Models

Domain: Performance Improvement
84
Reliable Coded Data Require a Reliable Coding

Process Framework
Domain: Clinical Data Management
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http://journal.ahima.org
Information Governance:
Healthcare and Beyond
The healthcare industry
isnt alone in its pursuit of
information governance.
Technology is forcing all
records-intensive industries
to look for new, innovative
ways to capture and preserve
relevant elements of data.
Video: Where is Your Organization

Hiding the Data?
This months video extra shines a light on three

places HIM professionals can look for hoarded data.
Live AHIMA Convention Coverage
Keep up on the latest news coming out of the 86th

AHIMA Convention and Exhibit, taking place
September 27 to October 2 in San Diego, CA.
Share and Connect with AHIMA

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The Journal of AHIMA is an official publication of AHIMA
AHIMA CEO
EDITORIAL DIRECTOR
EDITOR-IN-CHIEF
Lynne Thomas Gordon, MBA, RHIA, FACHE, CAE, FAHIMA

Anne Zender, MA
Chris Dimick

ASSISTANT EDITOR/
ADVERTISING COORDINATOR Sarah Sheber

ASSOCIATE EDITOR
Mary Butler

CONTRIBUTING EDITORS
Sue Bowman, MJ, RHIA, CCS, FAHIMA

Patricia Buttner, RHIA, CCS

`
Angie Comfort, RHIT, CDIP, CCS

Angela Dinh Rose, MHA, RHIA, CHPS, FAHIMA

Julie Dooling, RHIA

Melanie Endicott, MBA/HCM, RHIA, CCS, CCS-P, CDIP,

FAHIMA

Katherine Downing, MA, RHIA, CHP, PMP

Deborah Green, MBA, RHIA

Jewelle Hicks

Lesley Kadlec, MA, RHIA

Carol Maimone, RHIT, CCS

Paula Mauro

Anna Orlova, PhD

Kim Osborne, RHIA, PMP


Maria Ward, MEd, RHIT, CCS-P

Diana Warner, MS, RHIA, CHPS, FAHIMA

Lydia Washington, MS, RHIA

Lou Ann Wiedemann, MS, RHIA, CHDA, CDIP, CPEHR,

FAHIMA

ART DIRECTOR Graham Simpson
GRAPHIC DESIGNER
Jill A. Blacketer
EDITORIAL ADVISORY BOARD

Linda Belli, RHIA

Gerry Berenholz, MPH, RHIA

Carol A. Campbell, DBA, RHIA

Rose T. Dunn, MBA, RHIA, CPA, CHPS, FACHE, FAHIMA

Teri Jorwic, RHIA, CCS

Diane A. Kriewall, RHIA

Frances Wickham Lee, DBA, RHIA

Glenda Lyle, RHIA

Susan R. Mitchell, RHIA

Daniel J. Pothen, MS, RHIA

Cheryl Tabatabai Stachura, RHIA

Tricia Truscott, MBA, RHIA, CHP

Carolyn R. Valo, MS, RHIT, FAHIMA

Valerie Watzlaf, PhD, RHIA, FAHIMAc
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JOURNAL OF AHIMA MISSION
The Journal of AHIMA serves as a professional development tool
for health information managers. It keeps its readers current on
issues that affect the practice of health information management.
Furthermore, the Journal contributes to the field by publishing work
that disseminates best practices and presents new knowledge.
Articles are grounded in experience or applied research, and they
represent the diversity of health information management roles and
healthcare settings. Finally, the Journal contains news on the work
of the American Health Information Management Association.
EDUCATIONAL PROGRAMS
The Commission on Accreditation for Health Informatics and
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Journal of AHIMA (ISSN 1060-5487) is published monthly, except for the combined issue of November/December, by the American Health Information Management Association, 233 North Michigan
Avenue, 21st Floor, Chicago, IL 60601-5800. Subscription Rates: Included in AHIMA membership dues is a subscription to the Journal. The annual member subscription rate is $22.00 for active and
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Notice of Policy
Editorialviews expressed in articles contributed to the Journal of AHIMA are those of the author(s) and do not necessarily reflect the policies and opinions of the Association, editorial review
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Copyright 2014 American Health Information Management Association Reg. US Pat. Off.
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Presidents Message
IG Allows Organizations to Embrace

Information as an Asset
By Angela C. Kennedy, EdD, MBA, RHIA
AS AN EDUCATOR, I often find myself

answering the question: What is health
information management? As information continues its rise as a critical asset
for providers, this question has become
easier to answer. As data policies based
on the value of information become
standard, HIM professionals can simply
state, I govern healthcare data and the
information derived from it.
While some HIM professionals may
also find themselves in charge of governing financial and administrative data,
for the most part the bulk of HIM work
concerns the governance of healthcare
data and information. The need for information that you can trust has been the
driving force behind our profession for
decades. Our role is critical to the mission of the Triple Aim: reducing cost,
providing better care, and improving
population health. Those goals cannot
and will not be realized without trusted
health information.
At the end of August news broke that
a large US hospital network was hacked
and approximately 4.5 million records
were stolen. While the hackers did not
gain access to personal health information, they did gain access to demographic and identity information that
placed affected individuals at risk for
identity theft. Information is bought and
sold for different purposes every day.
Under the Health Insurance Portability
and Accountability Act, a patient can
sue for negligence when personal identity is breached. Successful data stewardship is of paramount importance as
the need to control and secure access
to patient information is heightened. Security breaches, e-discovery sanctions,
and compliance penalties support the
growing demand for information governance.
Models of healthcare are changing and
the need for trusted information, used to

drive agility and support key business
decisions, is a top priority. Technological
advancements are credited as the primary driving force behind the information explosion. In 2012, 500 petabytes of
data were collected electronically. Thats
equivalent to 10 billion four-drawer filing
cabinets of data. Reactive approaches
to data management are not acceptable
when managing healthcare data. The
integrity and accessibility of healthcare
data have a direct impact on patient care
and safety.
The pressure is on for healthcare organizations to get control of healthcare
data in an optimal way and move their
respective organizations forward. Sustainable benefits can be derived across
the healthcare ecosystem when organizations commit to the principles of information governance. Information governance requires the adoption of core
principles, a framework, and rules that
support a proactive approach to information management. These principles
are applied to all data types across the
enterprise. This infocentric approach
helps to create a culture within the organization that values information.
The time is now for information governance in healthcare. I challenge you to
assess the maturity of information governance for your organization. Apply and
refine information governance principles
as appropriate and reap the benefits of
embracing information as an asset.
In addition, I challenge you to dream
big, believe, and LEAD information governance initiatives across the healthcare
ecosystem.
Angela Kennedy (angela.kennedy@ahima.org) is
head and professor, department of health informatics and information management, at Louisiana Tech University.
14_October.indd 10
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Bulletin Board whats happening in healthcare
EHR Adoption is Rising, But Benefits of Health IT Use Remain Sluggish

The good news: more physicians and
hospitals are using electronic health
record (EHR) systems than ever before. The bad news: most providers
still find it challenging to exchange
health information, engage patients,
and meet the more advanced elements of the stage 2 meaningful use
EHR Incentive Program.
This was the collective message
from two papers recently published
by the Office of the National Coordinator for Health IT (ONC) in Health
Affairs. The first paper noted that 78
percent of office-based physicians
reported in 2013 that they have adopted some type of basic EHR system.
Nearly half of all physicians included
in the study had an EHR system with

advanced functionality in 2013more
than double the adoption rate in 2009,
the study said. Physicians in solo
practices and non-primary care specialties lagged behind others in EHR
adoption.
Hospitals fared a bit better than
physicians in the study, with 59 percent of hospitals saying they have adopted an EHR system with advanced
functionality in 2013. This is four times
the amount of hospitals measured in
2010. The data was collected by the
Centers for Disease Control and Preventions National Center for Health
Statistics and the American Hospital
Association in 2013.
CMS, AHIMA Ramp Up ICD-10 Preparations

With the Centers for Medicare and
Medicaid Services (CMS) officially
setting the ICD-10-CM/PCS deadline
for October 1, 2015, healthcare organizations have begun to once again
ramp up implementation efforts.
For CMSs part, the organization recently announced plans to offer three
end-to-end ICD-10 testing opportunities in 2015 with the hope of ensuring
the submission and remittance advice process is working smoothly with
the new code set, according to an article in Beckers Hospital Review. The
three ICD-10 testing sessions will be
conducted with an estimated 2,550
providers, suppliers, and other claim
submitters. Participants will submit
test claims during the sessions.
To help ensure that the 2015 implementation deadline sticks, CMS has
updated its Road to 10 website with
a series of videos featuring physician
champions of ICD-10 discussing the
benefits of the new code set. The videos offer a physicians view on the
value of ICD-10, and are available at
www.roadto10.org.
As part of its advocacy campaign
efforts supporting the implementation of ICD-10 in 2015, AHIMA has
launched its ICD-10 Grassroots Advocacy Campaign. The campaign
in part calls for AHIMAs component
state associations to also get involved
with advocacy at the local level.
AHIMA has created a new Top
Ten ICD-10-CM/PCS Questions resource that proponents of ICD-10
can use to support their views and
discuss ICD-10 implementation in
an educated way. The easy-to-use
frequently asked questions resource
includes answers to questions such
as Why does the US need to replace
ICD-9-CM?, What is the value of
ICD-10?, and Is the cost of ICD-10
implementation worth making the
transition?
The resource is available online in
AHIMAs HIM Body of Knowledge, located at http://library.ahima.org/xpedio/groups/public/documents/ahima/
bok1_050729.pdf.
While the study shows that providers are quickly adopting health IT, the
functionality of the majority of systems
may not be advanced enough to make
much of a difference in the treatment
of patients. The second paper showed
many providers need to upgrade their
EHR systems if they want to achieve
widespread health information exchange or meet the engagement and
quality measures called for in stage 2
meaningful use.
In 2013 health information exchange
among physicians was low, with only
39 percent reporting they could electronically share information with other
providers. Only 14 percent said they
could electronically share data with
EHR Analysis Probes

Treatment Impact
Healthcare providers may unintentionally create kidney disease and even
cause death when following an aggressive treatment protocol for hypertension, according to new research.
Physicians have often emphasized
the need to bring a patients blood
pressure down as low as possible for
the best outcomes, said lead study
author John J. Sim, MD, in a press
release. However, the findings of our
study suggest that treating patients
with high blood pressure too aggressively may potentially lead to poor
health outcomes.
To conduct the study, researchers
analyzed the electronic health records
(EHRs) of about 400,000 Kaiser Permanente patients in southern California that were taking medication to treat
high blood pressure between January
2006 and December 2010. This research, conducted with the data available through EHRs, is a step toward
developing a better understanding of
ideal target blood pressure ranges.
14_October.indd 12
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ambulatory care providers or hospitals outside their organization.

Lack of user education or commitment may also be preventing providers from meeting stage 2 meaningful
usein 2013 the vast majority of hospitals had capabilities that could be
used to support many stage 2 meaningful use objectives but were just not
being used, according to Health Affairs. In the patient engagement area
of stage 2, only 10 percent of hospitals were giving patients online access
to view, download, and transmit their
health information. Only 30 percent of
physicians routinely used capabilities
for secure messaging with patients.
Stage 2 of the meaningful use pro-
gram will begin this year for those

providers who first attested to stage 1
in 2011 or 2012. To date, 75 percent of
eligible healthcare professionals and
91 percent of hospitals have demonstrated stage 1 meaningful use using
a certified EHR, according to ONC.
However, industry experts have said
that real healthcare benefits wont be
seen until the majority of healthcare
providers meet the more advanced
stages 2 and 3 of the meaningful use
program. These findings suggest
that although EHR adoption continues to grow, policies to support
health information exchange and patient engagement will require ongoing
attention, the authors said.
Survey Shows Low Numbers for ACOs

Pursuing HIE
Though most ACOs have electronic health records implemented and diverse
health IT capabilities, few currently participate in health information exchange
(HIE), according to the results of a study conducted by eHealth Initiative and
Premier, Inc. While some respondents indicated plans to participate in HIEs in
the future, they were outnumbered by those who did not. According to the results presented in the webinar, ACOs tend to participate more actively in HIEs
once they enter advanced and mature stages of operation.
Sample of Survey Responses Regarding ACO Participation in HIE

STATE/PUBLIC-OPERATED HIE
21 percent
19 percent
Yes
No, but plan to
No
36 percent
17 percent
17 percent
50 percent
PRIVATE/ENTERPRISE HIE
33 percent
17 percent
33 percent
10%
20%
30%
40%
Allegheny Health Network, based in Pittsburgh, PA, has launched a telemedicine program designed for use by
emergency medical services prior to a
patients arrival at the hospital.
A group of seven firms that develop
software systems used by officebased physicians have joined to form
a non-profit trade group, the Healthcare
Administrative Technology Association.
State Department of Corrections officials
in Oregon are urging the state to
convert prison health records to an
electronic system to eliminate current
inefficiencies of keeping medical, dental, mental health, and pharmaceutical
records all in one paper chart.
Online tool HealthMap identified a
mystery hemorrhagic fever in southeastern Guinea nine days before the
World Health Organization formally announced the Ebola outbreak epidemic
in West Africa.
Sutter Health Network celebrates the
10-year anniversary of its electronic
intensive care unit, which allows intensivists and nurses in two central hubs
to monitor up to 431 ICU beds around
the clock.
Southwestern Vermont Health Care has
launched two web portals for hospital
services and medical practices to enhance patient access to health data.
Allscripts and Clinical Architecture have
agreed to incorporate Clinical Architectures code set mapping feature
into Allscripts dbMotion health data
sharing tool.
COMMUNITY-BASED HIE
0%
In a malware attack originating

outside the US, hackers stole the
non-medical information of 4.5 million
patients from Community Health Systems,
based in Tennessee.
The American Osteopathic Association

joins the American Medical Association
and American Academy of Family Physicians in calling for electronic health
record training to be included as part
of the education program in medical
school.
50%
Source: eHealth Initiative. Keys to HIT Success: Results from the 2014 Survey on ACOs. August 12,
2014. http://www.ehidc.org/resource-center/webinar-materials/view_document/439-webinar-materialskeys-to-hit-success-results-from-the-2014-survey-on-acos.
Journal of AHIMA October 14/13
14_October.indd 13
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Study: Chronic Care Patients in Medical

Homes Had More Office Visits
MEDICARE PROGRAM INTEGRITY: INCREASED
OVERSIGHT AND GUIDANCE COULD IMPROVE
EFFECTIVENESS AND EFFICIENCY OF POSTPAYMENT CLAIMS REVIEWS
www.gao.gov/assets/670/664879.pdf
In this report from the Government
Accountability Office, the agency
recommends that CMS take actions
to improve the efficiency and effectiveness of contractors post-payment
review efforts, which include providing additional oversight and guidance
regarding data, duplicative reviews,
and contractor correspondence. The
study was performed in response
to questions raised regarding the
effectiveness and efficiency of postpayment claims reviews.
TRANSFORMING CONSUMER HEALTH INFORMATICS THROUGH A PATIENT WORK FRAMEWORK: CONNECTING PATIENTS TO CONTEXT
http://jamia.bmj.com/content/early/2014/08/14/amiajnl-2014-002826.
abstract
A study published in the Journal of the
American Medical Informatics Association finds that increased awareness of
social, technical, and environmental
health IT components is necessary in
order to promote patient engagement,
and efforts should align with patients
health-related activities.
CLINICIAN-CREATED DOCUMENTATION: REINSTATING QUALITY ASSURANCE PROGRAMS TO
SAFEGUARD PATIENTS AND PROVIDERS
www.ahdionline.org/portals/0/downloads/Resource_Kit/AHDI-AHIMA_QAwhitepaperJuly2014.pdf
A toolkit from AHIMA and the Association for Healthcare Documentation
Integrity provides healthcare organizations with tools to develop and
implement quality assurance programs
for electronic health record documentation. Standards for measurement,
reporting, and documentation improvement are included in this resource.
A new study refutes the assumption

that, in general, people with chronic
conditions will use non-co-pay methods of communication with physicians
as an alternative for office visits.
The study, published recently in the
Annals of Family Medicine, took a closer look at patients with diabetes who
received care before, during, and after the formation of a patient-centered
medical home approach to chronic
care. Researchers observed that patient use of telephone calls to physicians and secure e-mail platforms was
linked to a slight decrease in visits to
the doctors office, as well as an increase in patients reliance on nonco-pay calls and e-mails, researchers
noted.
But when researchers conducted a
regression analysis of the studyadjusting for variables such as morbiditythey saw an increase in office visits in the population and an increase
in phone calls and e-mails with physicians, according to Medscape.

Rosemarie Nelson, a health information technology consultant for the
Medical Group Management Association, told Medscape that telephone
calls and secure messages have never been a substitute for office visits
among patients with chronic disease,
and nobodys ever suggested that.
People with diabetes know that their
feet have to be looked at and their eyes
have to be examined, among other
reasons for office visits, Medscape reported.
Study investigator David T. Liss, PhD,
acknowledged that the study didnt
look at whether individuals who had
more contact with the healthcare system were more concerned with their
health. According to Medscape, Liss
said it would be logical that patients
[who had more contacts] could be
more engaged in their health.
Data Broker Tracking of Pregnant Women

Raises Privacy Concerns
Expectant mothers are an attractive
population for marketers, who use their
online and offline purchasing data to
target products. A pregnant womans
data is worth 15 times more than an
average persons data, according to a
recent article in The Atlantic.
In her article Bump Tracker: Nine
Months of Big Data, Natalia Holt describes how her Internet browsing history, which frequently included visits
to websites related to pregnancy, fertility, and motherhood, led her to discover the extent to which data brokers
tracked her activity. She writes that
for nearly every website she visited, at
least 12 data brokers monitored which
links she clicked, which products she
purchased, as well as which links directed her to other pages.
Merchants know that a new baby
means that serious purchases are

about to be made and that brand loyalty, often acquired before the baby
arrives, can yield years of dependable
purchasing, Holt wrote. To take advantage of this, data brokers are inventing new computational techniques
to zero in on this lucrative group.
The business of data brokering raises privacy and security concerns. Although the sale of consumer data is
regulated by the US Government Accountability Office, there is no comprehensive privacy law governing the
collection and sale of consumer data
and that, under current law, consumers
have no right to know what information
has been gathered about them or control how personal information is collected, even sensitive health information such as pregnancy, Holt said.
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AHIMA Developing Global HIM Curricula

ESTIMATING IMPACT OF PUBLIC HEALTH
INTERVENTIONS
www.communityhealthadvisor.org
A web-based tool called Community
Health Advisor from HealthPartners
Institute for Education Research, Partnership for Prevention, and the Robert
Wood Johnson Foundation predicts the
health and economic impact of public
health interventions and policies with
local, regional, and national estimates.
The tool is designed to help officials
and leaders determine which policies
and programs will have the greatest impact on health, mortality, and medical
costs.
STRATEGIES FOR ELECTRONIC DOCUMENT
AND HEALTH RECORD MANAGEMENT
www.ahimastore.org/ProductDetailBooks.aspx?ProductID=17550
A new text from AHIMA press authored
by Darice M. Grzybowski, MA, RHIA,
FAHIMA, provides guidance to facilities
struggling to manage an effective and
efficient legal health record. The text includes practical examples, case studies, and industry tips for successful use
of electronic document management
systems as a vital component of the
electronic health record.
SOFTWARE TARGETS HIGH-RISK
READMISSIONS
www.pccipieces.org
A software platform has been developed by Parkland Center for Clinical
Innovation to alert providers within 24
hours following admission if a patient
has a greater risk for readmission.
Called Pieces, the software analyzes
clinical and social data found in the
patients electronic health record. The
Level I trauma center and teaching hospital University Health System, based in
San Antonio, TX, has implemented this
software as part of their efforts to reduce hospital readmission rates.
In early August, AHIMA and the AHIMA

Foundation convened an international
group, the Global Health Workforce
Council (GHWC), in Chicago, IL, to
launch work on a global health information management workforce curricula standard.
The group included 13 appointed
members from 12 different countries.
The GHWCs emphasis was on ensuring the curricula standard is internationally applicable, flexible and consistent, and provides a basis for the
profession to be recognized by governments, higher education leaders, and
employers in any country, according to
AHIMA Foundation officials.
The GHWC will release a draft of the
workforce curricula later this year. Additionally, country-level workgroups will
bring stakeholders together to review
and provide feedback on the global
curricula standards and competencies.
The standard will be developed
through an open and transparent process that seeks input and consensus
from country-level workgroups and
stakeholders, said William Rudman,
PhD, RHIA, executive director of the
AHIMA Foundation and co-chair of the
council. We are thrilled that the GHWC
appointed members are leaders from
around the globe with accomplishments, experience, and influence in the
fields of healthcare,education, government, and associations with HIM, technology and informatics expertise.
According to AHIMA CEO Lynne
Thomas
Gordon,
MBA,
RHIA,
CAE, FACHE, FAHIMA, the curricula
standard will guide educational programming and workforce training, and
contribute to an increase in the quality
and number of highly trained professionals around the world with expertise in health information management,
health informatics and health information technology.
Strategy, Infrastructure Development Needed

to Leverage Data for Care
As health IT continues to advance, the
US healthcare industry faces the task of
keeping abreast of new developments
and maintaining an infrastructure that
allows providers to take full advantage
of the information being collected.
In the quest to streamline the process of matching patients with their
healthcare data across different systems and settings of care, a nationwide
patient data matching strategy is a top
priority, according to a letter from the
Electronic Health Record Association
to the US Senate Finance Committee.
Patient identification that ensures
accurate patient record matching
across provider sites is a primary concern when aggregating patient information from multiple organizations,
the letter states. Establishing an improved, reliable method to match patients with their records is an important
step in making electronic healthcare

data both more readily available and
more useful to providers. Error rates
in existing technologies that manage
patient identification are sufficiently
high to cause concern about medical
errors, redundant testing, and inefficiency, the letter states.
A need for health IT infrastructure improvements to support complex care
management was also emphasized
in a perspective paper published in
the New England Journal of Medicine.
Better algorithms could be developed
for identifying patients whose care offers the greatest opportunity for reducing expenditures, health information
exchanges could be created to provide
real-time data to CCM teams, and software for population management and
care manager work flow could be improved, the researchers wrote.
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New Coordinator Reshapes

Direction of ONC
By AHIMAs Advocacy and Policy Team
KAREN DESALVO, MD, MPH, MSc, believes its time to shake things up a little
at the Office of the National Coordinator
for Health IT (ONC). DeSalvo, who previously served as the New Orleans city
health commissioner and senior health
policy advisor to Mayor Mitch Landrieu,
began her appointment as National Coordinator for Health IT in January 2014.
DeSalvo assumed the helm while
the agency was taking on a challenging balancing act, facing the regulatory
burdens of multiple competing priorities
such as HIPAA, the Affordable Care Act,
stage 2 of the meaningful use EHR Incentive Program, and ICD-10-CM/PCS.
Shake-Up Announced on First Day

Just one day after taking office, DeSalvo wasted no time sharing her initial
thoughts on the direction of ONCs work.
At a Health IT Policy Committee (HITPC)
meeting she outlined a plan that would
focus ONCs efforts on harnessing health
IT for multiple purposes, including public health. She indicated that she would
like to see improvements over time that
would allow for assistance in preparing
for disasters.
DeSalvo further outlined her plan in
April at a HITPC meeting when she
talked about expanding ONCs priorities
beyond meaningful use. This seems
like a good time to make some form and
function adjustments to the policy committee and the workgroups, DeSalvo
said. We are pivoting to readjust to our
smaller budgets and perhaps, over time,
changes to the structure of our agency.
Stating that the HITPC workgroups
are going through an evolution, DeSalvo
presented a proposed restructuring designed to support current ONC priorities,
stressing the importance of communication and reducing redundancy. DeSalvo
proposed four workgroups that HITPC
would focus on:

Health IT strategic planning
Advanced health models and meaningful use
Health IT implementation, usability,
and safety
Interoperability and health information exchange
Privacy and security and consumer engagement would cut across all of these
topics, she noted.
Stating the opportunity to be as strategic and forward thinking as possible, DeSalvo stressed that the workgroups will
be flexible and easily adjusted. Transition
began in early May, with efforts continuing through the summer.
Organizational Changes Reshuffle

Staff
In June 2014 DeSalvo continued to shake
things up by announcing multiple organizational changes. In an internal memo to
staff DeSalvo stated that as the agencys
original health IT infrastructure and program funding from the HITECH Act was
expiring, ONC would reshuffle staff into
a smaller number of departments. She
stressed overall accountability to the US
population as a primary concern of the
agency, stating that it is our responsibility to take this opportunity to reshape our
agency to be as efficient and effective as
possible.
The main focus of ONC going forward
will be to foster health IT interoperability, support care transformation, and develop a framework to support the use
of health data by providers, insurers,
researchers, and others. DeSalvo went
on to state in the internal communication
that this new structure will help us expand our role as convener to further advance new and innovative uses of health
IT across the federal government and
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with the private sector.

As a part of the staffing restructure new consolidated departments were announced:
National Coordinator (Karen DeSalvo, MD, MPH, MSc)
Deputy National Coordinator (Jacob Reider, MD)
Office of Care Transformation (Kelly Cronin)
Office of the Chief Privacy Officer (Kathryn Marchesini,
JDacting)
Office of the Chief Operating Officer (Lisa Lewis)
Office of the Chief Scientist (Doug Fridsma, MD, PhD)
Office of Clinical Quality and Safety (Judy Murphy, RN)
Office of Planning, Evaluation, and Analysis (Seth Pazinski)
Office of Policy (Jodi Daniel)
Office of Programs (Kim Lynch)

Office of Public Affairs and Communications (Peter
Ashkenazacting)
Office of Standards and Technology (Steve Posnack)
All departments now report to DeSalvo or Reider. DeSalvo
aims to improve the overall efficiency of ONC by combining similar functions and thus improving the groups ability to
elevate critical priority functions. The new structure provides
a much flatter organization chart and a more accountable
reporting mechanism.
Agency leaders have already begun a focus on the development and implementation of an interoperability roadmap,
furthering care transformation, establishing a framework to
support the use of health data, improving patient safety,
improving public health, and further advancing medical science.
strategist with Kindred Healthcare, based in Louisville, KY

Interoperability and Health Information Exchange
--
Chair: Micky Tripathi, president and CEO of the
Massachusetts eHealth Collaborative
-- Co-chair: Chris Lehmann, MD, professor of pediatrics and biomedical informatics at Vanderbilt University, based in Nashville, TN
Privacy and Security
-- Chair: Deven McGraw, partner with Manatt, Phelps
& Phillips
-- Co-chair: TBD
Consumer Perspective and Engagement
-- Chair: Christine Bechtel, president of the Bechtel
Health Advisory Group, based in Washington, DC
-- Co-chair: TBD
More Changes Likely to Come

In six short months, DeSalvo successfully realigned ONC
with the next steps needed to advance health IT in the US.
Her goals of promoting interoperable healthcare, improving
efficiencies at the agency, and providing more accountability
will definitely be something to watch.
The AHIMA Advocacy and Policy Team (advocacyandpolicy@ahima.org)
is based in Washington, DC.
Workgroups Whittled Down

DeSalvos work continued, and on July 8, 2014, it was announced that the current 15 Health IT Policy Committee
workgroups and subcommittees would be reduced to six.
To further emphasize the need for change, DeSalvo, who
serves as the HITPC chair along with vice chair Paul Tang,
announced the six new HITPC workgroups and chairs.
These workgroups include:
HIT Strategy and Innovation
-- Chair: David Lansky, president and CEO of the Pacific Business Group on Health
-- Co-chair: TBD
Advanced Health Models and Meaningful Use
-- Chair: Paul Tang, MD, chief innovation and technology officer at the Palo Alto Medical Foundation
-- Co-chair: Joe Kimura, MD, medical director of analytics and reporting systems at Atrius Health, based
in Boston, MA
HIT Implementation, Usability and Safety
-- Chair: David Bates, MD, medical director of clinical
and quality analysis, information systems at Partners HealthCare, based in Boston, MA
-- Co-chair: Larry Wolf, health information technology
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Inside Look
The Time for Information

Governance is Now
By Lynne Thomas Gordon, MBA, RHIA, FACHE, CAE, FAHIMA, chief executive officer
FOR AHIMA, 2014 has been the year of

information governance (IG).
From Information Governance Month in
February to this months 86th Convention
and Exhibit, AHIMA has been breaking
new ground in exploring, understanding,
and making recommendations for IG in
healthcare organizations.
Many HIM professionals understand
that information is critical to coordinating care, so the healthcare industry must
start to better govern this information.
But AHIMA is not doing IG work in a
vacuum. Other industries have been
working with these issues for some time
and formulating compelling arguments
for IG. Those with a legal or risk management bent, for instance, are quick to
point to the risks of not doing enterprise
IG, such as inefficiency and vulnerability
to legal risk. Others point to the need to
get a handle on proliferating amounts of
data.
But AHIMAs work is driven not just by
the fear of bad news, but by looking at
the big picture. By focusing on the unique
aspects of governing health information,
particularly on quality and continued integrity of data, we are playing the long
game of improving healthcare. Better
governance of our information leads to
better coordination of care, which contributes to better outcomes, increased
patient satisfaction, and reduced cost.
More Insights into IG

This months issue contains a variety of
articles to bring the big picture of IG into
clearer focus.
Earlier this year, AHIMA and Cohasset
Associates unveiled a white paper detailing the results of the first-ever survey
of IG practices in healthcare. In Slow
to the Information Governance Starting
Line, Chris Dimick highlights some of
the surveys surprising results, as well
as relays AHIMAs recommendations for

taking action to improve IG adoption in
healthcare. The paper states that the
majority of healthcare organizations lack
a vital information governance strategy.
(The information governance white paper
is available for download online at www.
ahima.org/IGwhitepaper.)
As information proliferates, it also becomes cheaper and easier to storebut
easier isnt always better. In Digging Out
from Data Hoarding, Mary Butler addresses how HIM professionals can use
IG strategies to manage the vast stores
of information currently being hoarded
by many healthcare organizations.
AHIMAs 2013 Health Information Exchange Practice Council spent considerable time reviewing the emerging landscape and envisioning the future state
of health information exchange (HIE).
Tracking HIEs Ever Evolving Operational Models is a first look at the councils
research in this important area.
The ICD-10-CM/PCS implementation
delay has created clouds of confusion
on the HIM horizon. Kelli Horn, RHIT,
CCS, offers suggestions that will help in
Leading Your Facility Through the ICD10 Delay Storm.
I am particularly pleased to note this
last article. Recently, AHIMA unveiled its
IG Principles for Healthcare. Developed
by a task force of experts, the principles
combine best practices, information
theory, and legal principles in healthcare, resulting in a list of essential considerations for the development of an IG
program. Task force member Sofia Empel, PhD, summarizes the principles and
discusses how they can be used in The
Way Forward.
I urge you to read the article, and the
principles, and think about how your
organization can take the next step forward in IG.
14_October.indd 23
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Digging Out
from Data
Hoarding
14_October.indd 24
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Digging Out from Data

Hoarding
USING GOVERNANCE TO MANAGE INFORMATION

ASSETS AND PREVENT DIGITAL DATA AVALANCHES
By Mary Butler
IF A BRAZEN television show producer were looking to cash in

on the popularity of shows about hoarders, observing a health
information management (HIM) department could be a good
place to start.
Stories about hoarding records abound. Some hospitals have
reinforced their floors to accommodate the weight of new boxes
of records, while others have constructed whole new buildings
to help contain records overflow.
As with the hoarders who pop up regularly on Dr. Phil,
records managers live with the constant fear that the files
theyve purged will be valuable down the line, whether thats
in 10 weeks or 10 years. HIM professionals in these roles have a
legitimate pointhealth records can be subpoenaed, help prevent allergic reactions, and chronicle the progress of chronic
and acute disease processes. Conflicting federal, state, and
organizational regulations offer little reassurance when purging clutter, particularly if a provider or vendors service area
crosses state lines.
Complicating the issue, the digital era of electronic health record (EHRs) allows mounds and mounds of information to be
stored on computer serversout of sight and hidden from scrutiny. But just because the data hoard is unseen doesnt mean
that the issues that come with itinability to quickly retrieve
and reproduce vital information or legal implications of a lack
of proper retention/destruction policies, for examplestill have
detrimental effects for healthcare organizations.
Information governance programs have been developed in
healthcare to tackle these concerns and offer HIM professionals
a much-needed framework for getting their own IG programs
started. A joint study released this summer by AHIMA and Cohasset Associates demonstrated just how necessary a framework is. Only 37 percent of survey respondents said they had a
program in place to retain only relevant information in response
to a legal hold.
To grasp the challenges of enacting an information governance program, its important to compare how healthcare measures up against other data-intensive industries. One also must
examine how and why organizations amass the volume of data
they do, study information governance programs, and fully understand the pitfalls and the benefits of retaining everything.
Finally, one must understand just what HIMs role is in information governance.
But I Might Need It Later

An issue that HIM professionals encounter in their efforts to
clean up databases is that enterprise-wide, everyone has a stake
in retaining information. This is a phenomenon Seth Katz, MPH,
RHIA, assistant administrator, information management and
program execution, HIM department, at Missouri-based Truman Medical Center, sees a lot. He says that even when creating intake forms, departments such as nursing, finance, revenue
cycle, social work, and case management request that their own
data be captured up front.
All of these departments come to the table saying Wed rather capture it than not, Katz says. From their perspective its
just digital info on a server, How hard can it be? They dont
understand the long-term ramifications for storing all of this
data.
Brent Bigelow, CISSP, CEH, a member of AHIMAs Information Governance Task Force and senior vice president of security architecture for Cardinal Health, has witnessed this play out
in his professional and personal experience.
Working in a healthcare environment, he knows that organizations try to collect as much information about a patient
as they can to properly diagnose them and justify a treatment
plan for reimbursement. Gathering adequate data up front
also prevents clinicians from having to call patients back into
the office for unnecessary follow-up visits, and eliminates
time consuming phone calls. Although healthcare organizations are collecting all this information, it is very rarely actually used. When Bigelow took his own kids to the doctor for
school physicals, he was amazed by the number of questions
their doctor asked.
But from the professional perspective Im thinking How are
they going to deal with this? Wheres all this data going? Where
is it going to end up? Will it end up under the desk in a box? Is
it on some sort of PC thats got a build up of dust? Or on a hard
drive? Bigelow says.
Another very common, yet very daunting, governance concern in many organizations is e-mail backlogs. Melissa Martin,
RHIA, CCS, CHTS-IM, chief privacy officer and HIM director at
West Virginia University Hospitals, says that she and her colleagues struggle with the I might need this mentality about
e-mail.
I think the biggest area where we hoard digital information or
digital data is actually e-mail. And much of that e-mail has very
important information, whether its patient information or business data, that we, for lack of a better term, hoard, Martin says.
Its not always the most up-to-date information.
Martin added that in legal cases where metadata is subpoenaed, information as presented in e-mails can be very misleading. People tend to use e-mail more like a chat process and
then they keep it. When they keep it and it gets subpoenaed as
part of a legal case, it can get extremely detrimental to an organization, Martin says.
EHR Gold Rush Adds to Data Clutter

Because the evolution of EHRs developed so rapidly, with help
from the federal governments meaningful use EHR Incentive
Program, many organizations are scrambling to catch up, and
that means they hang on to data in a variety of formats. Information is stored in paper records, electronic records, as images
14_October.indd 25
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Hoarding
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(CT imaging, ultrasound, etc.), audio files, and a myriad of other

formats.
Retention laws can be slow to change and adapt, Katz says. For
example, providers in Missouri are still required to offer the option of a telegram as a means of notifying a patients next of kin
about the patients death.
And theres some concern too that Ive had this information
in my chart for 10 years, am I OK to purge it according to state
law? Because it doesnt say that I cant. So theres some uncertainty there, Katz says.
The healthcare industry is far from being an outlier in the
realm of data hoarding, says Ed Hallock, director of marketing
strategy of RSD Glass, a company that provides information
governance platforms and solutions. The problem of hoarding
electronic records and data occurs in many fields, including finance, banking, and especially highly regulated industries.
We have cultivated this culture of keep everything because
storage is so cheap, Hallock says. This is because nobody wants
to be in the position where you cant find what you need to
find, he says. This is not unique to healthcare.
Hoarding electronic data is more problematic because any
data steward can see the very visible, external cost to storing information on paper, whereas relatively inexpensive storage via
cloud computing, external hard drives, thumb drives and products such as Dropbox arent as tangible.
Im not convinced [storing electronic data] is cheap. Someone has to back it up, someone has to archive that data, and so
there are a lot of other inherited costs, Hallock says.
He notes that digitized data are even more susceptible to being stored in a format that could potentially become obsolete.
For example, health data or imaging tests are often burned onto
compact discs, but new laptops or tablets already dont have the
ability to read that type of data.
HIM to the Rescue
Request a demo.
HealthStream.com/ICD10AHIMA
Visit booth #1617 at the AHIMA

Convention & Exhibit to learn more.
Every reality or talk show that features an exploited, heartstring-tugging hoarder also casts a professional organizer
or psychotherapist (or both) in the role of a rescuer who can
intervene and help the hoarder de-clutter. In the healthcare
realm, that person, ideally, works in an organizations HIM department.
Whether they realize it or not, HIM professionals already analyze data and incorporate informatics skills and workflow management into their day-to-day activities, Martin says. She says
HIM professionals data stewardship duties should mirror those
of a clinical documentation improvement specialist in a coding
department. In both roles, HIM can combine their information
governance skills with their clinical expertise to tell a patient
or recordsstory.
We need the HIM folks in the middle, whenever data is getting pulled together, whether its for pro forma for a future business venture, or whether its data were gathering to negotiate a
contract with an insurance company, Martin explains.
Data stewardship is a competency of any HIM professionals
toolbox, Katz says. HIM employees know how data are created,
where it lives, and how to find a specific piece of data upon re-

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14_October.indd 26
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9/16/14 2:50 PM

Hoarding
Rooting Dark Data Out of the Shadows

HIDING IN THE dark recesses of healthcare information systems lurks the problem of dark data. Like data hoarding, dark
data isnt unique to healthcare.
In the HIM world, dark data is also known as shadow
data, shadow charts, or convenience copies. Like the
dark matter filling the universe that astronomers cant see
or understand, but know exists, so too lurks dark data for
HIM professionals.
Dark data is generated when a user accesses, for example, a patient chart to review clinical documentation for billing purposes. They may save that file to their own desktop
computer or hard drive, save it to an internal SharePoint site,
or e-mail the file to a colleague. Dark data also hides on employees mobile devices if they bring them to work, and take
home information to work on later.
This creates additional, untracked copies of information
that may eventually work their way back into official record
systems and cause versioning issuesor float out in the
world unchecked but used to make business or care decisions. Dark data is also information being created independent from official record keeping processes, and apart from
the watchful eye of an HIM professional.
Datskovsky compares dark data to the stuff in the bottom
of your closet you dont want to sort through.
quest. Now that healthcare organizations have built giant databases of valuable health information, HIM professionals are
well suited to manage data queries.
Katz was instrumental in implementing Truman Medical
Centers information governance initiative, which in the last
two years has transformed how data queries are handled in his
organization. He attributes part of Trumans success to the fact
that the information governance committee had three credentialed RHIAs.
HIM professionals are well suited to be on those teams and
lead some of those teams, and to really blaze the path on what
information governance will look like in five years when people
have built out programs, Katz says. Its an emerging trend and
topic that our skill set really aligns with.
Thanks to Trumans information governance activities, data
requestors are seeing turnaround times of four hours instead of
one business day or more. Very few data requests now fit the
criteria for complex.
Weve seen some improvement in satisfaction from staff.
They can get their data faster, weve seen satisfaction from the
analysts that are running that data because theyre not getting
20 different tickets, Katz says. Theyre getting those prioritized
for them Now people are asking for more detailed data and
were able to provide that much more quickly.
The following are examples of the types of data queries Trumans HIM department may receive:
A list of all the patients within a certain zip code with a
given comorbidity
Lets say you have a really, really old patient record system,
and it was running on a mainframe, and the mainframe no
longer works. But you still have a bunch [of data] to collect
from that. However you dont really know anymore what data
it is, Datskovsky says. The problem is, if you dispose of it,
you might be getting rid of something thats very important
for regulatory reasons. And its important for patient care,
compliance, or for a lawsuit. And you might miss something.
Cardinals Bigelow agrees that dark data is a problem
across industries, including healthcare. In his experience,
dark data is usually archived data stored to someones desktop as a shortcut, or it can be legacy data. And in some cases, dark data can be paper records stored in unofficial areas.
The data stored on a desktop, theres no clear understanding of whats valuable and whats not. Theres no retention flags on said data. Theres a lot of areas that have
that. Finding it can be a bit tricky, Bigelow says. He adds,
however, that his organization has a process in place to scan
computers and databases for certain criteria.
Its sort of like storing my kids pictures for 15 years. Its
there, I know I back it up. Im not sure where everythings at,
three computers later I just keep moving it over. So operationally, we tend to move that data without really interrogating it
and looking at it from an analysis standpoint, Bigelow says.
Th
e number of patients who visited a primary care clinic
during a certain period of time
How many patients have sought pre-natal care at a clinic,
typically if the facility is applying for a grant that requires
the organization to quantify this data
A physicians research project
The number of babies born during a specific time period
How Data Hoarding Hurts

Healthcare organizations cant afford to waste any time forming
and enacting information governance programs and practices.
Health dataparticularly in the electronic realmare susceptible to breaches and litigation, and unchecked data hoarding
can make these situations worse. Lawsuits, breach notifications,
and compliance violations can damage an organizations reputation as well as their finances.
With its framework document, Information Governance Principles for Healthcare, AHIMA provides guidelines for helping
organizations develop sound policies around how long certain
health data is retained by an organization and how and when it
can be purged.
The principles AHIMA has developed follow the associations
definition of information governance, which is: The adoption
of an organization-wide framework for managing information
throughout its lifecycle and supporting the organizations strategy, operations, regulatory, legal, risk, and environmental requirements.
Sandra Wolfskill, FHFMA, director of healthcare finance policy
14_October.indd 27
9/16/14 2:50 PM

Hoarding
at the Healthcare Financial Management Association (HFMA),

and member of AHIMAs Information Governance Task Force,
says that the task force is working to elevate responsibility for
information governance to the executive level and clearly apply
IG principles throughout the organization.
The biggest risk [in having ungoverned data] besides accidental breach is that the data may be used against the provider
in a legal action, Wolfskill explains.Organizations are perfectly
within their rights to destroy information that qualifies for destruction based on policy and state or federal law.If qualifying
data is destroyed, it cannot be breached or used against the provider or discovered.
So in that sense, managing retention and destruction is just
good business practice.
With regard to data retention, AHIMAs principles recommend
that organizations need an information retention program that
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defines what information to retain, how long to maintain it, and

how to dispose of it when it is no longer required. This is based
on the concept that information has a lifecycle, which begins at
its creation and ends at its final disposition.
West Virginia does not have any state health data retention
regulations, which has its pros and cons, according to Martin,
from the University of West Virginia Healthcare.
The pro for us in West Virginia, with not having one, means
WVU Healthcare can establish our own, and as long as we follow
that we should be covered from a legal perspective, says Martin,
noting that it becomes more complicated when her organization has to coordinate or partner with providers with different
policies.
Now, theres some states worse off than we are. They say you
have to keep it forever, or you have to keep it for 40 or 50 years,
Martin says. We established 20 years here at WVU. So I dont
know if its a good thing or a bad thing that we didnt have a state
law, because in a university setting youre allowed to set your
own retention. But some people might look at that a little bit differently.
For those who do keep records for longer than 50 years, recent changes to HIPAA enacted as part of the HITECH Act have
changed the rules on protecting and managing old information.
HITECH states that records 50 years old or older are no longer
formally protected by HIPAA and open to public viewing. Although HIPAAs regulation may have changed, organizations
can still enact their own rules regarding the release of this information. But if no policy is in place, the records must be released,
meaning providers should revise their release of information
and retention policies if they keep records past 50 years.
As Galina Datskovsky, PhD, CRM, a member of AHIMAs Information Governance Task Force, points out, AHIMAs principles dictate that each healthcare organization should follow
state and federal regulations. Organizations should look at each
internal system that creates or generates data, figure out which
ones are most vulnerable, and then rank the systems based on
which of the data need the highest level of protection and management. Using this ranking system will allow organizations to
prioritize which ones to improve and strengthen first.
Then organizations will know what they have and properly
decide how to apply principles to each collection in accordance
with that information, Datskovsky says.
Consider the following Dr. Phil-like advice: The sooner an
HIM department identifies (admits) they have a data hoarding
problem, the sooner they can apply information governance
initiatives to fix itand actually start enjoying the benefits of
well-maintained information.
Reference
BA IN HEALTH
INFORMATION MANAGEMENT
Visit online.sjcme.edu/ahima or call 800-752-4723
for more information.
AHIMA. Information Governance Principles for Healthcare.

2014. http://www.ahima.org/topics/infogovernance.
Mary Butler (mary.butler@ahima.org) is associate editor at the Journal of
AHIMA.
14_October.indd 28
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THE
WAY
FORWARD
AHIMA DEVELOPS INFORMATION GOVERNANCE PRINCIPLES
TO LEAD HEALTHCARE TOWARD BETTER DATA MANAGEMENT
By Sofia Empel, PhD
PICTURE THESE SCENARIOS: Janes role as health information management (HIM) director recently expanded to include her hospitals non-clinical information such as human
resources, legal, finance, and marketing. According to the senior leadership of Johns health insurance company, he must
align their existing information governance (IG) program
with the companys strategic goals. And Carol, who works for
a health information exchange (HIE), is charged with building
an IG program from the ground up.
Although these health information professionals have three
different imperatives, all of them can achieve their objectives
using AHIMAs newly developed Information Governance Principles for Healthcare (IGPHC).
IGPHC Helps Standardize Information Strategy

IGPHC is an information governance framework specific to
the healthcare industry which establishes a foundation of best
practices for IG programs in the form of eight principles:
Accountability
Transparency
Integrity
Protection
Compliance
Availability
Retention
Disposition
(Hint: remembering the principles is made easy by using the
mnemonic device A TIP CARD). A short description of each
principle can be found on page 31.
To appreciate IGPHC, its helpful to first understand the concept of IG. AHIMA defines IG as An organization-wide framework for managing information throughout its lifecycle and
supporting the organizations strategy, operations, regulatory,

legal, risk, and environmental requirements.
In effect, IGPHC is a group of fundamental norms, values, and
rules used to comprehensively govern an organizations information management strategy, whatever it may be, from cradle
to grave. It provides a framework of IG best practices; a model
for program development; a means of benchmarking against
peers; and a plan for legislative, judicial, accreditation, and organizational policy mapping.
Consider our three scenarios. Janes hospital most likely focuses its information management strategy on patient health
records, while Johns health insurance company concentrates
on reimbursement transactions. And Carols HIE probably
emphasizes the sharing of data among its members. Although
these organizational missions are different, their information
governance concerns are the samecomplete, current, and accurate information to the right person or entity at the right time.
Considered collectively, the principles of IGPHC paint a picture of what good IG would look like for providers and nonproviders alike, big or small, public or private. IGPHC allows
an organization to get a high-level view of its IG initiatives. This
perspective then can be used internally by the organization to
guide its IG actions, and externally by stakeholders to judge the
effectiveness of the organizations IG program.
Why IGPHC Needed to Be Developed

AHIMA recognized that the five Vs of datavolume, variety,
veracity, velocity, and valueare substantially different in an
electronic environment than a paper one. Electronic data require not only a bottom-up approach to information management, but also a top-down approach using information governance.
Its important to know the difference between governance and
14_October.indd 30
9/16/14 2:50 PM
The Way Forward
Principles of the IGPHC

THE FOLLOWING IS a summary of the eight principles included in the Information Governance Principles for Healthcare
(IGPHC). To access the full text of the principles and guidance on implementing them, visit www.ahima.org/topics/infogovernance.
Principle of Accountability
Principle of Protection
An accountable member of senior leadership, or a person

of comparable authority, shall oversee the information governance program and delegate program responsibility for
information management to appropriate individuals. The organization should adopt policies and procedures to guide
its workforce and agents and ensure that its program can
be audited.
An information governance program must ensure that the

appropriate levels of protection from breach, corruption, and
loss are provided for information that is private, confidential,
secret, classified, essential to business continuity, or otherwise requires protection.
Principle of Transparency
An organizations processes and activities relating to information governance should be documented in an open and
verifiable manner. Documentation shall be available to the
organizations workforce and other appropriate interested
parties within any legal or regulatory limitations and consistent with the organizations business needs.
Principle of Integrity
An information governance program shall be constructed so
the information generated by, managed for, or provided to
the organization has a reasonable and suitable guarantee of
authenticity and reliability.
Principle of Compliance
An information governance program shall be constructed to
comply with applicable laws, regulations, standards, and organizational policies.
Principle of Availability
An organization shall maintain information in a manner that
ensures timely, accurate, and efficient retrieval.
Principle of Retention
An organization shall maintain its information for an appropriate time, taking into account its legal, regulatory, fiscal,
operational, and historical requirements.
Principle of Disposition
An organization shall provide secure and appropriate disposition for information no longer required to be maintained by
applicable laws and the organizations policies.
management. Governance is strategic, while management is

tactical. Governance is top-down and answers what needs to
happen, while management is bottom-up and addresses how
to get it done. Governance sets organizational goals, direction,
and limitations, whereas management oversees the day-to-day
operations of the organization.
With this in mind, AHIMA set out to establish a set of comprehensive IG principles to guide organizations that interact with
and manage healthcare information. Some examples of these
organizations include healthcare service providers in all settings and non-providers such as information exchanges, claims
administrators, payers, and researchers. The data that need to
be governed encompasses all the information of a given organization, both clinical and non-clinical, and in all formats, both
electronic and analog.
AHIMA developed the IGPHC specifically for a broad range of
healthcare organizationsregardless of type, location, or size
to govern information across all functions of the organization.
Developing IGPHC Required a Balance of Priorities

AHIMA gathered together healthcare industry leaders and
IG experts from other industries to adapt the IGPHC from
ARMA Internationals Generally Accepted Recordkeeping
Principles. The IGPHC Taskforce developed the principles,

and afterward two groups vetted them independently: the IG
Advisory Group and the AHIMA-appointed review group. The
IGPHC Task Force then revised the IGPHC according to those
recommendations.
These thought leaders developed IGPHC based on practical
experience, information theory, and legal doctrine inside and
outside healthcare. The areas of expertise represented were
HIM, records and information management (RIM), information
governance, informatics, health information exchange (HIE),
quality improvement, medicine, nursing, information technology (IT), law, privacy, security, and financial operations.
The IGPHC Task Force considered values important to healthcare such as accuracy, timeliness, accessibility, and integrity
when developing the principles. They also accounted for the
many competing interests of information stakeholders such as
workforce, regulators, auditors, patients, and society. The group
then distilled all of this detail down to eight IG principles, which
were created to be applicable across all healthcare industry organizations.
IGPHC and the Organization

As a best practice framework, IGPHC assists organizations in
14_October.indd 31
9/16/14 2:50 PM
The Way Forward
Maturity Model Evaluates Information Governance

AHIMAS INFORMATION GOVERNANCE Maturity Model provides a scalable IG framework so organizations can access
what they are doing well and where they need improvement
when using the eight IGPHC principles. The model organizes
and measures IG risks in a structure that can be easily understood and implemented by many different stakeholders and
audited periodically.
The maturity model allows a healthcare organization to
assess its processes and procedures according to IG best
practices and a clear set of external benchmarks. Maturity
for each IGPHC principle is ranked on a scale from one to
five, with one being sub-standard and five being transformational.
Most organizations will not be at the same level of maturity
for each principle, which is not only expected but acceptable.
Sometimes an organization may even be in-between levels,
scoring a 4.5 in accountability, for example. Few, if any, orga-
operating effectively while ensuring compliance with legal requirements and other duties and responsibilities. By promoting robust and repeatable processes, IGPHC helps establish
policy, prioritize investments, determine accountabilities,
protect information with suitable controls, and more generally reduce risk.
Think about the implications to the above scenarios of having
one authoritative IG source, namely IGPHC, and then consider
the healthcare industry more generally. According to IGPHC,
the information initiatives of Jane, John, and Carol in the above
scenarios require long-term and overarching policies, elevating
their projects from operational to strategic perspectives. More
importantly, IGPHC alerts organizations to the need for comprehensive information governance across an industry sometimes too bogged down by how (tactics) to determine what
(strategy).
IGPHC and the Practitioner

Healthcare information professionals benefit from IGPHC by
using it for IG program development, benchmarking, compliance initiatives, and auditing. IGPHC can be applied repeatedly
and in similar circumstances, allowing the information professional to practice consistently and confidently.
Further, IGPHC resonates with senior leadership when its
used as a framework to connect the organizations values
with its actions. The principleseither individually or collectivelyprovide common talking points for a large variety of
stakeholders, including the practitioner, senior leadership, IT,
compliance, and legal, to get on the same page and move forward together with an information governance project. Furthermore, by using AHIMAs associated maturity model (see sidebar
above), a practitioner can help guide the organizations future
IG decision-making and actions by tracking their progress
against IG Maturity Model benchmarks.
Remember Jane, John, and Carol? IGPHC could help them de-
nizations will score 5 in every category, much less even one,

since information governance is a continuous improvement
process.
The maturity model permits an organization to focus on
those areas of IG that it deems important. This can be certain
principles, a particular part of the organization, or even a specific process or procedure. This type of scalability promotes
a natural progression of IG improvement in terms of expectations and, more importantly, resources.
Knowing a maturity level for each IGPHC principle allows
an organization to improve in that area and make decisions
for future actions based on its risk appetite. The maturity
model can be used for gap analysis, benchmarking, risk assessment, and program evaluation and development.
The maturity model is expected to be available by the end
of the year. Watch AHIMAs website, www.ahima.org, for
more details.
termine what needs to be done based on their organizations

objectives. Then they could use the maturity model to measure
where the organizations IG is today, determine where it should
be in the future, and develop priorities for how remediation
and improvement will be accomplished. Afterward, they can
follow-up with routine monitoring, periodic reassessments, and
regular audits to ensure IG compliance and to promote continuous improvement.
Information in the 21st Century

For many years the healthcare industry has acknowledged
that information management is becoming increasingly complexvolume is increasing, variety is unparalleled, veracity is
sometimes questionable, velocity is lightning fast, and value is
increasing. For these reasons, AHIMAs IGPHC and its associated IG Maturity Model are powerful tools in the governance
and management of organizational information.
Like other frameworks, IGPHC is not intended to be prescriptive, nor is it intended to be used in the same way by every
organization every time. The purpose of IGPHC is to provide
points of reference for generally agreed upon IG best practices in order to conduct operations effectively while ensuring
compliance with legal requirements and other duties and responsibilities. In fact, good information governance increases
quality of care and patient safety, improves population health,
increases operational efficiency and effectiveness, and reduces costs.
What would Jane, John, and Carol say about IGPHC? That its
good for the organization, good for the information professional, and good for the healthcare industry.
Sofia Empel (sempel@infocentricstrategies.com) is president and chief information governance consultant at InfoCentric Strategies and a member
of the AHIMA Information Governance Principles for Healthcare Task
Force.
14_October.indd 32
9/16/14 2:50 PM
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EXPIRATION DATE: APRIL 1, 2015

Take quizzes online at https://www.ahimastore.org
Journal of AHIMA
Continuing Education Quiz
NOTE: BEGINNING JANUARY 1, 2015, MAILED/PAPER CE

QUIZZES WILL NO LONGER BE ACCEPTED. CE QUIZZES WILL
ONLY BE ADMINISTERED ONLINE AT WWW.AHIMASTORE.ORG.
Quiz ID: Q1418510 | HIM Domain Area: Performance Improvement | ArticleThe Way Forward
For an opportunity to receive CE credit

of 1 clock hour, mail this form with the
appropriate processing fee to:
AHIMA
Journal of AHIMA CE Quiz
PO Box 77-2735
Forms must be received by the
Expiration Date above.
First Name (please print)
Last Name
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Address
City
REFER TO THE ARTICLE for the one best answer to each question. Questions are based solely on the
content of the article.
1. Information Governance Principles for
Healthcare (IGPHC) is a framework
designed specifically for the
healthcare industry.

a. true

b. false
6. The eight principles of IGPHC provide

talking points for stakeholders to
move forward with electronic health
record implementation.

a. true

b. false
2. The mnemonic A TIP CARD is used

to:

a. address compliance issues

b. submit a claim for reimbursement

c. remember the eight principles
of IG

d. none of the above
7. IGPHC is a rigid, prescriptive

framework intended to be used in the
same way by every organization.

a. true

b. false
3. The eight IG principles are:

Accountability, Transparency,
Integrity, Protection, Compliance,
Availability, Retention and

a. Disposition

b. Destruction

c. Shredding

4. Electronic data requires a bottom-up

and a top-down approach using IG.

a. true

b. false
5. The five Vs were developed and based
on practical experience, information
theory, and legal doctrine inside and
outside healthcare.

a. true

b. false
8. This principle states that an

organization shall maintain
information in a manner that ensures
timely, accurate, and efficient
retrieval.

a. Protection

b. Availability

c. Disposition

9. The maturity model allows a
healthcare organization to assess its
processes and procedures.

a. true

b. false
10. T
he maturity model can be used for
gap analysis, benchmarking, risk
assessment and
evaluation.

a. overall

b. revenue cycle

c. program

d. a and b only
State, Zip Code
My check or money order payable to

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Quizzes received after the expiration printed at the top of this page will not be processed and the fee will be forfeited. Quizzes may not be retaken, nor can AHIMA
staff respond to questions regarding answers. Please allow a minimum of two weeks for delivery to AHIMA and four weeks for processing and return mailing of
the form certifying your completion of the CE activity. No record will be kept at AHIMA of your enrollment in this quiz.
14_October.indd 34
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Tracking HIEs
Ever Evolving
Operational
Models
EMERGING HEALTH INFORMATION EXCHANGE MARKET STILL SORTING
OUT ITS BUSINESS AND GOVERNANCE MODELS
By Kathy Callan, MA, RHIA; Jan Fuller, RHIA, CPHIMSS, FAHIMA; Lou Galterio, MBA, FHIMSS, CHIME, CP; Beth Just, MBA, RHIA, FAHIMA; Kimberly Reich, MBA,
MJ, PBCI, RHIA, CPHQ, FAHIMA; Christine Steigerwald, MBA, RHIA; Mary Lou Turner-Combs, RHIA; Sheldon H. Wolf; Julie Dooling, RHIA, CHDA; Annessa Kirby; and
Editors note: This article is part one of a two-part series analyzing the current state of health information exchange organizations and
their operational models.
14_October.indd 36
9/16/14 2:50 PM
Tracking HIEs Ever Evolving

Operational Models
HEALTH INFORMATION EXCHANGE (HIE) continues to be an

embryonic domaina swirling array of various public, private,
and robust electronic health record (EHR) models. Commenting on the state of contemporary HIE organizations (HIOs),
Irene Koch, executive director of the Brooklyn Health Information Exchange (BHIX), observed that evolution is still happening with all the systems and the standards.
Part of the difficulty in tracking the HIE realm results from the
variability of the HIE models and the HIE definitions deployed
in healthcare. As the number of operational HIEs continues to
grow, industry experts concur that eventual consolidation is
certain, as a combination of HIE governance models will need
to be put into position to assist an industry struggling with
working interoperability and information governance. The goal
will be to implement specifications in a variety of operational
frameworks that are repeatable, comprehensive, and preserve
the shared meaning.1
The Agency for Healthcare Research and Quality (AHRQ) reported that currently there are over 280 health information exchange organizations in operation and that over 50 percent of
the nations hospitals are actively participating in HIOs. Included among the ongoing initiatives are efforts to refine healthcare
operations, improve healthcare quality and outcome metrics,
enhance public health reporting, and advance research.2
Many HIE experts realize the need for parallel development of
both internal and external exchange. Robust internal exchange
is paramount to linking together an entitys physicians. But to
achieve accountable care organization (ACO) goals, meet requirements of the federal governments meaningful use EHR
Incentive Program, and ultimately serve the patient where they
choose to receive care, external exchange will also be critical.
The 2013 AHIMA Health Information Exchange Practice
Council recognized the evolutionary expansion of HIE models
and the strategic importance of developing HIE models, and
chose to charter a subgroup to review the emerging landscape
and provide perspective on the future state of HIE. Their research highlighted key differences in subscription-based versus
transaction-based HIE exchange models and the importance of
information and data governance for sustainability.
Five Critical Success Factors for Private, Public HIOs

The 2012 eHealth Initiative Special Report titled The Rise of
the Private Health Information Exchange and the Changing
Role of Public Health Information Exchange identified five
critical success factors for a private HIO. While the HIE Practice Council concurred with the importance of these five critical success factors and their importance to the success and
sustainability of private HIOs, they worked to expand upon
and add to the factors.
They contend that these factors of sustainability and success
are not solely limited to only private HIOs but could and should
be applied to all HIOs regardless of governance model.
Observed Traits of Transaction and

Subscription-Based HIOs
Transaction-Based
Non-Profit
Subscription-Based
Yes
For-Profit
Yes
EHR-to-EHR,
Direct
Yes
EHR via HIE
Yes
The six factors to HIO success, according to the Practice Council, are:3
1. Shared vision
2. Sustainable funding
3. Broad stakeholders
4. Physician engagement
5. Infrastructure
6. Information and data governance
The Practice Council believed that the eHealth Initiatives five
critical success factors for HIE were incomplete without the
inclusion of information and data governance, and therefore
added it to this list. Information and data governance allows entities to manage and control information by supporting enterprise endeavors and promoting compliance with its obligations.
It also strengthens the organization-wide framework for directing the creation and use of information critical to sustaining the
organizations strategy, operations, regulatory, legal, risk, and
environmental commitments.
Economics of HIE
The following overview is a comparison of HIOs that follow a
subscription-based exchange model and a transaction-based
exchange model. As HIE organizations mature they must transition away from public funding dependence, which until recently was the majority of HIOs primary funding source thanks to
federal and state grants aimed at kick-starting HIOs across the
country. However, that funding is starting to dry up.
As this transition occurs, HIOs are looking to hospitals as an
important source of revenue. However, for long-term financial
sustainability HIOs must seek revenue sources from emerging
interoperable, value-based collaborative care delivery models
and the successful governance, analysis, and use of HIE data.
Transaction-Based HIE
This model is normally found in a private market exchange,
though this is not a hard and fast rule. If there is a governance
organization controlling the HIE, it is usually a for profit vendor or entity that makes money over the cost of operations. In
14_October.indd 37
9/16/14 2:50 PM

Operational Models
the transaction model, cost and the operations of the exchange

activity is charged or passed on to the purchasers of the HIO
service or the owners of the EHR product, if there is one. Transactions fees could be charged per patient, per search, per visit,
or per result. A subscription fee can also be charged and based
on overall revenue or profit margin.
Also, in a transaction-based model of health information exchange, an EHR-to-EHR exchange tends to be used more often
than an EHR-to-HIE exchange, where in the subscription-based
model the output of the HIE is pushed or sent out to another
EHR or to the screen of an HIE portal user.
Participants may be charged for such items as the telecommunications medium; the software that makes exchange occur;
carrier charges; software maintenance to keep the EHR product
capable and certified; and overhead to pay for the operations
of the organization that enables exchange which, in this model,
many times is passed on to consumers implicitly by the EHR
vendors themselves. Another software cost that exists when
an exchange is transaction-based is for the development and
maintenance of various software interfaces that ensure traffic
flows among other HIOs or EHRs.
There may also be a margin built in for profit, but this is de-
termined by the larger business model. In more rare cases,

an intermediary that supports numerous EHR products such
as a regional health information organization (RHIO) may be
utilized. This role may become more common due to the new
guidance issued by the Office of the National Coordinator for
Health IT (ONC) and the Centers for Medicare and Medicaid
Services (CMS) regarding the modularity of certified EHRs
and the friendlier business atmosphere for these solutions that
now exists.
If there were a central organization that supported this model,
it typically has been found to be a for profit organization and
survives on profit margins. These profits could be distributed to
investors at some agreed upon financial target or attainment of
a clear and stated goal determined by investors or purchasers.
These financial targets can be immediate, per year, or after a
certain anticipated start up period where the entity shows ever
diminishing loss as profitability increases.
In the planning stage, this revenue model is usually determined in financial projection balance sheets and income statements in what are known as pro forma statements. These are
prepared previous to the birth of the organization and are part
of the business plan.4
14_October.indd 38
9/16/14 2:50 PM

Operational Models
Subscription-Based HIE
As noted earlier, the for-profit HIO costs may very well exist in
the EHR purchase price and ongoing costs but can be hidden
from obvious view in the vendors product line. Costs may be
dependent on the interchange agreement of the various EHR
vendors or be built into the softwares capability to be compatible with other systems based on published government standards. In a for profit model, HIE activity is a very real cost built
into the price of the EHR. In a non-profit subscription-based
model, the costs are explicit. The HIO or EHR vendors must
build in and pass on this cost to the consumers. Therefore, the
more expensive EHRs will have a higher probability of including
HIE functionality whereas the lower cost EHRs might be more
suited to using a subscription-based model.
The Practice Council observed that the economics of subscription-based HIOs are closely tied to non-profit governance organizations. HIOs are typically affiliated with non-profits. These
health information organizations are usually made up of community stakeholders. Even though a for-profit governance entity
can be called an HIO, it usually is formally not. A for-profit runs
with a board managed through a corporation, or it could simply
be a part of another vendor organization whose mission, at least
in part, is to turn a profit for stakeholders.
No matter how it is viewed, a true tax-exempt non-profits
costs are always paid for in some way by the taxpaying public,
whether it be a grant, some form of direct or indirect tax, or
some break even type of membership arrangement where the
organization, in order to keep its legal tax status, must collect
membership dues in order to stay afloat.
The public expects government to work and expects the taxes
they pay to ensure that any government function taken on also
works. HIE is another level of sustaining the public good that is
funded by taxes, and should therefore work.
With private investment in a for-profit HIE, functionality is
clearly purchased and it is expected to work from that private
funding. The consumer knows what they are buying; money
comes out of their pocket and into the investment either as a
purchase or as an expected return on utility with the expectation
that the return will be higher than what was put in originally.
In the subscription non-profit model, HIE is typically thought
of as a noun. In this noun, there is an implied repository (central or networked) that stores the data and subscribers go to that
repository to get the data. The repository is expected to have
data that are current and correct. Users may go to the repository
to get data in what is known as a pull model, or the repository
itself may have some software or networking mechanism built
into it to push the data to the users. The push model typically
pushes data to the EHRs of the subscribers.
or subscription fees. Everyone who pays taxes supports the

public non-profit HIOs, although not everyone receives direct benefit.
One can make the case that everyone benefits from publiclyfunded HIE as it is the entire and intersecting working network
of the public and private markets that makes the concept function and that the points of intersection could not exist without
both models. In this case, one can view the model in degrees
of direct utility for subscribers versus indirect beneficiaries who
are not subscribers. In transaction-based models, HIE is viewed
as a verb. From this perspective, HIE is not seen as an entity.
Data are updated and moves between EHRs but is not kept or
stored in one place.
It is too early to tell which HIE model is best for the improve-
Best Model Yet to Be Seen

The HIE as a repository, or noun, stays funded as a result of
public investment related to taxation as described above, and/
14_October.indd 39
9/16/14 2:50 PM

Operational Models
ment of healthcare, and which will survive the rigors of real-life

testing. For now, to get off the ground, HIE will need a variety of
models to be able to scale up sharing among physicians, hospitals, and patients and across care settings.
In the second installment of this two-part article series, the
authors will address whether HIEs are ready to support the information needs of the new value-based, patient-centric, and
outcomes-measured health system.
Notes
1. Enrado, Patty. HIE Industry is Still Evolving HIEWatch.
February 13, 2013. http://www.hiewatch.com/perspective/hie-industry-still-evolving.
2. Overhage, J. Marc. Trends in Health Information Exchanges. Agency for Healthcare Research and Quality.
March 26, 2014. http://www.innovations.ahrq.gov/content.aspx?id=3944.
3. eHealth Initiative. The Rise of the Private Health Information Exchange and the Changing Role of Public Health
Information Exchange. 2012. http://www.ehidc.org/component/dms/view_document/257-white-paper-optumthe-rise-of-the-private-health-information-exchange-
Coding Compliance AuditsMS-DRG/APR-DRG/APC

HCC, LTAC, Pro-Fee, CVIR/IR
ICD-9/ICD-10 Dual Coding Reviews
Online ICD-9 and ICD-10 Tutorials
Denial Reviews and Appeals
HIM Interim Management
Remote Coding Support
Medical Necessity Reviews
and-changing-role-of-public-exchanges-data-exchange.
4. Baldwin, Gary. Which Way for Data Exchanges? Health
Data Management 20, no. 3 (March 2012): 26. www.
healthdatamanagement.com/issues/20_3/Which-Wayfor-Data-Exchanges-44120-1.html.
Kathy Callan (kmcalla1@gundersenhealth.org) is director, HIM/clinical
systems, information systems at Gundersen Lutheran. Jan Fuller (fuller@
latech.edu) is associate professor at Louisiana Tech University. Lou Galterio (lgalterio@ieee.org) is president of SunCoast RHIO, Inc. Beth Just
(bjust@justassociates.com) is CEO/president of Just Associates, Inc.Kimberly Reich (KBStried@aol.com) is privacy and compliance officer at Lake
County Physicians Association. Christine Steigerwald (Christine.Steigerwald@bannerhealth,com) is senior director of HIMS operations at Banner Health. Mary Lou Turner-Combs (MaryLou.Turner@ky.gov) is enterprise MPI project manager at the Kentucky Governors Office of Electronic
Health Information, Cabinet for Health and Family Services. Sheldon H.
Wolf (shwolf@nd.gov) is the North Dakota Health Information Technology Director. Julie Dooling (Julie.Dooling@ahima.org) is a director of HIM
Practice Excellence at AHIMA. Annessa Kirby (annessa.kirby@ahima.org)
is a practice council manager at AHIMA. Harry Rhodes (harry.rhodes@
ahima.org) is a director of HIM practice excellence at AHIMA.
Focus On
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Presidents Message

Journal of AHIMA

Quiz ID: Q1428510 | HIM Domain Area: Performance Improvement | ArticleTracking HIEs Ever Evolving Operational
Models

AHIMA
PO Box 77-2735
Last Name
Address
1. Variability of HIE models and HIE
definitions deployed in healthcare
today make it difficult to track overall
HIE results.

a. true

b. false
2. HIE experts see the need for parallel
development of both internal and
external
.

a. audits

b. policies and procedures

c. exchange

3. As HIE organizations mature they
must transition away from public
funding dependence.

a. true

b. false
4. What type of fee is based on revenue?

a. transaction

b. activity

c. subscription

d. usage
5. The transaction-based model is used
more often in this type of exchange:

a. EHR to HIE

b. EHR to EHR

c. HIE to EHR

6. Pro Forma statements are prepared

after the organization has been
operational for a year.

a. true

b. false
7. Which item(s) can participants be
charged for?

a. telecommunications medium

b. carrier charges

c. overhead

d. all of the above
8. Economics of subscription-based HIOs
are closely tied to:

a. for-profit organizations

b. non-profit organizations

c. both a and b

9. HIE is thought of as a noun in the:

a. hybrid model

b. electronic model

c. non-profit model

10. T
axpayers support the public nonprofit HIOswhere everyone
receives a direct benefit.

a. true

b. false
City
State, Zip Code

* $15, Member
* $25, Non-member
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9/16/14 2:50 PM
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SLOW to the Information

Governance STARTING LINE
FIRST-OF-ITS-KIND SURVEY TRACKS HEALTHCARES
IG EFFORTS, SHOWS MOST ORGANIZATIONS ARE BEHIND
By Chris Dimick
Majority of Healthcare Organizations Lack Vital Information Governance Strategy

AHIMA HAS FIRED the starting pistol heralding in the urgent race to implement information governance (IG) practices
within the healthcare industry. While some organizations were
quick off the blocks and have been making broad strides in IG,
the majority of healthcare stakeholders are still moseying up to
the starting line.
This is the picture painted by the 2014 Information Governance in Healthcare Benchmarking White Paper, which
analyzes the first major survey conducted to study the information governance practices of healthcare organizations. Developed by AHIMA and Cohasset Associates, and released in
May, the study revealed that only 35 percent of healthcare organizations have a comprehensive strategy guiding information governance efforts.
Two-thirds of the respondents, or 65 percent, said they lack a

strategy for information governancewell below what AHIMA
experts say is warranted given the rising importance of quality
health information in reimbursement, audits, and delivering effective care.
AHIMA officials are using the results of the study, subtitled A
Call to Adopt Information Governance Practices, to gauge what
next steps they should take to help lead healthcare organizations toward better IG practices. The mission is core to that of
all health information management (HIM) professionals, with
AHIMA publicly stating that information governance practices
are the key to the future of the health information management
field and necessary if healthcare ever wants to use health data
and information to improve its care and financial processes.
14_October.indd 44
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Slow to the Information

Governance Starting Line
IG in Healthcare Benchmarking Survey: Organizations Main Drivers for IG
Regulatory compliance
HIGH - HIGHEST
Improve patient safety/patient care
Lack of trust or confidence in data
36%
Strongly Agree
11%
45%
44%
20%
9%
45%
46%
New care delivery models

(population health management)
9%
41%
50%
Need to integrate and/or improve

systems and technologies
8%
38%
54%
Need for increased standardization
8%
35%
57%
Changing payment environment
7%
32%
61%
Need for clinical, quality and/or

business analytics
5%
22%
73%
Need to manage and contain costs
2%
18%
80%
Mostly Agree
44%
Strongly or Mostly Disagree
Cohasset Associates and AHIMA. Information Governance in Healthcare A Call to Adopt Information Governance Practices. 2014.
http://www.ahima.org/IGwhitepaper.
Information governance is a strategic imperative for all organizations within the healthcare ecosystem, says AHIMAs Chief
Operating Officer and Executive Vice President Deborah Green,
MBA, RHIA. Improved quality and patient safety, cost control,
care delivery redesign, and responding to regulatory changes
are top goals for healthcare organizations, and all are dependent on trustworthy information.
Healthcare IG Less Mature than Warranted

The IG survey and white paper evaluate and quantify the state of
healthcare information governance maturity and effectiveness,
address the information challenges facing the healthcare industry, and offer a roadmap for organizations to effectively govern
their health and business information.
Information governance has been defined by AHIMA as:
An organization-wide framework for managing information
throughout its lifecycle and for supporting the organizations
strategy, operations, regulatory, legal, risk, and environmental
requirements.
The low adoption rate may be due to information governance
being a relatively new initiative for the healthcare industry.
While most organizations have governance programs for certain healthcare functions, such as privacy and security policies,
the survey showed that an organization-wide information governance program had not yet been established in the majority of
provider organizations.
Privacy and security policies had the highest maturity ranking
at 50 percent, while information preservation policies were only
at 30 percent and information deletion and destruction policies
at 26 percent. These maturity levels are below acceptable for an
industry that handles highly sensitive personal information,
Green says.
The survey showed four trends in the current state of healthcare IG awareness and practices:
1. O verall, IG programs are less prevalent and less mature
in healthcare organizations than is warranted, given the
importance of information.
2. Most organizations have not yet established a comprehensive strategy for information governance, or approached
information governance in a formal way.
3. The information governance framework and its foundational components call for strengthening and expansion.
4. Information lifecycle management practices related to
core functions require improvement.
These are issues that need to be addressed as soon as possible
in healthcare in order to maxmize the use of data as an asset and
improve care processes. AHIMA officials hope it will be HIM
professionals who grab the racing baton and lead their organizations down the information governance track.
14_October.indd 45
9/16/14 2:50 PM

Survey: Do You Have a Comprehensive Strategy for IG in Place?
65%
DONT KNOW OR
DO NOT HAVE IG
PLANS IN PLACE
34%
35%
31%
Yes
No
Dont know
Cohasset Associates and AHIMA. Information Governance in Healthcare A Call to Adopt Information Governance Practices. 2014.
http://www.ahima.org/IGwhitepaper.
Healthcare Sees Need for IG Practices,

But Slow to Start
The majority of the 1,000 healthcare-based survey respondents,
65 percent, stated that they recognize the need to formalize
information governance practices and align how information
is managed across all functional areas. Of these respondents,
however, only 43 percent have actually initiated an information
governance program and 22 percent have not started an IG program at all.
While information governance practices currently have a low
adoption rate, the need is on healthcare professionals radar
and efforts are rising. A total of 84 percent of respondents have
seen governance measures improve, and 91 percent anticipate a
significant rise in information governance practices in the next
three years.
We need information we can trust if we are going to achieve
the Triple Aim of healthcare, Green said during an August webinar discussing the results of the study.
Information governance is also central to health information
exchange, since providers need to first trust that the information
they are receiving from another provider is accurate and properly managed, then they need internal governance processes
to ensure that the information is properly integrated into their
electronic health record (EHR) systems.
The study showed healthcare organizations agree that there
are compelling drivers for formally launching an information
governance program and improving practices, with 95 percent
stating the ability to improve quality and safety of patient care as
a key driver for implementing IG practices. Managing and containing costs and responding to a changing payment environment were also noted as key drivers for formalizing IG practices.
The survey results are undeniable. Information governance is
a strategic imperative: regulatory compliance, safe quality care,
cost control, responding to changing reimbursement systems
and evolving delivery models, are top goals for healthcare or-
ganizations, the white paper states. All are highly dependent

on trustworthy information. These organizational goals are advanced through the adoption of information governance practices; the absence of IG will impede their achievement.
The key drivers for adopting IG practices identified by respondents were regulatory compliance (98 percent), improving patient safety/patient care (95 percent), and to manage and contain costs (93 percent). The lowest ranked driver was lack of
trust or confidence in data at 56 percent, which Green says she
is surprised by. This shows many providers just implicitly trust
their data are correct without having the proper governance
controls in place to ensure it is actually trustworthy.
There are important implications for data quality here as
results showed that foundational work in measures and metrics were immature. If we havent defined metrics for our expectations, how can we say we trust our data? Green says.
Survey findings on quality controls and quality improvement programs showed that attributes of quality, metrics, and
improvement protocols are not as well defined or well understood as expected.
Education and Buy-In Still Needed

Industry-wide education on the benefits of information governance is necessary, according to the study. While 65 percent
recognize the need for IG programs, 24 percent didnt know if
their organization had a formal plan.
This statistic is concerning, Green says, since the survey respondents were individuals who should know whether an IG
plan exists or not. The IG survey of AHIMA and non-AHIMA
members targeted clinical and non-clinical executives, officers,
directors, and managers in provider and non-provider organizations within the healthcare industry. The survey received
more than 1,000 responses between March and April 2014.
The highest number of respondents were in information/
records management job roles, followed by information and
14_October.indd 46
9/16/14 2:50 PM

data quality, and then privacy and data protection. A total of 46

percent of respondents were directors, with 20 percent at the Csuite level and 15 percent at the management level.
When adopting an information governance strategy, AHIMA
recommended creating IG programs that are cross-functional
and have the support of senior-level staff. An organizations governance focus should not just be on clinical information, but on
non-clinical, business, and operations information as well.
I encourage my colleagues in the C-suite to make a comprehensive information governance strategy an organizational priority, says AHIMA CEO Lynne Thomas Gordon, MBA, RHIA,
FACHE, CAE, FAHIMA. Its easy to think it can be put on hold
or maintained in one department while executives deal with
other challenges, but this is a mistake.
Developing a strategy should be a collaborative effort and is
essential to realizing the benefits of governance.
Effective information governance programs need to have clear
measures for success and a pointed mission. When discussing
quality improvement programs instituted as part of information governance activities, the survey respondents showed they
were focusing on some, but not all, areas identified by AHIMA
for improvement. For example, 68 percent stated that they are
formally assessing the impact of system upgrades on information quality. But only 60 percent said they have been working to
improve the rate of their master patient index (MPI) accuracy
over the past three years, and 26 percent said they didnt know
if this measure was being tracked. That is an issue, Green says,

since errors in the MPI can have significant effects on the quality of care provided. Part of the issue could be finding focus in
providers IG efforts. When asked if the desired attributes of information quality are explicit and understood, only 24 percent
strongly agreed and 44 percent mostly agreed.
Even Mature Governance Programs Need Attention

Even mature specialized governance programs need attention,
according to the survey. While 97 percent of respondents said
essential policies for maintaining private and secure protected
personal health information were in place in their organizations, only 81 percent reported that business associate agreements were enforced and routinely audited. Just 80 percent report routine and comprehensive auditing for compliance with
privacy and information security practices. Since these are core
HIM compliance areas, the result should be closer to 100 percent, AHIMA officials say. The recent changes to HIPAA law
and increased penalties for data breacheshave made it even
more important for healthcare organizations to monitor their
privacy and security, as well as their association with third-party businesses.
Also, only 37 percent of healthcare organizations said they had
the ability to preserve only relevant informationin either paper or EHRsin response to a legal hold. One of the first strides
organizations should take when implementing IG practices is
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to enact detailed information disposition policies that govern

when information is retained and destroyed, as well as transferred if moving to a new electronic system or merging with another provider. We found opportunities to improve disposition
core functions in healthcare organizations, Green says.
The survey also measured the maturity of select IG components, many of which organizations should already be doing, to
gauge how much work providers needed to do to get their programs up to speed with IG. While 26 percent reported having a
mature business continuity, disaster recovery, and crisis management policy in place, only 15 percent said they have a mature
data map that identifies key information repositories. A total of
31 percent of respondents said they were making improvements
to their data mapping capabilities.
AHIMA Recommends IG Actions

In light of the need for IG improvements at most healthcare facilities, the IG white paper recommended various actions HIM
professionals and healthcare providers should take to improve
the quality of their information.
To achieve the full benefits of information governance initiatives, AHIMA recommends organizations develop the following:
A n accountability framework and decision rights to ensure the effective use of information across an enterprise
Defined processes, skills, and tools to manage information throughout its entire lifecycle
Information standards, rules, and guidelines for functioning in an increasingly electronic environment
Specific action included the call to HIM professionals to build
awareness of the importance of IG and the direct impact of IG
on the advancement of organizational goals. As part of this education, individuals should illustrate how IG supports top goals
for healthcare organizations, and designate senior sponsorship
and a champion that can enthusiastically lead the change management effort for effective IG, Green said during her webinar
presentation.
Information governance efforts should be directly tied to an
organizations strategy, Green says, that aligns implementation
outcomes to an organizations goals and priorities including
patient care, organization performance, and risk mitigation. A
cross-functional IG steering committee should be chartered to
strengthen integration across all IG disciplines, which makes
the program more organizationally comprehensive.
Organizations should then prepare a comprehensive maturity assessment for their IG program and create a plan to implement IG strategy. All IG goals and achievements should be
communicated to staff and trends highlighted by the collection
of meaningful metrics based on direct actions. AHIMA also recommends in the paper that organizations adopt a long range
change management program to continuously build IG support
and improve compliance.
IG is long term work, and requires us to rethink how we are
using and managing information today, Green says.
The white paper also recommends organizations reanalyze their information lifecycle management and use IG to
strengthen their practices, from record creation or receipt

through final disposition. Formalized IG practices should be
implemented to enhance information integrity, quality, and
trustworthiness, and interdepartmental teams should be
created to develop and apply workable IG practices to newer
technologies and information types. For example, the paper
says organizations should define effective practices to identify
and preserve information needed for legal holds, and have the
ability to reinstate business-as-usual practices once the legal issue has been resolved.
Survey Just the Start of AHIMAs IG Efforts

In addition to publishing a white paper on the survey results,
this year AHIMA has been convening healthcare stakeholders to
develop an information governance framework for healthcare,
has established an expert advisory group to review and provide
input into information governance development efforts, and is
developing resources and guidelines to aid in operationalizing
IG in healthcare. While AHIMA has currently been defining
what information governance is for healthcare, the next step
will be defining how to use information governance in an operational sense to improve processes and care, Green says.
During this months 86th Annual AHIMA Convention and
Exhibit the association will unveil its Information Governance
Principles for Healthcare, eight guidelines organizations can
use to help frame its IG programs (see the article on page 30 for
more information about the principles). A Maturity Model SelfAssessment is also being developed to help organizations measure their IG efforts. Another IG survey is also likely in the near
future, this time focusing on the job roles of IG and how healthcare roles in general have changed due to the ever advancing
electronic environment.
In 2015 AHIMA will launch an information governance pilot
where healthcare organizations will take the IG Principles for
Healthcare and Maturity Model and work on integrating them
into actual practice. This will help operationalize IG for others
to mirror in their IG programs, AHIMA officials say.
AHIMA officials say they feel this first survey and white paper
serves as a good initial measurement of healthcares progress in
the information governance marathonbut there is still much
more track to cover. This survey shows that healthcare organizations need to develop and implement a strategy for governing information, Green says. Ensuring reliable information is
available where and when it is needed depends on it.
Chris Dimick (chris.dimick@ahima.org) is editor-in-chief of the Journal of
AHIMA.
Read More
2014 Information Governance in Healthcare
Benchmarking White Paper
www.ahima.org/IGwhitepaper
Read the full white paper and see complete results from the 2014 IG
survey online. A webinar discussing the survey results and the white
paper is also available online at www.ahima.org/topics/infogovernance.
14_October.indd 48
9/16/14 2:50 PM
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Leading
Your Facility
Through
the ICD-10
Delay Storm
By Kelli Horn, RHIT, CCS
14_October.indd 50
9/16/14 2:50 PM
Leading Your Facility Through

the ICD-10 Delay Storm
WHEN THE CENTERS for Medicare and Medicaid Services

(CMS) announced in the spring of 2014 that ICD-10-CM/PCS
would be unexpectedly delayed for at least one year, the health
information management (HIM) community was shocked.
Hospitals, healthcare facilities, and educational organizations
had been budgeting, planning, and carrying out essential job
functions in preparation for the October 1, 2014 implementation date. Now that several months have passed, and a new
implementation date of October 1, 2015 has been set, these organizations are still faced with many decisions, including:
Do we continue educating our coders in ICD-10 or do we
delay or halt the training?
Do we continue our dual coding/auditing initiative for reimbursement, productivity, and educational gap analysis?
Do we continue rewriting physician queries to reflect ICD10 terminology and concepts or return to ICD-9 language?
Because budget dollars and ICD-10 preparedness and readiness are at stake when the ICD-10 code set is finally implemented on October 1, 2015, organizations must evaluate and decide
what is best for them. However, since the industry is expecting
the 2015 conversion date to stick, organizations should keep
moving forward with coder, clinical documentation improvement (CDI) specialist, and physician education on ICD-10.
As healthcare leaders, HIM professionals are poised to help
lead their facility through this ICD-10 delay storm. Below are six
ways HIM professionals can be seen as courageous leaders in
the frustrating and dramatic conversion to ICD-10.
1. Prepare for ICD-10and the Unexpected

Healthcare facilities know another storm is coming. The official
code set will convert to ICD-10 in October 2015, unless an unexpected delay pushes it back for a third time. While always a
possibility, CMS has shown signs that it is throwing all its weight
behind keeping the 2015 deadline in place. This can be compared to a city being told that a storm will be coming in one
year. It could be a tornado or an earthquake, but nobody knows
for sure. Therefore, the city would be wise to prepare for both
storms. Thats how it is with the current ICD-10 delay storm.
Healthcare facilities may be converting to the ICD-10 code set
or remaining with the ICD-9 code set on October 1, 2015. Nobody knows for sure. Therefore, healthcare facilities would be
wise to be prepared for both code sets.
2. Become a Cheerleader
Healthcare facilities should stay the course with their current
ICD-10 initiatives. Leadership should remain fully focused and
encourage others verbally, and by example, to stay the course
with ICD-10 implementation. Staff may become frustrated or
disgruntled, but HIM professionals have an opportunity to defuse the negativity and move forward. They can do this by validating their staff members natural fear of the unknown and
the stress that accompanies major change, and by promoting a
Weve got this attitude.
Reading Resources on ICD-10

AHIMAs ACHIEVING ICD-10-CM/PCS Compliance
in 2015: Staying the Course for Better Healthcare A
Report From the AHIMA 2014 ICD-10/CAC Coding
Summit, published in Perspectives in Health Information Management, provides further guidance regarding
coding accuracy and productivity, clinical documentation improvement, and delay opportunities. http://
perspectives.ahima.org/achieving-icd-10-cmpcscompliance-in-2015-staying-the-course-for-better-healthcare-a-report-from-the-ahima-2014-icd10cac-coding-summit/#.U-p_2WM0GIo
The Journal of AHIMA Practice Brief Using CDI Programs to Improve Acute Care Clinical Documentation
in Preparation for ICD-10 published in June 2013
can also provide further CDI assistance. http://library.
ahima.org/xpedio/groups/public/documents/ahima/
bok1_050207.hcsp?dDocName=bok1_050207
3. Keep Moving Forward with Education

Before the delay went into effect, Ardent Health Services, a company based in Nashville, TN, that owns and operates 12 acute
care hospitals in Albuquerque, NM (Lovelace Health System),
Tulsa, OK (Hillcrest HealthCare System), and Amarillo, TX (BSA
Health System), was working with a consulting firm to carry
out the physician, coder, and CDI specialist education, while
carrying on business as usual in an ICD-9 world. Below is a
summary of Ardents implementation efforts before the ICD-10
delay was announced.
Physician Education
This one-year initiative of educating physicians with high dollar and high volume visitsOB/GYN, cardiac, general surgery,
and orthopedicshad just been completed when the delay occured. Upon completion of their relevant ICD-10 education,
CDI specialists had planned to follow up with CDI coaching
sessions and share case examples of how the physicians could
specifically improve their documentation due to ICD-10 higher
specificity requirements.
Clinical Documentation Improvement Education

CDI specialists had been evaluating patient visits from an ICD10 perspective, asking questions and researching answers related to concurrent coding and query revisions. They were also
receiving bi-weekly ICD-10 education.
Coder Education
Inpatient and outpatient coders had completed extensive online anatomy and physiology, pathophysiology, and ICD-10
training, and were moving quickly to actually practicing coding
in ICD-10. Some coders were dual coding and receiving educational feedback.
14_October.indd 51
9/16/14 2:50 PM
Leading Your Facility Through

the ICD-10 Delay Storm
Despite the delay, Ardent is staying committed to their current education initiatives. They are making only frequency and
timeline adjustments due to the delay. Selected coders were
performing dual coding three to four hours per week before
the delay, and now that has been pushed until the fourth quarter of 2014 or first quarter of 2015. In the meantime, all coders
have been assigned more online educational lessons to assist
in keeping their ICD-10 knowledge at an acceptable level. CDI
specialists were receiving weekly ICD-10 education, and that
has decreased to monthly education. The ICD-10 Query Committee is still meeting on a weekly basis to revise existingand
create newqueries to reflect ICD-10 terminology and documentation initiatives. Finally, physicians had completed their
ICD-10 training, however, refresher training will be re-evaluated in 2015. Ardent is leading by exampleother facilities should
also continue physician, CDI specialist, and coder training even
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though a delay of ICD-10 implementation has occurred.
4. Self-Educate to Stay ICD-10 Sharp

Leaders should ensure they are staying up-to-date with ICD10 codes and concepts. There are many educational resources
available, including online AHIMA courses for HIM coding
professionals, physicians and clinicians, and non-coding
healthcare professionals. Another resource includes selfeducation using the published ICD-10-CM and ICD-10-PCS
code books. In addition, leaders should stay current with the
quarterly Coding Clinics published by the American Hospital
Association.
5. Volunteer to Educate Others on ICD-10

Because the ICD-10 transition affects all healthcare workers
directly or indirectly, a vast amount of education is needed
from all professions. Clinicians, ancillary staff, physicians,
coders, and CDI specialists will all need to be trained in ICD10 to some degree. If possible, volunteer to educate these individuals. If public speaking is not something of interest, there
are other behind-the-scenes tasks that need to be completed
during this time. One could create an educational slide deck
for the presenter, make copies of slide decks for session participants, schedule educational sessions and contact potential
participants, conduct follow-up calls to remind employees of
upcoming sessions, and coordinate follow-up action items
from sessions.
6. Stay Involved and Help Adjust Timelines

Discussions involving implementation timeline adjustments
should continue due to the delay. Attending local, regional,
state, and national coding seminars and conferences is imperative to continue being exposed to ICD-10 coding, terminology,
and concepts. Staying informed and up-to-date with the following resources is a vital part of this delay, such as ahima.org,
Journal of AHIMA, AHIMA Advantage, CodeWrite, ICD-TEN,
and other related resources.
Keep Moving Forward

Healthcare leaders should keep moving forward in their ICD10 initiatives, including physician, coder, and CDI specialist
education, if they want to be prepared for the brewing ICD-10
implementation storm. Staying committed to current facility
ICD-10 initiatives should remain a high priority, with variance
related to frequency and timeline adjustments.
Now is the time for leaders to step up to the plate and assist
with ICD-10 initiatives through the delay storm. They should
throw out the Its not my job mentality and help during these
uncertain times. As a result, healthcare facilities will be ready to
embrace the ICD-10 code set in the near future.
Kelli Horn (Kelli.Horn@hillcrest.com) is an AHIMA-approved ICD-10CM/PCS trainer and the coding education manager at Ardent Health Services. She is also an adjunct coding instructor at Tulsa Community College.
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2014
CONVENTION
GUIDE
SEPTEMBER 27 OCTOBER 2, 2014
SAN DIEGO CONVENTION CENTER, SAN DIEGO, CA
PRE-CONVENTION EVENTS
SEPTEMBER 27-28, 2014
CONVENTION AND EXHIBIT
SEPTEMBER 29-OCTOBER 1, 2014
POST-CONVENTION EVENTS
OCTOBER 2, 2014
14_October.indd 54
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YOUR GUIDE TO CONVENTION 2014
This year has been both an exciting and challenging one for the healthcare industry. Therefore, the 86th Annual
AHIMA Convention and Exhibit has been designed to provide a space where health information management
(HIM) professionals can address the challenges and opportunities that face the healthcare industryboth now and
in the future. The theme for this years meeting, Leading the Way to Health Intelligence, serves as a guideline for
the discussions that will take place as industry and government thought leaders and experts facilitate thoughtprovoking sessions and panels with a focus on how HIM is transforming the healthcare industry.
Attendees can expect to gain new insights on the evolution of the HIM field and HIMs role in healthcare,
connect the dots on how HIM roles are likely to evolve, and gather information that will support efforts to move
organizations forward in embracing the benefits of expanded HIM roles. Some highlights of the convention
include:
Exhibit hall showcasing the latest technologies and solutions for healthcare
AHIMA Foundation Thought Leaders Lecture Series
Educational site visits
Professional Development and Career Center
AHIMA, AHIMA Foundation, and Journal of AHIMA booths
IFHIMA Business Meeting
AHIMA Foundation Silent Auction
Networking events
Educational sessions on a variety of topics
Visit www.ahima.org/convention for the latest updates to the convention program, and to view an informational
video on the event.
BREAKING NEWS DELIVERED ONLINE
Whether at the event or back home, you can follow all of the convention action online. Look for special e-Alert
announcements linking you to a full online edition of AHIMA Today, the on-site convention newspaper. Also, visit
the Journal of AHIMAs website, http://journal.ahima.org, for special convention coverage in the days leading up
to convention and during the event.
To get news by the minute, follow the convention on Twitter with the hashtag #AHIMACon14 as staff and
attendees post updates you can receive on your computer or phone. Sign up at http://twitter.com/ahimaresources.
14_October.indd 55
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Learn about the Latest HIM

Products and Services in the
Exhibit Hall
The exhibit hall will feature

approximately 200 exhibitors.
Discover leading-edge products and
services and earn 1 CEU by visiting the
exhibit hall. An exhibitor Scavenger
Hunt game features the chance to
win a $500 AmEx gift cheque.
The following is a list of exhibitors
as of September 1. Check for
convention updates at www.ahima.
org/convention.
3M Health Information
Systems
A2iA
ABT Medical Inc.
Access
Addison Group
AGS Health
AHA Central Office
AHDPG
AHIMA
Alpha II, LLC
Allegra Health, Inc.
American Medical
Association
Amphion Medical
Solutions
Anthelio Healthcare
Solutions
ARGO
Art2Link
Artificial Medical
Intelligence Inc.
Asante Alliance
Ashford University
Association
for Healthcare
Documentation Integrity
Aviacode
BACTES
Baylor Health Care
System
Beacon Partners
Berkeley Research Group
BizTech Healthcare
Solutions
Bottomline Technologies
Caban Resources
CAHIIM
Care Communications
Inc.
Career Step
CCHIIM
CDIMD-Falcon
Consulting Group
Channel Publishing
ChartMaxx by Quest
Diagnostics
ChartWise
Clinical Architecture
Coastal Healthcare
Consulting
CodeBusters, Inc.
CODEMED, Inc.
Coding Concepts, LLC
Coding Network, LLC
CodingAID
COMFORCE
Cornerstone OnDemand
CRG Medical
Cynergistek, Inc.
Data Distributing, LLC
Decision Health
Dell
Digital Transcription
Systems, Inc.
Diskriter, Inc.
Diversified Medical
Records Services
Dolbey
DriverSavers Data
Recovery
East Carolina University
eCatalyst Healthcare
Solutions, Inc.
Eclat Health Solutions
EDCO Health Information
Solutions
ELSEVIER
Elsevier | MC Strategies
Enovative Technologies
EPSON
eSolutions
Excite Health Partners
Executive Health
Resources, Inc.
Find-A-Code
For The Record
FormFast
Fujitsu Computer
Products of America
FutureNet
GeBBS Healthcare
Solutions
GRM
Guardian Analytics
HCPro/ACDIS
Health Data Consortium
Health Data
Management
Healthcare Coding and
Consulting Services (HCCS)
Healthcare Cost Solutions
Healthcare Resource
Group
Healthcare Source
HealthPort
HFMA
HIA
himaginesolutions
HIMOAP
HIMSS
HIMSS Communications
HRS
Huff DRG REVIEW
Hyland Software, Inc.
I.D.S.
GENERAL SESSION HIGHLIGHTS
Standing Up to Cancer
Rob Lowe
Actor and cancer awareness advocate Rob Lowe will

present the closing keynote address at AHIMAs 86th
Convention and Exhibit on Wednesday, October 1.
The star of some of the most iconic films and television
shows of a generation, Rob Lowe is also a New York
Times bestselling author and a passionate advocate
on issues related to healthcare, cancer awareness,
sobriety issues, the environment, and entertainment. Personally
impacted by cancer (both his mother and grandmother died from
breast cancer, and his father survived non-Hodgkins lymphoma) Lowe
knew he had to get involved and take a stand against cancer. Lowe
will talk about his experiences with the disease, and the importance
of continued work by everyone to support cancer survivors. After his
presentation, Lowe will participate in a book signing.
Federal Update
Karen B. DeSalvo, MD, MPH, MSc, National

Coordinator for Health Information Technology
Karen B. DeSalvo, MD, MPH, MSc, has focused her
20-year career on improving access to affordable,
high-quality care for all people, especially
vulnerable populations, and to improving overall
health. A physician, DeSalvo has done this through
direct patient care, medical education, policy and
administrative roles, and as a researcher. As the national coordinator
for health information technology, she is leading the nations charge to
promote, adopt, and meaningfully use health information technology
in order to achieve better care, lower costs in healthcare, and improve
the overall health of everyone in the US.
Inspired Leadership
Rich Bluni, RN
Sometimes the very qualities that make healthcare

leadership so deeply rewarding can also make it a
challenge over time to sustain energy and passion.
In this presentation, Rich Bluni, RN, author of
Inspired Nurse and Oh No! Not More of That Fluffy
Stuff, provides a wealth of action-oriented spiritual
stretches that helps more fully integrate the
rewarding gifts of healthcare into healthcare professionals daily lives.
Inspired Leadership is a welcome validation that when professionals
stay engaged and committed, theyre more likely to achieve the best
results in terms of both clinical outcomes and human compassion.
On the Front Lines of Healthcare: A Case

Study of Data-Driven Dialogue with the
Department of Defense
Jeff Arnold, Chairman and CEO of Sharecare
Jeff Arnold founded health and wellness platform

Sharecare with Dr. Oz, in conjunction with Harpo
Productions, Sony Pictures Television, and Discovery
Communications. Sharecare helps people maximize
their human potential by connecting them with medical experts,
support tools, and interactive programs. Join Arnold as he leads
discussions and shares with the AHIMA audience the latest topics in
healthcare.
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Leading the Way: Advances in Medical

Care
Eric Topol, MD, cardiologist and chief academic

officer at Scripps Health
Healthcare futurist Eric Topol, MD, cardiologist and
chief academic officer at Scripps Health, gives a tour
of the advances in medical technology happening
all around todays healthcare professionals and their
business. Topol communicates the thrill of working in such exciting,
transformational timesand the urgency of not being left behind. He
was voted the #1 Most Influential Physician Executive in the United
States in a poll conducted by Modern Healthcare.
Leading the Way: Life Changing

Innovation
Nate Harding, CEO and Co-Founder of Esko

Bionics
In addition to being co-founder of Esko Bionics, Nate
Harding is also a co-inventor of the companys core
exoskeleton technology (body-external dynamic
full-body scaffolds). The company has advanced its
product from the initial prototypes shared with the US military to the
incredible creation of today. Harding will demonstrate the benefit of
technology merging with healthcare and how that union can create
life-changing options for US soldiersand now civilianswho have
survived spinal cord injuries or a stroke and those who struggle with
weaknesses in the lower extremities.
Using Health IT to Drive Health Care

Transformation
Judy Murphy, RN, FACMI, CHIMSS, FAAN, chief

nursing officer, Office of the National Coordinator
for Health IT
Judy Murphy directs the Office of Clinical Quality
and Safety and advances the vision of using health
IT to improve healthcare, lower costs, and promote
consumer use of health IT. Involved with health informatics for over 25
years, Murphy was vice president, electronic health record applications
at Aurora Health Care in Wisconsin, where she led the EHR program
prior to her current role. Murphy has a longstanding reputation of
patient advocacy and maintaining a patient-centric point of view,
and approaches her work with unyielding energy and commitment to
the healthcare transformation enabled by technology.
EARNING CEUS AT THE CONVENTION
The AHIMA Annual Convention and Exhibit is also an opportunity to

earn the CEUs need to maintain AHIMA certifications. Beginning in
2014, CEUs will be awarded on the basis of verified attendance using
radio-frequency identification. Each session room will be equipped
with a scanner that automatically scans the tag located on your
convention ID badge. The scanner will record your IN and OUT times.
A minimum time requirement of 45 minutes must be met to receive
credit for a session. You will not need to enter your CEUs manually.
CEUs are earned by attending general session and educational track
sessions Monday through Wednesday. Questions regarding this system
may be directed to David Rich at david.rich@ahima.org.
Iatric Systems, Inc.

IMAT Solutions
IMO, Intelligent Medical
Objects
In Record Time, Inc.
Infinite Trading, LLC
IOD Incorporated
Iron Mountain
Jacobus Consulting
Journal of AHIMA
Just Associates
Kaiser Permanente
KIWI-TEK
KodakAlaris
Kofax, Inc
Lexicode, a Source HOV
Company
LifeMed ID
Loyola Health Law
Programs
M*Modal
Maxim Health
Information Services
McGladrey LLP
McKesson
MedAssets
MedData, Inc.
MedeAnalytics
Medi-Copy Services Inc
MediQuant, Inc.
Mediscribes
MedKoder
MedPartners HIM
MedTek
Melissa Data
MiraMed Global Services
MQIdentity
MRO
MSUSA
National Cancer
Registrars Association
Nearterm Corporation
Nuance
Odyssey Merchant
Services
OHSU-Biomedical
lnformatics
Olympus Imaging
America, Inc.
OmniClaim, Inc.
On Assignment HIM
On Call Central
On Call Consulting Inc.
Optum
Otto Trading, Inc.
Ovation Revenue Cycle
Solutions
Panacea Healthcare
Solutions Inc.
Parallon
Partner Healthcare
Business Solutions
Peak Health Solutions
Perceptive Software from
Lexmark
Perry Johnson &
Associates, Inc.
Pickerson
PLATOCODE
Precyse
Primeau Consulting
Group
Privacy Analytics
Professional
Development and Career
Center
Proquest
Prospective Payment
Specialists
Provident Consulting
Pyramid Healthcare
Solutions
Q-Nomy
Quadramed
RCM Health Care
Services
Regis University
Reimbursement
Management Consultants,
Inc.
Relaxtion Station Sponsored
by Sutherland Global
ReleasePoint
RevenueMed
RightWay Recruiting
Salutopia
Scanstat
Scrypt
SPi Healthcare
Standard Register
Healthcare
STAT Imaging Solutions
Stat Solutions, Inc.
Stephens College
Stern & Associates, Inc.
Strategy Companion
Streamline Health
Student Lounge
Superior Global
T-Systems
The Coding Alliance
The College of St.
Scholastica
Thompson Reuters
Accelus
Time Warner Cable
Business Class
TransDyne
TruBridge
TruCode
Trust HCS
UASI
Universal Coding
Solutions
University of Alabama at
Birmingham
University of Central
Florida
University of Cincinnati
University of Illinois
Chicago
University of San
Francisco
University of Washington
UT Health-School of
Biomedical Informatics
VASCO Data Security
Vee Technologies
Verisma Systems, Inc.
VisionWare
VITALWARE
Wacom Technology
Western Governors
University
WK Health, Health Language
Wolters Kluwer Law &
Business
WorkBeast
ZHealth Publishing / ZHealth
Consulting
14_October.indd 57
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2014 CONVENTION HALL MAP

EXHIBIT HALL EVENTS
At the industrys most extensive HIM and health IT

exposition, the exhibit hall will feature approximately
200 exhibitors. Dont forget, attendees earn 1 CEU
just for visiting the exhibit hall. Plus, an exhibitor
scavenger hunt game features the chance to win a
$500 AmEx gift cheque. Learn more about exhibitors
and their offerings at ahima.org/convention/exhibits.
Exhibit Hall Hours
Sunday, September 28 | 5:30 p.m.7:30 p.m.

Monday, September 29 | 11:30 a.m.4:30 p.m.
Tuesday, September 30 | 11:30 a.m.4:30 p.m.
Wednesday, October 1 | 9 a.m.12:30 p.m.
14_October.indd 58
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Morning with AHIMA: Complimentary Grab

and Go Breakfast
Wednesday, October 1 | 9:15 a.m.10:30 a.m.
SDCC, Ground Level, Exhibit Hall
With so much to see and do, a complimentary Grab

and Go breakfast will be available in the Exhibit Hall
Caf on Wednesday morning. Open to all registered
attendees.
14_October.indd 59
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Working Smart a professional practice forum

Navigating Privacy & Security / e-HIM Best Practices / Standards Strategies / Quality Care
Law Changes
Patient Access to
Clinical Lab Reports
By Kelly McLendon, RHIA, CHPS
THE US DEPARTMENT of Health and Human Services (HHS)

continues to look for avenues to allow greater patient access
to their own health information so that they may be more active in their healthcare management. HHS recently created
final rules that remove the Clinical Laboratory Improvement
Amendments (CLIA) regulatory barriers and HIPAA exceptions
for CLIA-certified laboratories and CLIA-exempt laboratories as
a way to expand patient ability to view and participate in their
own care. CLIA prohibits the release of laboratory test results
directly to the patient. A patient can only receive results directly
from the ordering provider.
New Final Rule Now Effective

On April 7, 2014 a HHS final rule, CLIA Program and HIPAA
Privacy Rule; Patients Access to Test Reports became effective. The rule has a mandatory implementation date of October
6, 2014 and impacts two federal rule sets, with implications for
both CLIA-certified and CLIA-exempt laboratories. This final
rule amends the CLIA regulations for patient or authorized personal representative access to their laboratory test reports directly from clinical laboratories subject to CLIA. The final rule
leaves in place the existing CLIA language requiring the release
of lab reports only to authorized persons and, if applicable, to
the persons responsible for using them or to the laboratory that
initially requested the test.
In addition to the CLIA regulation amendment, the final rule
amends the HIPAA Privacy Rule to provide individuals (patients) and their designees the right to access and direct where
to send copies of their protected health information (PHI), such
as lab reports directly from the lab that performed the test. Since
this amendment applies to labs subject to HIPAA, most clinical
laboratories in the United States will need to comply. Clinical

laboratories that are not subject to HIPAA will not be under any
federal obligation to provide access or copies directly to individuals, but they will be permitted to do so under federal law.
Many Hospital Labs Already Compliant

At present many clinical labs are located within or as a part of
organizations such as hospitals or surgery centers that also provide care other than laboratory services and are typically operated with more formal HIM processes that routinely perform
release of information (ROI). Hospitals can continue to require
requests for copies to come in through the HIM department,
whether via a portal or other HIPAA compliant mechanisms
already in place. These organizations will not see a change in
their ROI operations, although they should update their HIPAA
and CLIA compliance program documentation and Notice of
Privacy Practices (NPP) to reflect the update.
For clinical laboratories that do not already have a formal record request or copy policies and procedures in place, care must
be taken to get them implemented by the October 6, 2014 compliance deadline. The ROI requirements and best practices necessary for safely and securely managing patient record requests
can be confusing due to their complex nature. AHIMA has made
its HIM Body of Knowledge tools available to assist in the management of ROI processes.
A New Line of Service

HIPAA rules place emphasis on individuals receiving access to,
and copies of, their PHI. An important means to reduce liability
is to avoid barriers in the provision of these services. Instead,
healthcare organizations must be open and make it easy for the
14_October.indd 60
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patient to request and have their copies delivered. For example,

laboratory administrators should make sure a patient has the
means to make a records request through a web portal. This also
applies to a patients representative. It seems likely that the Office for Civil Rights (OCR) would find that kind of service provision a favorable factor in an investigation or audit.
State Law Adds Complexity

Although the new final rule preempts many state laws regarding the provision of copies of PHI from clinical laboratories
directly to individuals, there are complications. For example,
record copy fees may be set by the state. Clinical laboratories
within each state will have to balance which state laws may be
preempted from those that are not as they define their processes
for ROI and the fees that are allowed to be charged. Under the
HIPAA Privacy Rule, state laws can set medical record copy fees
that are considered reasonable and can be implemented, as
long as they do not include fees forbidden by HIPAA.
How HIPAA is Impacted

The removal of the clinical laboratory exception in HIPAA aligns
clinical laboratories with the requirements other covered entities are subject to within HIPAA for record disclosure. Although
the typical individual request will be for access or copies of laboratory test results, the rules that now apply to laboratories allow
D I S C E R N I N G
for the requests to be subject to the HIPAA designated record

set (DRS) rules. A clinical laboratorys DRS probably includes a
more expansive scope of information than only laboratory test
results. The DRS might include billing and insurance information depending upon the definition created by each organization. Each clinical laboratory implementing ROI to satisfy the
access and copy rules should evaluate and document their designated record sets as a part of their policy creation.
Under the final rule clinical laboratories will have the same
HIPAA-required 30-day response limit requirement. Under
HIPAA, a request must be responded to within 30 days of receiving the request. There is a specific exception granted if the test
results take longer than 30 days to generate due to laboratory
processing. As long as HIPAA-based access processes such as
patient notification are followed, these requests do not have to
be fulfilled. The comments within the rules assert that 30 days
is enough time for the ordering physician to receive the results
and review them with the patient prior to the laboratory distributing the copies. Laboratories are specifically not required to
interpret the results of their tests for the requestor.
As with all HIPAA requests, proper requestor identification
and care in the disclosure process is required. The risk of liability is higher for organizations that provide access to and disclosure of PHI due to both HIPAA and state breach laws. This also
means that breach determination policies and procedures must
Identities
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be up-to-date and operational in order to keep organizational

liability as low as possible. As with all the HIPAA rules, there is
no exception for mental health or other highly sensitive patient
health information (i.e., sexually transmitted diseases) access
or disclosure.
Currently, under the HIPAA Omnibus Final Rule, the right to access applies to the delivery of copies to the individual or their designated recipient in both paper and electronic formats. Clinical
laboratory records in both paper and electronic formats are now
equally subject to HIPAA access and disclosure requirements.
E-mailing lab results is allowed as stated in HIPAA, but must
be encrypted for transit and at rest in order to be considered
within the breach safe harbor. However, e-mail does not have
to be encrypted if the patient wishes to receive it in an unencrypted form and the lab (or other department managing the
disclosure) informs the patient of the risks. Whether or not to
encrypt e-mail is always an issue that requires careful consideration, though it is strongly recommended.
ered entities that have the CLIA exception language within their
NPP must be updated. This rule has modified the HIPAA Omnibus Final Rule required date for a NPP update; both the CLIA
Amendment and Final Rule changes have to occur by October 6,
2014. They can be modified together and only once as long as it
is completed by this date. CLIA laboratories need to provide patients access to and copies of their NPP in the same manner as
all other entities subject to HIPAA. If the clinical lab has a website, it should also post a copy of their NPP.
With the deadline for the new CLIA regulatory amendment
and removal of the HIPAA exception occuring October 6, laboratories should have already begun to perform gap analyses to
identify areas that need to be addressed and implement the
necessary policies, procedures, and forms.
Reference
Notice of Privacy Practices Must Be Updated
US Department of Health and Human Services. CLIA

Program and HIPAA Privacy Rule; Patients Access to
Reports. Federal Register 79, no. 25 (February 6, 2014): 72897316. https://federalregister.gov/a/2014-02280.
Covered entities are required to provide individuals with details about how to access and get copies of their PHI through
the Notice of Privacy Practices (NPP) document. Impacted cov-
Kelly McLendon (kmclendon@complianceprosolutions.com) is the managing director at CompliancePro Solutions.
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The Risks and Results of

Data Spoliation
By Ron Hedges, JD
THE SEPTEMBER E-HIM Best Practices article answered some

basic questions about preservation of records in the context of
civil litigation. This article will consider the question, What if
something goes wrong?
Spoliation Defined
Health information management (HIM) professionals are likely

to play some role in litigation that involves their employer. They
may have to locate, collect, and process informationor recordshowever that might be defined. To illuminate the importance of HIMs role, its imperative to talk about what can
happen if something that lawyers and judges call spoliation
occurs.
There are a number of definitions of spoliation. For the purposes of HIM, this definition will apply: Spoliation is a legal
term for the loss of information that should have been preserved
and that is relevant to a claim or defense. That simple definition
gives rise to a number of questions. For example:
W hat does loss mean? Must the information be irretrievably gone? What if the information can be retrieved, albeit at significant cost? What if the information is available from some other source?
Does loss imply or require a specific state of mind?
With state of mind referring to what an individual was
or wasnt thinking when they carried out an action. Must
a party intend to make the information unavailable in a
particular litigation? What if the party simply intended
to do something that resulted in the loss of the information, such as creating and applying a policy that routinely
eliminates information? What if the party was simply negligent in its attempt to preserve the information?
H
ow relevant must the lost information be? What if the
lost information is of marginal importance, as opposed to
being something that could be central to a claim or defense?
Has the other party, the one that has been deprived of the
information because the information has been lost, been
prejudiced because of the loss?
There is no simple answer to any of these questions. Indeed,
the federal and state courts across the nation are split on what
a party must show to allow a court or jury to find that there has
in fact been spoliation. Why? There are a number of reasons, but
two stand out:
The courts are divided on what state of mind must be
shown. Some courts say that a party must act with the intent to deprive the other party of the information. Other
courts say that any purposeful act that results in the loss
of the information is sufficient. Others say that negligence,
or gross negligence, is sufficient for a finding of spoliation.
Once state of mind has been provenwhatever that state
of mind isthe courts are divided on what else must be
proven. Some courts say that because intent has been
shown, relevance and prejudice may be inferredhowever that might be defined. The idea is that if information
is lost, the other party cannot know what the information
was and how it has been prejudiced and it would be unfair
to require the other party to prove what it cannot know.
Other courts say that the other party must always prove
state of mind, relevance, and prejudice.
There is no simple answer to these questions because, as not-
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ed above, it depends on where the litigation is pending.
Consequences of Spoliation
Assume for the sake of discussion that a party has been found
to have spoliated relevant information with the requisite state of
mind and that the other party has incurred prejudice. What can
be done to level the playing field?
Here are some examples:
A court could award attorneys fees and costs to the injured party, as measured by what the injured party had to
do to prove the spoliation.
A judge could allow the injured party to conduct additional discovery and require the spoliator to pay for that
discovery.
A judge could declare that certain facts that had been in
dispute have been established.
A judge could allow a jury to hear evidence that spoliation
had occurred and could consider that evidence in rendering a verdict.
A judge could allow a jury to infer something occurred or
didnt occur because relevant information has been spoliated
In extreme circumstances, a judge could impose a sanction that would end a case in favor of the injured party.
Obviously, none of these outcomes would be something anyone would like to see happen.
What This Means for HIM

As a practical matter, spoliation should be nothing of consequence to individuals or their employers. Every now and then,
a decision is issued in which a party is found to have engaged
in spoliation. When that happens, the consequences may become known in the legal and corporate communities and may
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about the importance of the preservation of relevant information. Based on legal statistics, however, parties rarely seek sanctions against another party for spoliation and, when parties do,
sanctions are rarely imposed.
HIM professionals should appreciate the importance of the
management of information, or information governance. Management allows for information to be preserved for litigation
purposes. The word preservation implies that information
that is subject to a litigation hold will not be lost but, instead,
be available in litigation. Management also implies a reasonable and documented process that can be used, if need be, to
refute any allegation of spoliation.
Review Relevant Processes and Policies

While the risks of spoliation are real, HIM professionals
shouldnt panic. Instead, individuals should focus and review
the processes they have in place to retain and preserve information. If policies are lax or nonexistent, they should be brought up
to legal standards to avoid spoliation.
Ron Hedges (r_hedges@live.com) is a former US Magistrate Judge in the
District of New Jersey and is currently a writer, lecturer, and consultant on
topics related to electronic information. This article is intended only for
educational purposes; it is not intended to provide legal advice.
Read More
Additional Litigation Guidance Online
www.ahimajournal-digital.com/ahimajournal/
september_2014#pg1
Read articles on litigation rules and preservation policies in the September 2014 Journal of AHIMA digital edition: HIPAAs Place in CourtOrdered Discovery and How and Why to Preserve Health Records.
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Driving Standards Toward

Interoperability with PHR
Functionality
By Kim Osborne, RHIA, PMP
HEALTHCARE IS POISED to experience true interoperability when it can exchange personal health information via electronic health record (EHR) systems, insurance claims systems,
and other health information exchanges with personal health
records (PHRs). A comprehensive PHR will help individuals
maintain a longitudinal view of their own health history. EHR
portals are beginning to provide patients with the ability to view,
download, transmit (VDT), and then store PHR information,
enabling consumers to become the custodians of their own
health records.
Health information management (HIM) professionals need
to be informed and familiar with the standard functionality of
PHRs as the ability to download and store personal health information becomes accessible to patients. Patient engagement
functionality in the Centers for Medicare and Medicaid Services 2014 meaningful use EHR Incentive Program criteria
has providers working hard to build patient portals to meet this
requirement. In stage 1 of meaningful use providers must attest for accessor the ability of at least 50 percent of patients to
electronically view their health data. In stage 2, providers must
attest for useor the ability of at least 5 percent of patients to
electronically view, download, or transmit their health data to a
third party. The next step for patients is the ability to import that
health data into a PHR. Therefore, understanding the functionality of PHR systems is important for HIM and health IT professionals.
PHR functionality is moving closer to the goal of interoperability with the publication of an international standardthe
Personal Health Record System Functional Model (PHR-S FM)
Release 1. PHR-S FM is a standard defining features and functions necessary for the management of PHR systems. The stan-
dard was released in May 2014 by Health Level Seven (HL7) and
will also become a standard through the International Organization for Standardization (ISO), ISO 16527, through the efforts
of the ISO/Technical Committee 215 on Health Informatics
(ISO/TC215) Working Group 1 on Architecture, Frameworks,
and Models. This standard will be available globally through
these two standards organizations.
Potential users who may benefit from this standard include
healthcare providers, public health agencies, healthcare insurers, employers, consumers, and vendors for EHRs, PHRs,
and mobile health. This standard will support design, development, certification, and implementation of PHR systems
under a common international reference for PHR system functionality.
PHR Standards and the Consumer

It is important to note that there is a difference between a PHR
and a PHR system (PHR-S). The PHR is the health record itselfincluding data, pictures, graphs, and other information.
The PHR-S is the foundational software that maintains the PHR.
The PHR-S FM standard does not define the PHR, but instead
describes features and functions of software required to manage PHRs. The PHR-S is a tool centered on the patient as the
user and works to enable data sharing between the PHR-S and
other healthcare-related systems. The PHR-S FM standard will
promote functional interoperability between information systems involved in capturing, managing, processing, and delivering PHRs. The standard provides a framework to drive requirements for PHR content standards including specific use cases
of PHR information use, their data content (data sets and value
sets), and information models to ultimately achieve semantic
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interoperability between systems.

In development since July 2008, the standard has undergone
rigorous balloting with HL7 and ISO, assuring internationally
approved functional criteria for PHR systems. In addition, the
PHR-S FM standard references another ISO standard applicable
to the document ISO/TR 14292:2012 Health informaticsPersonal health recordsDefinition, scope, context and global
variations of use.
The PHR-S FM standard describes a system that will provide consumers with a tool to capture and maintain important
health information such as demographic data, insurance coverage, provider details, and health history including problems,
allergies, medications, laboratory results, immunizations, and
encounters. The PHR-S FM specifies information systems functions for information security, with identity and access management capabilities, audit trail, document storage, and other information management functions to ensure reliable, consistent,
and trustworthy information.
Other functions could include drug interaction alerts, appointment reminders and interfaces to provider scheduling systems, cost comparisons, clinical trial eligibility, patient educa-
AHIMAs Role in Standards Development

AHIMA IS PROUD to serve as the ANSI-delegated Secretariat to the ISO/TC215,and as Administrator of the United
States Technical Advisory Group (US TAG), the delegation
representing the US to ISO/TC215. ISO/TC215 has published 127 international standards since the technical committee was formed in 1998. HL7 works in liaison with ISO to
collaborate on developing international standards.
Health informatics standards aim to enhance efficiency,
safety, quality, and effectiveness of the delivery of care.
Within healthcare, standards form the foundation for interoperability and the seamless electronic exchange of
health data and information.
International standards provide state-of-the-art specifications for products, services, and good practices, helping to make them more efficient and effective. Developed
through global consensus, they also help facilitate international trade.
Providing patients with greater access to their healthcare data through

the ability to view, download, and transmit health data into a PHR is an
important goal for HIM and health IT professionals.
tion, and visualization tools such as graphical presentations of
test results, progress, and goals.
Allowing the user to maintain a longitudinal view of his or her
own health history, the PHR-S has the capability to assimilate information from various sources. The PHR-S may also allow the
user to store other personal health-related information such as
copies of advance directives and living wills. Additionally, the
PHR-S may have the functionality to link the user to health information specifically related to his or her own medical conditions.
PHRs Part of Achieving Healthcare Triple Aim

A highly functional, truly interoperable PHR-S has the potential to positively impact the Triple Aim of healthcarewith
improved quality of care, at reduced costs, resulting in better
health for all by engaging patients in managing health-related
information and making informed decisions to maintain a
healthy lifestyle. It can also guide vendors in building necessary
capabilities into their products, and act as criteria for functional
certification of PHR-S.
Understanding the functionality requirements detailed in the
PHR-S FM standard is the first step in the movement toward
standards for interoperability with PHRs. Providing patients
with greater access to their healthcare data through the ability
to view, download, and transmit health data into a PHR is an
important goal for HIM and health IT professionals.
References
Health Level Seven International. PHR-S FM Personal Health
Record System Functional Model (PHR-S FM). http://www.
hl7.org/implement/standards/product_brief.cfm?product_
id=88.
International Organization for Standardization. ISO/TR
14292:2012 Health informaticsPersonal health records
Definition, scope, context and global variations of use.
ht t p://w w w.i s o.or g /i s o/ home/store/c at a log ue _tc/
catalogue_detail.htm?csnumber=54568.
Coelius, Rebecca Mitchell. Getting the facts regarding view,
download, and transmit 2014 requirements. Health IT
Buzz. January 31, 2014. http://www.healthit.gov/buzz-blog/
meaningful-use/view-download-transmit-facts/.
Centers for Medicare and Medicaid Services. Eligible
Professional Meaningful Use Core Measures. April
2014.
http://www.cms.gov/Regulations-and-Guidance/
Legislation/EHRIncentivePrograms/downloads/Stage2_
EPCore_7_PatientElectronicAccess.pdf.
Kim Osborne (kim.osborne@ahima.org) is the former standards manager,
public policy at AHIMA.
14_October.indd 67
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Informatics Harnesses
Healthcares Wild, Rich Data
By Lou Ann Wiedemann, MS, RHIA, CPEHR, FAHIMA
HEALTHCARE HAS BECOME a data-rich field, and any data

rich environment requires the ability to analyze large, complex data sets. The field of informatics provides tools to integrate data, information, knowledge, and wisdom when processing data. Good informatics includes many functions, and
although informatics may have multiple definitions and subcategories, for the purpose of this article informatics is considered a business functionsimilar to information technologywith many resulting products.
As information technology rapidly changes healthcare it has
created new challenges and opportunities. Informatics enables organizations to study data, consider their impact, and
solve problems. Informatics is sometimes used in combination with another field such as bioinformatics or business. The
American Medical Informatics Association (AMIA) defines
health informatics as the fields of clinical informatics and
public health informatics, including both applied research
and practice.
Informatics uses information technology for assimilating,
gathering, organizing, analyzing, and presenting healthcarerelated data. These data are used to produce information for
decision support, to improve quality of care, decrease costs,
enhance patient safety, and increase interoperability. Health
information technology (HIT) is the tool, and information,
knowledge, and decision support are the outcomes.
Where Informatics and HIM Intersect

The golden age of informatics is upon the healthcare industry. As organizations and providers move rapidly to integrated
electronic health records (EHR), informatics has matured to
an essential level of business activities such as charge analy-
sis or drug-to-drug interaction. Organizations are now positioned to leverage information contained in their systems in a
way that was previously unmanageable in paper records.
Used correctly, informatics can

harness data into meaningful
information that streamlines
administrative processes,
improves quality of care, and
decreases healthcare costs.
As such, informatics and its components and outcomes have
become crucial assets.
To further demonstrate how informatics impacts healthcare
one must understand the hierarchical process of transforming
data to information. The first layer is data. As the most basic
level, it refers to the collection of characters or numbers such
as a physician order. Data are usually interpreted into some
type of value, usually qualitative or quantitative. A data element can be in a structured format, such as a numeric fivedigit field or unstructured free form text such as a narrative.
The next layer is information. Data are then manipulated
as values by turning it into information. The layer after that is
knowledge. Knowledge refers to the ability to use information,
or more importantly, how to use it. The final layer is wisdom,
which is how and when to use the knowledge.
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Visual Representation of Transforming Data into Informatics
The organization pulls information from the

EHR and pharmacy systems to determine
which medications are ordered for fevers
over six months.
INFORMATICS
Based on clinical factors,

medications are needed
and ordered.
WISDOM
KNOWLEDGE
INFORMATION
The patient has a fever.
The patients temperature is 40 degrees.
DATA
40 degrees Celsius
The Ever Growing Reach of Informatics

Informatics is now found in every corner of the industry. As a
sound multidisciplinary approach to decision making, it has expanded its reach beyond research and public health. Informatics depends on clean data. As such, data and their subsequent
analysis becomes an important subset of informatics.
In some cases informatics is considered to be an advanced
level function of health information management. The certified
health data analyst (CHDA) credential is one way of showing
competency in this arena. As organizations become more datadriven, advanced analytical tools make it easier to collect, store,
and analyze a wider range of data. From this level, the analysis
of data at a minute level generates healthcare intelligence.
Healthcare intelligence transforms raw clinical data into
meaningful and useful information. It is the application of informatics that allows the wide range of data to be transformed.
Used correctly, informatics can harness data into meaningful
information that streamlines administrative processes, improves quality of care, and decreases healthcare costs.
References
American Medical Informatics Association. The Science of
Informatics. http://www.amia.org/about-amia/science-
informatics.
Bellazzi, R. et al. Data Analysis and Data Mining: Current
Issues in Biomedical Informatics. Methods of Information
in Medicine 50, no. 6 (2011): 536-544. http://www.ncbi.nlm.
nih.gov/pubmed/22146916.
Crawford, Mark. Making Data Smart. Journal of AHIMA 88,
no. 2 (February 2014): 24-27.
Eramo, Lisa A. Healthcares Data Revolution. Journal of
AHIMA 84, no. 9 (September 2013): 26-32. http://library.
bok1_050328.hcsp?dDocName=bok1_050328.
Haux, R. Medical Informatics: Past, Present, Future.
International Journal of Medical Informatics 79, no. 9
(September 2010): 599-610.
Kennedy, Angela. Informatics Ahead: HIM Must Rise to
the Challenge of Evolving Industry Demands. Journal of
AHIMA 88, no. 2 (February 2014).
Liu, J.L.Y. and J.C. Wyatt. Basic Concepts in Medical
Informatics. Journal of Epidemiology and Community
Health 56 (2002): 808-812.
Lou Ann Wiedemann (lou-ann.wiedemann@ahima.org) is a senior director of HIM practice excellence at AHIMA.
14_October.indd 69
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PRACTICE BRIEF
practice guidelines for managing health information
Information Governance Offers a Strategic

Approach for Healthcare
FOR THE PAST several decades, adoption of health information technologyspecifically electronic health record (EHR)
systemshas been a central focus in the effort to improve care
and gain greater efficiencies. The healthcare industry is now
earnestly beginning to shift emphasis from adoption and implementation of the technology to how data and information that
has been captured can be optimized and leveraged for strategic
advantage.
According to a 2014 study conducted by AHIMA, most healthcare organizations are still at the beginning of this journey.1
Organizations are striving to address new imperatives for information afforded by tools such as business intelligence and
predictive analytics. The ability to effectively manage and utilize
information of all types has become an essential competency
for the viability of healthcare organizations in an era of accelerated change and transformation.
Information governance is emerging as a strategy that aligns
with and enables a healthcare organization to achieve its goals.
Successful organizations recognize information as a valuable
asset that must be carefully and thoughtfully managed throughout the information lifecycle. The purpose of information governance is two-fold:

Stewardship of information that supports compliance
and risk management
Leveraging information to achieve organization goals
The purpose of this Practice Brief is to describe the essential
aim and focus of information governance as a strategic approach for managing the asset of information for healthcare organizations. It is important to note that information governance
goes well beyond the traditional boundaries of health information and its management. Health information management
(HIM) and other healthcare professionals will need to think and
plan broadly for how information can be optimized and leveraged to achieve the organizations goals.
Defining Information Governance

At this time there is not a singular definition for information
governance. In many cases, organizations will define information governance for themselves. ARMA International offers a
definition that includes many of the strategic components of
information governance.
AHIMA defines information governance as:
The enterprise-wide framework for managing information

throughout its lifecycle and supporting the organizations strategy, operations, regulatory, legal, risk and environmental requirements.
Healthcare organizations achieve their organizational goals

through a focus on the patients interests. Therefore, the information governance framework must address issues unique to
healthcare such as patient safety, quality of care, patient engagement, and clinical documentation improvement. This even
pertains to non-care delivery organizations such as third party
payers, health information exchange organizations, and suppliers. Information governance helps organizations structure,
manage, and capitalize on information by:
1. Reducing risks
2. Increasing efficiencies
3. Achieving a competitive advantage
As a strategy, information governance ensures that information is utilized as an asset to support decision making for the
organization. Information governance addresses all information, whether it is generated internally or externally to the organization, regardless of its state or location (i.e., finance, human
resources, etc), including but not limited to:
Unstructured information and discrete data
Paper-based records and forms
E-mail
Social media
Voice recordings
Images
Any other storage medium or format of information
Information governance ensures that tools are in place to promote the creation, validation, and adoption of new information.
It allows an organization to leverage and determine the value
of information for decision making, and it provides aid in determining appropriate access and disposition. The information governance processes thereby help define the information
throughout its lifecycle for each organization.
Developing Information Governance Through a

Strategic Approach
Many industries are already well versed in information gover-
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Practice Brief
nance, but for healthcare it represents a change in the approach

to the management of information. When applied to healthcare,
information governance highlights the need to have a plan and
take a structured approach to how organizations manage all the
information assets and resources within the organization.
The organizational culture must be taken into account when
developing an information governance program. Strategies for
developing a sustainable information governance program include aligning the information governance program with business goals, reviewing drivers that the organization is following,
and determining what the organizational tolerance is for risk. In
addition, demonstrating return on investment, or a cost/benefit
analysis, will play into the development of the program. The information governance program must have its own budget, and
thus requires an assessment and application of the resources
necessary to the program, such as staffing, financing, and needed software and technology.
Information governance differs from traditional HIM in that
it is an enterprise-wide program that requires leadership and
support from the organizations executive leaders. This enterprise approach is vital because of the need to focus on assessing
risks, evaluating for gaps, and pulling together the right package of policies, procedures, and tools to manage any identified
risks and gaps. Resources need to be allocated to ensure that the
work can be carried out. Information governance is about strategically managing all of the information that healthcare organizations are gathering, creating, and preserving in vast quantities
each day. Information governance needs to be approached as a
formal strategy.
Organizations need to take an integrated approach to managing information strategically at the enterprise level. Information
governance in healthcare is an important step toward achieving
the Triple Aim of:
Improve the patient experience of care (including quality
and satisfaction)
Improve the health of populations
Reduce the per capita cost of healthcare2
According to the Institute for Healthcare Improvement, organizations that attain the Triple Aim will have healthier populationsin part because of new designs that better identify
problems and solutions further upstream and outside of acute
healthcare.3 As the coordination of care beyond the acute care
setting becomes increasingly widespread, governing all of that
information is a part of the picture in meeting the Triple Aim.
Information governance can help reduce and better manage the
cost of healthcare and give organizations an opportunity to be
more financially stable. The introduction of analytic tools can
facilitate improved population health management and ultimately result in higher quality of care.
Aligning Information Governance with

Organizational Goals
Successful information governance programs combine HIM,
legal and compliance functions, IT, finance, human resources,

and clinical areas to help healthcare organizations reduce risk
and drive patient outcomes as well as improve business performance. Accountability is key, since information governance is
the means to ensuring that the rest of the organizations strategies are successful. To obtain engagement from the executive
suite, start by focusing on the core strategic goals of collecting
data, which include:
Safe, effective patient care
Stable business operations
Financial viability
Use the organizational goals to promote the information governance program. For example, if the organization wants to become an accountable care organization (ACO), think about how
information governance can help move this project forward. If
the organization wants to focus on physician mergers, leverage
information governance to help bring the companies and their
information together into one organization. Having strong policies and procedures in place can help ensure there is coordinated patient care and a seamless transition for patients and staff.
One of the ways to make money or save money for a healthcare
organization and to achieve the goals outlined above is to be
able to transform data into usable, meaningful information. If
these objectives can be achieved, then the organization can derive business intelligence from data and information assets.
Decision makers develop strategy based on a number of factors. While there are a multitude of business needs for information governance in todays healthcare environment, some key
challenges have surfaced in recent years that can lead to the
need for a strategic focus on information governance:
1. There is enormous pressure from all sides of the legal and
regulatory world to access information electronically.
Healthcare organizations need to create, manage, retrieve, maintain, archive, and dispose of information appropriately. There are growing demands for information
to respond to RAC audits and HITECH-HIPAA requirements.
2. There is a need to collect a variety of clinical information,
such as data for cancer research or test results, or for reporting to registries. Other clinical information may be
collected to assess expanding or decreasing the organizations services, such as adding a childrens hospital or
cardiology center, or selling a clinic.
3. There is a need for access to patient information for multiple customers (i.e., patients, payers, regulatory agencies). Information is the lifeblood of any organization and
increasingly healthcare enterprises will need to be able to
manage it effectively in order to remain competitive and
accountable with new care and payment models that are
based on value and quality rather than fee for service.
Clinical documentation improvement, new quality measures, and population management will all drive the need
for analytics, which is dependent on sound information
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Practice Brief
governance practice and application.

4. Retention and storage of information is very costly to
manage. Combine that with the awareness that a great
deal of information is redundant and not all of it has equal
value. Information governance processes eliminate the
waste incurred with managing information that is no longer needed.
Characteristics of a Successful Information

Governance Strategy
Fundamentally, information used for analysis or reporting must
be accurate and trustworthy for the analysis and reporting. Otherwise, comparisons may be inaccurate and lead to poor outcomes or lower scores on public rankings. Poor data may lead
to poor patient outcomespatients may be injured or even die.
Hospitals and providers may be ranked low, giving the appearance that they are inadequate or incompetent. Analytics are
now being applied more than ever and the data must be accurate. As more information is available, strong practices are
needed to ensure validity.
There are a number of common characteristics that help ensure a successful information governance strategy:

Business-Led and Business-Driven: Solid information
governance begins with a clear strategy for the organization that is business-led and driven by strategy. At each
stage, knowing the overall strategy helps staff remain focused on the organizational goal of meeting the needs of
patients and all other consumers of healthcare information.

Measurable: Successful information governance programs are founded on clear and consistent policies, rules,
and training that result in measurable and repeatable outcomes.
Differentiated: To successfully govern information for patient care, regulatory, risk, and business needs, the individual pieces of information must be differentiated from
each other in some way.
Achievable: To be effective, each healthcare organization
must have a plan that is logical, realistic, and achievable,
and which is dependent not only on the needs of the organization but also on the availability of resources to carry
out the work.
Avoids Complexity: Healthcare organizations can spend
huge sums of money developing an information governance strategy, but if it is so complex that the organization
cannot mobilize its workforce to implement the necessary
changes, then the program will likely fail.
Communicable: Results must be measurable and communicable. Educating staff on the progress of the program
using scorecards, team meetings, and the intranet helps
hold staff accountable for outcomes and keeps them engaged in the program.
Copes With Uncertainty: Standardization of processes
leads to a more consistent approach and response to
threats that can help the organization cope with ambiguity or uncertainties.
Flexible: Information governance programs must ensure
that information and systems are secure, but must be designed to allow for flexibility where required to carry out
job duties.
Not Prescriptive: Information governance should facilitate discussion among business units by providing a common platform for decision-making based on the individual needs of the organization.
The information governance

framework must address issues
unique to healthcare such as
patient safety, quality of care,
patient engagement, and clinical
documentation improvement.
This even pertains to non-care
delivery organizations such as
third party payers, HIEs, and
suppliers.
Information Governance Should Start Now
Why should information governance be a priority that gets
started now when there are so many other pressing needs?
Most healthcare initiatives and changes currently taking place
involve data and information; there is a growing need to both
produce and harness large amounts of data, and an information
governance program is an invaluable addition to meeting those
needs effectively.
Information governance is focused on strategy and not specific processes. However, some of the same skills that are used in
managing health information can be applied to implementing
information governance across an organization, such as at an
enterprise-wide level developing policies and ensuring regulatory compliance.
Key information, both clinical and operational, often has been
managed throughout the organization at the individual departmental level. Bringing all of this information together (financial,
operational, and clinical) with enterprise-wide policies and
guidelines can mitigate operational and regulatory issues, such
as the requirement for infinite storage of unnecessary information and the associated costs, an inability to pull the correct information when needed, problems with versioning of policies,
and a lack of clear ownership of information.
Many organizations have experienced challenges with information integrity. This has been complicated by the explosion
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Practice Brief
of Big Data with its increasing volume, variety, and velocity of

data across the continuum of care. For example, the accuracy of
coded data has been called into question when it was time to do
quality reporting or public reporting of the hospitals data. Other
healthcare organizations have had situations that eroded trust
in data or information. When trust is eroded people find workarounds and create inefficiencies that have downstream effects
that can turn out to be very expensive. Healthcare organizations
are beginning to realize how much time is spent on clean-up
of data/information before it can be released (i.e., claims, state
reporting, quality measurements, and outcomes).
A leading goal for many healthcare organizations is to be able
to transform collected data into usable, meaningful information. Business intelligence is the process of using, applying, and
converting information assets to assist in driving towards the
achievement of strategic business goals.
One of the key objectives of an information governance program is to produce strategic business intelligence by leveraging
the information assets of an organization. Information governance helps ensure the integrity of information. One of the biggest benefits to information governance is reducing how much
time is spent on the clean-up of data/information that has to be
sent out from within the organization (i.e., claims, state reporting, and quality measurements/outcomes).
Finally, organizations need to have a single source of truth.
Establishing a single source of truth is about two things:
1. Having an information architectural framework across
disparate databases and networks
2. Determining which source will represent the primary
source of truth for the enterprise
The information governance program should be designed to
make sure that all information resources and investments support the business goals of an organization. Lack of a strong information governance program can pose serious consequences
to a healthcare organization.
There are multiple compelling business and legal reasons
right now in healthcare that highlight the need for information
governance:
The risk of privacy and security breaches that become
more costly each day
The need for a massive update of systems, processes, and
education that must be undertaken to support ICD-10CM/PCS implementation
Trying to get the workflows and information right to qualify for attestation to the meaningful use EHR Incentive
Program
Changing payment models that make it impossible to survive without good quality clinical and financial information
Courts that are promulgating new rules on e-discovery
that can prove to be extremely costly, even when the
healthcare institution is not a litigant or party in a lawsuit
Healthcare organizations need the functions that information

governance programs provide to measure their compliance, effectiveness, benchmarks, and comparisons in areas such as:
Population health
Quality and cost effectiveness
Public reporting
Clinical research
Business and financial performance
Regulatory compliance
Managing all of these challenges and meeting the requirements becomes much less daunting when approached under
the guidance of an effective information governance framework.
Creating the Information Governance Business Case

Navigating the regulatory environment today is challenging
for any business, but especially so in healthcare. The quantity of new regulations is steadily increasing and auditors are
cracking down on compliance, leaving healthcare organizations with little choice but to manage an ever-growing amount
of information.
Because of this, healthcare organizations need to begin to
effectively manage their information not only for regulatory
reasons but also to avoid damage to their reputation should
something go wrong. But for many information governance
proponents, proving the value of information governance can
be a complicated matter, particularly if senior leaders want to
see a return on investment before offering support or allowing
funding.
Here are some fundamental questions to answer before attempting to launch an information governance initiative in an
organization:
Is the entire business on board?
Is the value of an information governance program understood?
How will information governance improve business processes and decision making?
How does each information governance program reinforce or benefit improvement?
If the information governance leadership team can provide
concise and positive responses to these fundamental questions, they can dramatically increase the likelihood of building
a strong information governance initiative. Gaining executive
buy-in may well be the most important step of all in achieving a
successful information governance program.
The programs success also needs to be measured through
metrics to show its value to the organization. For example, the
general selling point might include a statement that information
governance will help improve patient outcomes. Once the information governance program is well established, organizations
would develop specific metrics to demonstrate that the initiative is effectively supporting patient outcome improvement.
14_October.indd 73
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Practice Brief
Sustainability is Key to Long Term Success

How can organizations keep information governance front and
center in a dynamic environment? For information governance
to succeed, proper planning and vision are essential to getting
started. But once initiated, there can be a number of challenges
encountered that make keeping the momentum difficult.
Get Stakeholders Involved

It is important that all stakeholders are involved in the information governance program. Leadership needs to keep the focus
aimed on key information governance initiatives and create a
culture of accountability. Sponsorship and participation from
both clinical and operational leadership are critical for information governance program success. Continued efforts to keep
these relationships engaged create an environment conducive
to sustainable information governance program strategies.
Communication
Ensure that all relevant staff members understand how the information governance initiatives will support the overall business strategy for the organization and what role each individual
plays in the process.
Provide Ongoing Training

There is a need to not only train users on new processes, but
to educate them on why it is being done. Untrained staff cannot anticipate the consequences of their actions on potential
outcomes.
Auditing and Monitoring

Unlike old processes in a paper-based environment, a user error
that may have gone undetected before could have catastrophic
effects in an enterprise information governance environment.
Internal auditing and monitoring can help mitigate this risk.
Report Results
Continue to assess and modify information governance processes to ensure organizational goals and strategies are being
met and report the outcomes of information governance initiatives through a scorecard or similar reporting tool.
Getting Information Governance Up and Running

There is no one-size-fits-all approach to information governance. Developing a program takes a minimum of 12 to 18
months.4 After the program is implemented, continuous review
and refining is required to maintain the program and ensure it
aligns with the current strategy for the organization.
An information governance program will not be embraced
without first building awareness of its importance. Demonstrating the direct impact of information governance on the advancement of organizational goals is key in getting recognition for the
importance of this program. All stakeholders must be educated
on the importance of establishing an overarching information
governance program to expand the benefits of interdisciplinary
collaboration. Leaders must illustrate how information governance supports top goals for healthcare organizations.
Information governance programs often start with a specific
need or challenge. The utility may be demonstrated on a small
scale through a single project. The success of the smaller project
may be used to begin building a large program. For example,
one project might be to organize/clean up shared drives, or another place to start could be with a project to attach retention
schedules to all the various types of information within an organization.
Below are important factors to consider when developing the
IG program:
Build a compelling business case
- Start with the organizations pain points, or look for
a strategic business opportunity (i.e., participation in
an ACO, buying new physician practices, or population health management)
- Timing is critical, determine current pain points
- Acknowledge and get others to understand that this is
not just another IT project (it is important to note that
this is not necessarily about acquiring IT resources,
but about utilizing the data to make business decisions)
Collaborate with the CIO/IT to gain support
Begin with an assessment to identify gaps and risks in existing policies and processes
Secure an executive sponsor, engage them in the process,
and then plan the approach
- Identify goals, define purpose
- Determine who is in charge and who holds which responsibilities
- Create a high level work plan
- Define measures of success
- Define budget and/or return on investment
Identify a sponsor and start building relationships with
stakeholders
Create a charter
Identify an interdisciplinary committee to oversee information governance
Find the low hanging fruit and/or business need to focus
on, such as:
- EHR
- Acquisition (and integration) of other organizations
- Meaningful use
- Denials/Readmissions
Review/Update/Create policies and procedures
Define success of the program
- Create the metrics
- Develop business metrics that link to the information
governance program
- Answer the question What does success look like?
The current level of the organizational metrics must
demonstrate the organizations definition of success
14_October.indd 74
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Practice Brief
Notes
1. AHIMA. 2014 Information Governance in Healthcare: A
Benchmarking White Paper. 2014. http://research.zarca.
com/survey.aspx?k=SsURPPsUPQsPsPsP&lang=0&data=.
2. Thomas Gordon, Lynne. Information Governance for
the Health Care Industry: Now Is the Time. iHealthBeat.
February 3, 2014. http://www.ihealthbeat.org/perspectives/2014/information-governance-for-the-health-careindustry-now-is-the-time.
3. Institute for Healthcare Improvement. IHI Triple Aim
Initiative.
http://www.ihi.org/Engage/Initiatives/TripleAim/Pages/default.aspx.
4. Reno, Danielle and Sandra Kersten. Getting Serious
About Information Governance. Journal of AHIMA 84, no.
5 (May 2013): 4849.
References
ARMA. Glossary of Records and Information Management
Terms, 4th edition. 2012.
Iron Mountain. Redefining the Role of Health Information
Management in the New World of Information
Governance. http://www.ironmountain.com/KnowledgeCenter/Reference-Librar y/View-by-Document-Ty pe/
White-Papers-Briefs/R/Redefining-the-Role-of-HealthI n f o r m a t i o n-M a n a g e m e n t-i n-t h e -Ne w-Wo r l d- o fInformation-Governance.aspx.
Prepared By
Lesley Kadlec, MA, RHIA
Diana Warner, MS, RHIA, CHPS, FAHIMA
Lydia Washington, MS, RHIA, CPHIMS
Acknowledgements
2014 Enterprise Information Management Practice Council
2014 Tennessee CSA Delegation
Marlisa Coloso, RHIA, CCS
Katherine Downing, MA, RHIA, CHPS, PMP
Vickie Griffin, RHIT, CCS
Deborah Kohn, MPH, RHIA, FACHE, CPHIMS, CIP
Yvonne Pennell, MA, RHIA
Harry B. Rhodes, MBA, RHIA, CHPS, CDIP, CPHIMS, FAHIMA
Angela Dinh Rose, MHA, RHIA, CHPS, FAHIMA
Sharon Slivochka, RHIA
Lou Ann Wiedemann, MS, RHIA, CDIP, CHDA, FAHIMA
14_October.indd 75
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Coding Notes
The ABCs of HHS-HCCs

TAKING A CLOSER LOOK AT THE COMMERCIAL RISK ADJUSTMENT
By Janet Franklin, RHIT, CCS, CCS-P, CHC
THERE ARE THREE age-defined models under commercial

risk adjustment. These are the Adult Model (ages 21 and up), the
Child Model (ages 221), and the Infant Model (ages 01). The
model applicable to a patient is dependent on their age at the
end of the benefit year. If a 20-year-old patient turns 21 on December 31, the patient will be in the Adult Model for that year.
There is one exception to this rule. Any infant born at the end
of one benefit year and discharged in the second benefit year is
considered age 0 for both years.
The Department of Health and Human Services Hierarchical
Condiction Categories (HHS-HCCs) that feed these models are
specific diagnosis codes used to report conditions addressed
by the provider in a face-to-face encounter with the patient. If
a diagnosis code reported for a patient maps to an HCC, then
the coefficient (or weight) of that HCC is added to the patients
risk score. If a particular code is reported multiple times, it will
only be counted once. If multiple different codes mapping to
the same HCC are reported, the HCC will only be counted once.
While many HCCs are additive, if a particular HCC falls
within a hierarchy, and more than one unique HCC within that
hierarchy is reported, the patients risk score is only impacted
by the highest weighted HCC in the hierarchy. If a patient has
two or more HCCs that fall into two different hierarchies, then
the highest weighted HCCs in each hierarchy are additive. An
example of a hierarchy under HHS-HCCs is displayed in the
table on this page. If a diagnosis mapping to HCC 090, Personality Disorders, is assigned during the year in addition to a diagnosis mapping to HCC 087, Schizophrenia, the patients risk
score will only be impacted by HHS-HCC 087.
HHS-HCC Hierarchy Example

HCC
Supersedes HCCs
HCC Description
087
088, 089, 090, 102, 103
Schizophrenia
088
089, 090, 102, 103
Major Depressive and Bipolar

Disorders
089
090, 102, 103
Reactive and Unspecified Psychosis, Delusional Disorders
090
Personality Disorders
102
090, 103
Autistic Disorder
103
090
Pervasive Developmental
Disorders, Except Autistic
Disorder
Demographic Factors Affect Group Assignment

In addition to hierarchies, the commercial risk adjustment
model utilizes groups. When one or more codes mapping to
multiple HCCs in the same group are reported, only a single
group weight will be added to the risk score.
While HCC assignment is driven by diagnosis code, demographic factors such as age and sex can further impact assignment. The table at the top of page 77 displays a few examples.
Some HCCs are specific to only one or two models while other
HCCs cross all models. The pregnancy HCCs are applicable to
both the Child and Adult Models but are further limited by sex
14_October.indd 76
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Coding Notes
Demographic Factors Impacting HCC Assignment

Coded Conditions
Demographic
HHS-HCC
Demographic
HHS-HCC
Breast Cancer
Age <50
011, Colorectal, Breast (Age < 50),

Kidney, and Other Cancers
Age 50+
012, Breast (Age 50+) and Prostate

Cancer, Benign/Uncertain Brain Tumors,
and Other Cancers and Tumors
Conjoined Twins
Age 0
247, Premature Newborns, Including Birth weight 2000-2499 Grams
Age 1+
097, Down Syndrome, Fragile X, Other

Chromosomal Anomalies, and Congenital Malformation Syndromes
Coagulation Factor VIII

and IX Disorders
Male
066, Hemophilia
Female
075, Coagulation Defects and Other

Specified Hematological Disorders
and age at the time of the diagnosis (ages 1255). Patients who
are not within this age range will not be assigned a pregnancy
HCC. HCCs driven by low birth weight diagnoses are restricted
to the Infant Model, age 0.
Interaction Type, Level Helps Determine Risk Score

One additional available element used in determining the risk
score for a patient in the Adult Model is referred to as Interaction Type. There are two levels of interactions, medium cost
and high cost. Only one interaction may be assigned to a patient, and a high cost interaction supersedes a medium cost
interaction. The two variables used in determining an interaction level and coefficient are severe illness indicator and the
interaction factor (desiginated HCCs or HCC groups). Based
on the combination of the two variables, there are nine possible high cost interactions and seven possible medium cost
interactions.
Severe illness indicators include:
002 Septicemia, Sepsis, Systemic Inflammatory Response
Syndrome/Shock
042 Peritonitis/Gastrointestinal Perforation/Necrotizing
Enterocolitis
120 Seizure Disorders and Convulsions

122 Non-Traumatic Coma, Brain Compression/Anoxic
Damage
125 Respirator Dependence/Tracheostomy Status
126 Respiratory Arrest
127 Cardio-Respiratory Failure and Shock, Including Respiratory Distress Syndromes
156 Pulmonary Embolism and Deep Vein Thrombosis
Patient Enrollment Plan Factors Into Risk Score

In addition to HCCs, hierarchies, groups, age/sex designations, interaction types, and infant severity levels, there is still
one more element that is needed to arrive at the patients risk
scorethe type of plan in which the patient is enrolled. Not only
do the HHS-HCC coefficients vary by the age-defined model
type (Adult, Child, or Infant), they vary between plan types.
There are five plan types, referred to as metal level plans. The
five metal levels are platinum, gold, silver, bronze, and catastrophic. Under commercial risk adjustment, there are actually
a total of 15 models, three age-defined models applicable to
each of the five plan levels. By looking at a patient within each
of the age-defined models with the same diagnoses, the impact
of these variables can be seen. The table on page 79 provides an
overview of these variables, organized by age group.
With many variables impacting a patients final risk score, the
foundation for the HHS Risk Adjustment Model is the accurate
assignment of ICD-9-CM diagnosis codes. Both the Department of Health and Human Services and the Centers for Medi-
Examples of HHC-HCCs Included in Infant

Severity Levels
Severity Level
Examples of HHS-HCCs Included
Severity Level 5
008 Metastatic Cancer
Severity Level 5
129 Heart Transplant
Severity Level 4
126 Respiratory Arrest
Severity Level 4
145 Intracranial Hemorrhage
Infant Model Coefficient Based on Severity Level
Severity Level 3
001 HIV/AIDS
The Infant Model works differently than the Adult and Child
Models. While infants are assigned HCCs, their coefficient is
based on the highest of one of five severity levels (with one being the lowest) that result from a combination of their maturity
category (birth weight or age 1) and the severity of their nonmaturity HCCs.
There is also an additional coefficient added to the score of
male infants based on age 0 or 1.
Severity Level 3
020 Diabetes with Chronic Complications
Severity Level 2
070 Sickle Cell Anemia
Severity Level 2
081 Drug Psychosis
Severity Level 1
037 Chronic Hepatitis
Severity Level 1
0071 Thalassemia Major
14_October.indd 77
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Coding Notes
Adult Interactions
A SEVERE ILLNESS indicator must be paired with a qualified HHS-HCC in order for an interaction (either high cost or medium
cost) to be assigned to the patient.
High Cost Interactions
Medium Cost Interactions
Severe Illness Indicator with One of the Following HCCs
Severe Illness Indicator with One of the Following HCCs
006 Opportunistic Infections
035 End-Stage Liver Disease
008 Metastatic Cancer
038 Acute Liver Failure/Disease, Including Neonatal Hepatitis
009 Lung, Brain, and Other Severe Cancers, Including Pediatric

Acute Lymphoid Leukemia
153 Atherosclerosis of the Extremities with Ulceration or Gangrene
010 Non-Hodgkins Lymphomas and Other Cancers and Tumors
154 Vascular Disease with Complications
115 Myasthenia Gravis/Myoneural Disorders and Guillain-Barre

Syndrome/Inflammatory and Toxic Neuropathy
163 Aspiration and Specified Bacterial Pneumonias and Other Severe Lung
Infections
135 Heart Infection/Inflammation, Except Rheumatic
253 Artificial Openings for Feeding or Elimination
145 Intracranial Hemorrhage
HCC Group G03

054 Necrotizing Fascitis
055 Bone/Joint/Muscle Infections/Necrosis
HCC Group 6
067 Myelodysplastic Syndromes and Myelofibrosis
068 Aplastic Anemia
HCC Group 8
073 Combined and Other Severe Immunodeficiencies
074 Disorders of the Immune Mechanism
Source for columns 1 and 2: The American College of Physicians Evidence-Based Guide to Complementary & Alternative Medicine by Bradly Jacobs, MD, MPH,
and Katherine Gundling, MD, FACP. Philadelphia: ACP Press, 2009.
care and Medicaid Services require that all diagnoses be coded

according to the ICD-9-CM Official Guidelines for Coding and
Reporting and Coding Clinic guidelines.
References
Department of Health and Human Services. Patient Protection
and Affordable Care Act; HHS Notice of Benefit and Payment
Parameters for 2014 and Amendments to the HHS Notice
of Benefit and Payment Parameters for 2014; Final Rules;
Patient Protection and Affordable Care Act; Establishment
of Exchanges and Qualified Health Plans; Small Business
Health Options Program; Proposed Rule. Federal Register 78,
no. 47 (March 11, 2013). http://www.gpo.gov/fdsys/pkg/FR2013-03-11/pdf/2013-04902.pdf.
Department of Health and Human Services. Patient Protection
and Affordable Care Act; HHS Notice of Benefit and Payment
Parameters for 2015; Final Rule. Federal Register 79, no. 47.
(March 11, 2014). http://www.gpo.gov/fdsys/pkg/FR-201403-11/pdf/2014-05052.pdf.
Centers for Medicare and Medicaid Services. HHS-Developed
Risk Adjustment Model Algorithm Instructions. Center
for Consumer Information and Insurance Oversight. 2013.
http://www.cms.gov/CCIIO/Resources/Regulations-andGuidance/Downloads/ra-instructions-4-16-13.pdf.
Centers for Medicare and Medicaid Services. HHS-Developed
Risk Adjustment Model Algorithm Instructions. Center
for Consumer Information and Insurance Oversight. 2014.
http://www.cms.gov/CCIIO/Resources/Regulations-andGuidance/Downloads/DIY-instructions-5-20-14.pdf.
Centers for Medicare and Medicaid Services. HHS Risk
Adjustment Model Technical Details. Retrieved from CCIIO,
Premium Stabilization Programs, Regulations and Guidance.
Center for Consumer Information and Insurance Oversight.
2014. http://www.cms.gov/CCIIO/Resources/Regulationsand-Guidance/Downloads/ra-tables-03-27-2014.xlsx.
Kaiser Family Foundation. Explaining Health Care Reform: Risk
Adjustment, Reinsurance, and Risk Corridors. January 22,
2014. http://kff.org/health-reform/issue-brief/explaininghealth-care-reform-risk-adjustment-reinsurance-and-riskcorridors/.
Janet Franklin (Janet.D.Franklin@kp.org) is compliance manager for risk
adjustment, government audit, and reimbursement team, national compliance, ethics, and integrity office at Kaiser Permanente.
14_October.indd 78
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Coding Notes
Impact of HHS-HCC Model Variables, Demonstrated by Age Group

Adult Model: Male patient age 62 with the listed HCC relevant diagnoses captured during the year
Coefficients
Demographic/Dx
HCC/Group
Platinum
Gold
Silver
Bronze
Catastrophic
Age 60+, Male
N/A
1.028
0.880
0.704
0.487
0.424
Staph Pneumonia
163
9.052
8.934
8.883
8.913
8.924
Sepsis
002
13.969
13.506
13.429
13.503
13.529
Kidney Transplant Status
183
10.944
10.576
10.432
10.463
10.482
End-Stage Renal Disease

(superseded by HCC 183 above)
184
Interaction (Sepsis and Staff

Pneumonia)
Medium Cost
Interaction
2.498
2.648
2.714
2.813
2.841
37.491
36.544
36.162
36.179
36.2
Total
Child Model: Male patient age 20 with the listed HCC relevant diagnoses captured during the year
Coefficients
Demographic/Dx
HCC/Group
Platinum
Gold
Silver
Bronze
Catastrophic
Age 60+, Male
N/A
0.379
0.304
0.198
0.101
0.077
Staph Pneumonia
163
10.730
10.615
10.549
10.566
10.571
Sepsis
002
17.309
17.142
17.061
17.081
17.088
183
43.158
42.816
42.659
42.775
43.808

184
71.576
70.877
70.467
70.523
71.544
No interactions in the child model

Total
Infant Model: Male patient age 1 with the listed HCC relevant diagnoses captured during the year
Coefficients
Demographic/Dx
Severity Level
Platinum
Gold
Silver
Bronze
Catastrophic
0.117
0.102
0.094
0.065
0.054
Term * Severity Level 5
71.576
70.877
70.467
70.523
71.544
Total
71.693
70.979
70.561
70.588
71.598
Maturity Category Age 1

Age 1, Male
Staph Pneumonia
Severity Level 4
Sepsis
Severity Level 4
Severity Level 5

14_October.indd 79
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Coding Notes
Reliable Coded Data

Require a Reliable Coding
Process Framework
By Judy A. Bielby, MBA, RHIA, CPHQ, CCS, FAHIMA
A POORLY MANAGED coding process can thwart the effective

use of coded diagnosis and procedure data. Take for example
Hospital A, a fictitious hospital that does not effectively manage
their coding processes. At this hospital, the coding professionals
are concerned primarily with the impact that coding has on reimbursement. Decisions on code assignment are based first and
foremost on the impact that the code has on reimbursement.
Queries are written only if the increased specificity will result in
higher reimbursement. As soon as the coder finds a diagnosis
or procedure that places the encounter into the highest-paying
DRG, the coding process stops and the coder moves on to the
next chart.
Compare this scenario with that of Hospital B, a fictitious
hospital with a strong information governance program
which includes clear-cut policies, processes, and standards
that result in coding compliance. At this hospital, everyone
understands the impact that code assignment has not only on
reimbursement but also on the other significant uses of coded data. Decisions on code assignment are based on coding
rules, guidelines, standards, and relevant data set definitions.
Queries are written when necessary to ensure data integrity.
Principal and additional diagnosis codes on inpatient encounters are selected and reported in accordance with the Uniform
Hospital Discharge Data Set (UHDDS) definitions of principal
and additional diagnoses.
Diagnosis and procedure codes are not just reported for
reimbursement purposes. There are many users and uses of
coded data. Internally, coded data are used by the facility, including medical staff, administration, and management. The
data are used internally to support clinical and administrative

decision making and to evaluate quality and efficacy of care
provided. Federal agencies, state data banks, policymakers,
researchers, provider associations, third party payers, healthcare purchasers, and consumer organizations also rely on
data reported by facilities and providers. Coded data are used
by many entities outside the hospital for a variety of purposes
including research, public health, health policy, quality and
safety monitoring, and more.
More than Just Reimbursement

According to an AHIMA position statement, coded clinical data
are used in order to:
Assist with clinical performance improvement
Measure the quality, safety, severity of illness, and efficacy of care
Manage care and disease processes
Track public health and risks
Provide data to consumers regarding costs, quality, and
treatment option outcomes
Design payment systems and process claims for reimbursement, including pay-for-performance measures
Perform research, epidemiological studies, and clinical
trials
Serve as clinical data set for some personal health records
Design healthcare delivery systems and monitor resource
utilization
Identify fraudulent practices
Set health policy1
14_October.indd 80
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Coding Notes
The coding process must provide accurate, consistent, and reliable coded data. Policies, processes, and standards that ensure
coding compliance are an important component of a healthcare
entitys information governance program. A compliant coding
process which results in reliable coded data is highly valued for
the many uses of coded data stated above. The users of coded
data will trust the data if they are convinced that the process of
coding the data is reliable.
Reliable Data Depends on Documentation

For coded data to be reliable, the source documentationthe
patient health recordmust be reliable. The structure and content of the health record must conform to set expectations. This
has a tremendous impact on code assignment. Inconsistent adherence to documentation requirements results in inconsistent
reporting of coded data. Incomplete documentation results in
inadequate reporting of coded data. Requirements with regard
to health record documentation are set forth by a number of
sources at the national, state, and local level as noted in the side
bar on this page.
Certain date elements such as principal diagnosis, other diagnoses, and principal procedure are uniformly defined. The
National Committee on Vital and Health Statistics developed
standardized data elements for inpatient hospital data with the
UHDDS and ambulatory care with the Uniform Ambulatory
Care Data Set (UACDS). The UHDDS was adopted by the federal
government for data collection and it is also used for a variety
of other purposes. The definitions included in the UHDDS and
UACDS are widely recognized and accepted for data collection
by federal and state governments along with other public and
private users of healthcare data.
The use of data sets such as the UHDDS allows for consistent
and standardized reporting of data, but only if the data set definitions are applied correctly. A data set provides definitions to
be used for a prescribed set of data elements. It is imperative
that coding professionals understand the importance of following data set definitions that are applicable to the type of encounter being coded. Users of the coded data expect adherence to
official coding guidelines, coding rules and conventions, and
applicable data set definitions.
Information Governance Impacts Coding

Medical staff bylaws, rules, and regulations related to health records should be reviewed regularly to ensure compliance with
external documentation requirements and standards. Facility
guidelines on coding should also be reviewed and updated at
least annually as part of an organizations information governance work.
AHIMA is one of the driving forces in an effort to introduce information governance into healthcare. Many AHIMA resources
are available that discuss how to implement information governance practices and also discuss its role in ensuring the integrity
of coded data. These resources can be found on the information
governance landing page of AHIMAs website at www.ahima.
Resources for Health Record

Documentation Requirements
THE FOLLOWING IS a list of rules, regulations, standards,
and other resources for health record documentation requirements in hospitals and provider practices. This is not
intended to be a complete list but does highlight some of
the more significant resources:
State and/or county licensure requirements regarding
health record content
Reimbursement requirements (such as Medicare Conditions of Participation or Conditions for Coverage)
Voluntary accrediting agency standards (such as The
Joint Commission)
ASTM International Computerized System Standards
(such as ASTM E1384 Standard Practice for Content
and Structure of the Electronic Health Record)
Health Level Seven (HL7) International Standards
Professional associations (such as AHIMA and physician specialty organizations)
Professional liability insurance companies, malpractice insurance companies, physician insurance pools
US Department of Health and Human Services Office
of Inspector General Compliance Program Models
Medical staff bylaws, facility rules and regulations
org/topics/infogovernance and also in AHIMAs HIM Body of

Knowledge.
Note
1. AHIMA. Statement on Consistency of Healthcare Diagnostic and Procedural Coding. AHIMA Position Statement. December 2007. http://library.ahima.org/xpedio/
groups/public/documents/ahima/bok1_036177.hcsp.
References
AHIMA. Assessing and Improving EHR Data Quality
(Updated). Journal of AHIMA 84, no. 2 (March 2013): 4853 [expanded online version]. http://library.ahima.org/
xpedio/groups/public/documents/ahima/bok1_050085.
hcsp.
AHIMA. Clinical Documentation Improvement Toolkit.
Chicago, IL: AHIMA Press, 2014. http://library.ahima.org/
xpedio/groups/secure/documents/ahima/bok1_050585.
pdf.
AHIMA. Computer-Assisted Coding Toolkit. Chicago, IL:
AHIMA Press, 2014. http://library.ahima.org/xpedio/
groups/secure/documents/ahima/bok1_050666.pdf.
AHIMA. Data Quality Management Model (Updated).
Journal of AHIMA 83, no. 7 (July 2012): 62-67. http://library.
bok1_049664.hcsp.
AHIMA. Information Integrity in the Electronic Health Record.
14_October.indd 81
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Chicago, IL: AHIMA Press, 2012. http://library.ahima.org/

xpedio/groups/secure/documents/ahima/bok1_049709.
pdf.
AHIMA. Statement on Consistency of Healthcare Diagnostic
and Procedural Coding. December 2007. http://library.
bok1_036177.hcsp.
AHIMA. Statement on Quality Healthcare Data and
Information. December 2007. http://library.ahima.org/
xpedio/groups/public/documents/ahima/bok1_047417.
hcsp.
Butler, Mary. Keeping Information Clean: New Information
Governance Efforts Challenge HIM to Sort Out Dirty Data.
Journal of AHIMA 84, no. 11 (NovemberDecember 2013):
28-31.
http://library.ahima.org/xpedio/groups/public/
documents/ahima/bok1_050467.hcsp.
Cassidy, Bonnie S. Defining the Core Clinical Documentation
Set for Coding Compliance. AHIMA Report. October
2012.
http://library.ahima.org/xpedio/groups/public/
documents/ahima/bok1_049822.pdf.
Centers for Medicare and Medicaid Services. 2015 ICD-10-PCS
Official Guidelines for Coding and Reporting. 2014. http://
www.cms.gov/Medicare/Coding/ICD10/Downloads/2015PCS-guidelines.pdf.
National Center for Health Statistics. ICD-9-CM Official
Guidelines for Coding and Reporting. October 1,
2011.
http://www.cdc.gov/nchs/icd/icd9cm_addenda_
guidelines.htm.
National Center for Health Statistics. 2015 ICD-10-CM Code
Set and ICD-10-CM Official Guidelines for Coding and
Reporting. 2014. http://www.cdc.gov/nchs/icd/icd10cm.
htm.
National Committee on Vital and Health Statistics. Core
Health Data Elements Report. August 1996. http://ncvhs.
hhs.gov/ncvhsr1.htm.
National Uniform Billing Committee. Official UB-04 Data
Specifications Manual. Chicago, IL: American Hospital
Association, 2015.
National Uniform Claim Committee. 1500 Claim Form
Reference Instruction Manual for Form Version 02/12.
Chicago, IL: American Medical Association, 2014. http://
nuc c .or g /i m a g e s/s t or i e s/ PDF/15 0 0 _ c l a i m _ f or m _
instruction_manual_2012_02-v2.pdf.
Judy A. Bielby (jbielby@kumc.edu) is a clinical assistant professor at the University of Kansas Medical Center School of Health Professions, health information management program, and a consultant with Durst and Associates.
Correction
In the Coding ICD-10-PCS Medical and Surgical-Related Sections: Understanding Osteopathic, Other Procedures, and Chiropractic article in the June 2014 issue, the root operation listed
under Osteopathic in the sidebar on p. 67 was misidentified as
Measurement. The correct root operation for the definition given is Treatment. The Journal regrets the error.
14_October.indd 82
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14_October.indd 83
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Presidents Message

Journal of AHIMA

Quiz ID: Q1438510 | HIM Domain Area: Clinical Data Management | ArticleReliable Coded Data Require a Reliable
Coding Process Framework

AHIMA
PO Box 77-2735
Last Name
Address
1. Which of the following actions will
most likely yield reliable coded data?

a. coders do not spend additional
time reviewing the inpatient record
after the diagnoses and procedures
already coded place the encounter
into the highest-paying DRG

b. coders make coding decisions
solely on the impact that the code
has on reimbursement

c. coders make coding decisions
that are based on coding rules,
guidelines, standards, and relevant
data set definitions

d. hospital employees write queries
only if the increased specificity will
result in higher reimbursement
2. The users of coded diagnosis and
procedure data can trust the data if:

a. every inpatient encounter in the
sample has at least one CC or MCC
reported

b. everyone else is using the data

c. the data are free

d. the process of coding the data is
reliable
3. State data banks rely on coded data
reported by facilities.

a. true

b. false
City
State, Zip Code

* $15, Member
* $25, Non-member
4. It is possible to incorporate and use

coded clinical data in personal health
records.

a. true

b. false
5. ICD-9-CM coded data are not used for
measuring:

a. patient feedback

b. quality of care

c. safety of care

d. severity of illness
6. Which of the following was most

instrumental in the development of
the UHDDS?

a. Florence Nightingale

b. The Joint Commission

c. National Committee on Vital and
Health Statistics

d. Office of the National Coordinator
for Health Information Technology
7. What does the abbreviation UHDDS
stand for?

a. Uniform Health Diagnosis and
Disease Set

b. Uniform Healthcare Discharge Data
Set

c. Uniform Hospital Discharge Data
Set

d. Uniform Hospital Diagnosis Data
Standards
8. A
provides specific
definitions to be used for a prescribed
set of data elements.

a. data set

b. diagnosis standard

c. policy

d. project charter
9. Hospital guidelines on coding should
be regularly updated as part of the
hospitals
efforts.

a. accreditation

b. information governance

c. orientation

d. recredentialing
F
s
R
F
C
10. T
he UHDDS was adopted by the
federal government for data
collection and it is also used for
a variety of other purposes.

a. true

b. false
R
F
R
F
C
F
a
14_October.indd 84
9/16/14 2:51 PM
Information Governance (IG) is a Strategic

Imperative for the Future of Healthcare.
Prepare for that future with materials and resources from AHIMA.
PUBLICATIONS
Implementing Health Information Governance:

Lessons from the Field
Linda Kloss, MA, RHIA, FAHIMA
NEW!
This book outlines lessons from healthcare organizations that have

already made progress in formalizing information governance.
It offers tested practices for aligning governance to the
organizations goals, organizing and staffing governance and
enterprise management, building on what is working, and guiding
incremental improvement.
PRICE: $59.95 | MEMBER PRICE: $49.95
Product Number: AB100213
WHITE PAPER
Get the Facts with the First

IG Benchmarking White Paper!
This survey marks the beginning of the development of an IG
framework, tools, guidelines and resources for healthcare
organizations to utilize as they either start or refine their
own IG programs.
WEBINAR REPLAYS
For one low price you and any number of your peers can benefit from reliable and expert information on timely
subjects with webinars and webinar replays from AHIMA.
Going Forward Into the PastInformation Governance and Standards: Enterprise Information Management
Recorded live on: June 19, 2014
Faculty: Deborah Kohn, RHIA, CHTS-CP, MPH, FACHE, CPHIMS
CEUs: 2
Results and Implications of First Survey of Information Governance Practices in Healthcare - FREE
Recorded live on: August 14, 2014
Faculty: Debora Green, RHIA, MBA
An Introduction to Information Governance

Recorded live on: August 21, 2014
Faculty: Lesley Kadlec, RHIA, MA
CEUs: 2
For additional information on Information Governance including HIMs role

and whats next visit, ahima.org/IG
MX9904
14_October.indd 85
9/16/14 2:51 PM
Calendar
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
10
11
16
17
18
24
25
2014 AHIMA Convention and

Exhibit, San Diego, CA
12
13
14
15
WEBINAR:
Using Social
Media to
Resolve
Healthcare
Issues Within
and Across
Organizations
19
20
WEBINAR:
21
Whats New
in Health
Informatics and
How it Might
Affect You
26
27
28
22
23
AHIMA ACADEMY FOR ICD-10-CM/PCS:
Building Expert Trainers in Diagnosis and

Procedure Coding, Orlando, FL
29
WEBINAR: How
WEBINAR: ICD-
to Avoid Greatly
Increased
Liability in
the Business
Associate
Relationship
10-PCS Coding
Challenges: The
Device Dilemma
30
31
AHIMA Annual Convention

2015 New Orleans, LA
September 26October 1
2016 Baltimore, MD
October 15October 20
14_October.indd 86
9/16/14 2:51 PM
A Look Ahead
Upcoming AHIMA Institutes, Seminars, Workshops,

and Webinars
Keep Informed
Resources and News from AHIMA

Upcoming CHPS Exam Prep Workshop
NOVEMBER
13
Webinar: Six Strategies to Protect Your EHR

Investment
17-18
AHIMA Academy for ICD-10-CM: Building Expert

Trainers in Diagnosis Coding: Chicago, IL
17-19
AHIMA Academy for ICD-10-CM/PCS: Building

Expert Trainers in Diagnosis and Procedure
Coding, Chicago, IL
UPCOMING INSTITUTES, SEMINARS,

WORKSHOPS, AND WEBINARS
December
1-3
CHPS Exam Prep Workshop, Las Vegas, NV
December
1-3
AHIMA Academy for ICD-10-CM/PCS: Building

Expert Trainers in Diagnosis and Procedure
Training, Las Vegas, NV
December
2
Webinar: Analytics to Fuel Your ICD-10 Engine
December
4
Webinar: Federal Health Information Model:

Supporting Effective, Secure Health Information
Exchange
December
9
Webinar: Stop the Madness! Simplify Healthcare

Provider Business Intelligence
December
10
Webinar: OPPS Update
December
11
Webinar: CPT Code Update
Check www.ahima.org/events for the latest schedule of

institutes, seminars, and workshops.
San Diego, CA | September 27October 2
With ARRAs emphasis on the privacy and security of electronic health records, experts are being sought out to ensure appropriate measures
are taken to protect health data. The Certified in
Healthcare Privacy and Security (CHPS) certification ensures advanced competency in designing,
implementing, and administering comprehensive
privacy protection programs. The CHPS Exam Prep
Workshop helps prepare professionals to sit for the
CHPS exam. This workshop reviews the knowledge
and skills needed for designing, implementing, and
administering comprehensive privacy and security
programs. Attendees also receive a free voucher
to sit for the exam (voucher must be used within
90 days of workshop completion). Some eligibility
requirements apply. To learn more, visit ahima.org/
certification or www.ahima.org/events/2014decchps-vegas. The workshop will be held December
1-3 in Las Vegas, NV.
CE Quizzes Only Available Online in 2015

Beginning January 1, 2015, mailed-in paper CE
quizzes taken out of the print Journal of AHIMA will
no longer be accepted. CE quizzes will only be
administered online at www.ahimastore.org. The
Journal of AHIMA will continue to publish the quiz
questions as a courtesy through the March 2015
issue. Starting with the April 2015 issue a box will
be included at the end of select articles that points
readers to the online version of the quiz, available in
the AHIMA Store.
New Text Outlines Lessons in Information

Governance
New from AHIMA Press, Implementing Health

Information Governance by Linda Kloss, MA, RHIA,
FAHIMA, outlines lessons from healthcare
organizations that have already made progress in
formalizing information governance. The book
offers tested practices for aligning governance to
the organizations goals, organizing and staffing
governance and enterprise management, building
on what is working, and guiding incremental
improvement. For more information visit www.
ahimastore.org.
AHIMA Convention App Available

The AHIMA convention app, available for registered
convention attendees, gives up-to-the-minute
information on new events, schedule changes, and
access to session materials, exhibitor information,
and networking with other attendees. To download
the app, visit http://ddut.ch/ahimacon14.
14_October.indd 87
9/16/14 2:51 PM
AHIMA Volunteer Leaders
AHIMA BOARD OF DIRECTORS

President/Chair
Angela C. Kennedy, EdD, MBA, RHIA
Head and Professor, LA Tech University
Ruston, LA
(318) 257-2854
angela.kennedy@ahima.org
President/Chair-elect
Cassi Birnbaum, MS, RHIA, CPHQ, FAHIMA
Senior Vice President of Health Information
Management and Consulting,
Peak Health Solutions, Inc.
San Diego, CA
(858) 746-7298
cassi.birnbaum@ahima.org
Speaker of the House of Delegates
Jennifer A. McManis, RHIT
Healthcare Consultant, Crowley Fleck Attorneys
Bozeman, MT
(406) 522-4501
jmcmanis@crowleyfleck.com
CEO, AHIMA
Lynne Thomas Gordon, MBA, RHIA, CAE,
FACHE, FAHIMA
Chicago, IL
(312) 233-1165
lynne.thomasgordon@ahima.org
TERM ENDS 2014DIRECTORS

Ann Chenoweth, MBA, RHIA
Senior Director of Industry Relations and
Market Research, 3M Health Information
Systems
Murray, UT
(801) 265-4390
afchenoweth@mmm.com
Dwayne M. Lewis, RHIT, CCS
President/CEO, DML Consulting, Inc.
Broken Arrow, OK
(918) 249-0101
dmlewisconsult@hotmail.com
Treasurer
Melissa M. Martin, RHIA, CCS
Chief Privacy Officer and Director of Health
Information Management, West Virginia
University Hospitals
Morgantown, WV
(304) 598-4109 x73716
martinme@wvuhealthcare.com

Secretary
Dana C. McWay, JD, RHIA
Court Executive/Clerk of Court, US Bankruptcy
Court for the Eastern District of Missouri
(314) 244-4600
danahimlaw@aol.com
Susan J. Carey, RHIT, PMP
System Director, HIM, Norton Healthcare
Louisville, KY
(502) 629-8913
susan.carey@nortonhealthcare.org
Cindy Zak, MS, RHIA, PMP, FAHIMA
Executive Director Corporate HIM,
Yale New Haven Health System
Woodbridge, CT
(203) 688-5466
cindy.zak@ynhh.org
Ginna E. Evans, MBA, RHIA, FAHIMA

Business Analyst, Revenue Cycle Development,
Emory Healthcare
Avondale Estates, GA
(404) 778-7960
ginna.evans@emoryhealthcare.org
Colleen A. Goethals, MS, RHIA, FAHIMA
HIM Consultant, Cardone Record Services, Inc.
Belvidere, IL
(815) 378-2632
cgoethals@mmrainc.com
Advisor to the Board
David S. Muntz, CHCIO, FCHIME, LCHIME,
FHIMSS
Senior Vice President/CIO, GetWellNetwork
Bethesda, MD
(240) 482-3192
David.muntz@getwellnetwork.com

Zinethia L. Clemmons, MBA, MHA, RHIA, PMP
Senior Health Information Privacy Specialist,
Department of Health and Human Services/OCR
Washington, DC
(202) 495-0533
zinethia.clemmons@hhs.gov
2014 CHAIRS OF AHIMA VOLUNTEER GROUPS

AHIMA Grace Awards Committee
Mark S. Dietz, RHIA
(763) 377-6720
markdietz2@msn.com
Engage Advisory Committee

Seth J. Katz, MPH, RHIA
(913) 526-4987
SJKatz5@hotmail.com
Nominating Committee
Tim J. Keough, MPA, RHIA, FAHIMA
(609) 936-2222
tkeo2@aol.com
AHIMA Triumph Awards Committee

Marion K. Gentul, RHIA, CCS
(302) 827-1098
mgs60mga@yahoo.com
Exhibit Advisory Committee

Julie W. Clark
(770) 205-6198
jclark@creativelyclark.com
Professional Ethics Committee

Laurie A. Rinehart-Thompson, JD, RHIA, CHP, FAHIMA
(614) 292-3694
Laurie.Rinehart-Thompson@osumc.edu
Annual Convention Program Committee

Adrienne A. Beauvois, RHIT
(626) 836-6634
abeauvois@coh.org
Fellowship Review Committee

Julie Wolter, MA, RHIA, FAHIMA
(314) 977-8720
wolterjl@slu.edu
State Advocacy Council

Sue (Jensen) Nathe, RHIT
(320) 231-3655
sue@medsuppliestrucare.com
2014 CHAIRS OF AFFILIATE VOLUNTEER GROUPS

AHIMA Foundation
Warren A. Jones, MD, FAAFP
(312) 233-1131
drwajones@bellsouth.net
Commission on Accreditation for

Health Informatics and Information
Management Education
Mervat Abdelhak, PhD, RHIA, FAHIMA
(312) 233-1548
info@cahiim.org
Commission on Certification for Health

Informatics and Information Management
Donna Rugg, RHIT, CCS
(585) 396-6784
donna.rugg@thompsonhealth.org
Council for Excellence in Education

Ellen Shakespeare Karl, MBA, RHIA, CHDA,
FAHIMA
(646) 344-7324
ellen.shakespeare@mail.cuny.edu
Envisioning Collaborative
(406) 522-4501
House Leadership
Laura W. Pait, RHIA, CDIP, CCS
(336) 946-1750
lpait@novanthealth.org
20142015 HOUSE OF DELEGATES

Speaker of the House of Delegates
(406) 522-4501
Speaker-elect of the House of Delegates

Laura W. Pait, RHIA, CDIP, CCS
(336) 946-1750
lpait@novanthealth.org
2014 PRACTICE COUNCIL VOLUNTEER CONTACTS

Care Coordination
Lee A. Wise, RHIA
(760) 880-7518
leewise2008@hotmail.com
Consumer Engagement
Anne L. Tegen, MHA, HRM
(952) 474-1780
anne.tegen@childrensmn.org
Teresa S. Brown, RHIT, CCS

tbrown@kdmc.org
Beth A. Friedman, RHIT

(770) 335-8570
beth@ten22pr.com
Clinical Terminology & Classification

Tammy R. Love, RHIA, CDIP, CCS
(501) 472-6634
Tammy.Love@hcahealthcare.com
Dwan A. Thomas-Flowers, MBA, RHIA, CCS
(904) 607-6610
HIMprofexcel@bellsouth.net
Enterprise Information Management

Kathleen Addison
(403) 943-0940
kathleen.addison@albertahealthservices.ca
Jill S. Clark, MBA, RHIA, CHDA, FAHIMA

(717) 246-9472
jclark@e4-services.com
Lori McNeil Tolley, MEd, BS, RHIA
(508) 822-1432
loriamcneil@gmail.com
Health Information Exchange
Sheldon Wolf
(701) 328-1991
shwolf@nd.gov
Privacy and Security

Sharon Lewis, MBA, RHIA, CHPS, CPHQ,
FAHIMA
(805) 542-0160
sharonlewisrhia@att.net
Susan M. Lucci, RHIT, CHPS, CMT, AHDI-F
(303) 646-3355
slucci128@hotmail.com
AHIMA volunteers also make valuable contributions as facilitators for Engage Online Communities. To locate the facilitator(s), go to a particular community, click on the Members tab, then click on the
community administrator link.
14_October.indd 88
9/16/14 2:51 PM
AHIMA Volunteer Leaders
COMPONENT STATE ASSOCIATION PRESIDENTS

Alabama
Sharon Horton-Woodruff, RHIT
Cullman, AL
(256) 352-8337
sharon.horton@wallacestate.edu
Indiana
Deborah Grider, CDIP, CCS-P
McCordsville, IN
(317) 908-5992
deborahgrider@mac.com
Nevada
Gregory Schultz, RHIA
North Las Vegas, NV
(702) 526-8361
gschultz00@aol.com
South Dakota
Sheila Hargens, MSHI, CMT
Parkston, SD
(605) 928-3741
sheila.hargens@avera.org
Alaska
Janie Batres, RHIA, CDIP
Anchorage, AK
(907) 252-7228
janieleigh44@hotmail.com
Iowa
Mari Beth Schneider Lane, MS, RHIA
Sheldon, IA
(712) 324-5061
mlane@nwicc.edu
New Hampshire
Jean Wolf, RHIT, CHP
Gorham, NH
(603) 466-5406
jean.wolf@avhnh.org
Tennessee
Lela McFerrin, RHIA
Chattanooga, TN
(423) 493-1637
lela.mcferrin@hcahealthcare.com
Arizona
Christine Steigerwald, RHIA
Gilbert, AZ
(480) 292-8293
Christine.Steigerwald@bannerhealth.com
Kansas
Julie Hatesohl, RHIA
Junction City, KS
(785) 210-3498
phoebehat@cox.net
New Jersey
Carolyn Magnotta, RHIA
New Egypt, NJ
(609) 758-8890
magnottac@deborah.org
Texas
Terri Frnka, RHIT
Bryan, TX
terrifrnka@yahoo.com
Arkansas
Marilynn Frazier, RHIA, CHPS
Ozark, AR
(479) 667-5153
mfrazier@ftsm.mercy.net
Kentucky
Diba Thakali, RHIA
Lexington, KY
(859) 979-3049
diba.thakali@bhsi.com
New Mexico
Vicki Delgado, RHIT
Albuquerque, NM
(505) 948-6711
vicki.delgado@kindredhealthcare.com
California
Shirley Lewis, RHIA, DPA, CCS, CPHQ
Upland, CA
(909) 608-7657
shirley.lewis5@verizon.net
Louisiana
Lisa Delhomme, MHA, RHIA
Rayne, LA
(337) 277-5544
delhomme@louisiana.edu
New York
Sandra Macica, RHIA
Saratoga Springs, NY
(518) 584-0389
s.macica@elsevier.com
Colorado
Melinda Patten, CDIP, CHPS
Aurora, CO
(720) 777-6657
melinda.patten@childrenscolorado.org
Maine
Nora Brennen, RHIT
Topsham, ME
(207) 751-1853
Nora.Brennen@va.gov
North Carolina
Jolene Jarrell, RHIA, CCS
Apex, NC
jolene@drgreview.com
Connecticut
Elizabeth A. Taylor, MS, RHIT
East Hartford, CT
(860) 364-4417
liz.taylor@sharonhospital.com
Maryland
Sarah Allinson, RHIA
Baltimore, MD
(410) 499-7281
sarahballinson@gmail.com
Delaware
Marion Gentul, RHIA, CCS
Lewes, DE
(302) 827-1098
mgs60mga@yahoo.com
Massachusetts
Walter Houlihan, MBA, RHIA, CCS
Springfield, MA
(413) 322-4309
Walter.Houlihan@bhs.org
District of Columbia
Jeanne Mansell, RHIT, CHTS-CP, CHTS-PW,
CHTS-IM, CHTS-IS, CHTS-TS, CHTS-TR
Washington, DC
(202) 421-5172
jeanne87@hotmail.com
Michigan
Thomas Hunt, RHIA
Owosso, MI
(989) 725-8279
thunt@davenport.edu
Florida
Anita Doupnik, RHIA
Tampa, FL
(813) 907-9380
anita.doupnik@nuance.com
Minnesota
Jean MacDonell, RHIA
Grand Rapids, MN
(612) 719-3697
jean.macdonell@granditasca.org
Georgia
Allyson Welsh, MHA/INF
Decatur, GA
Allysonwelsh@gmail.com
Mississippi
Phyllis Spiers, RHIT
Carriere, MS
(601) 347-6318
pspiers@forrestgeneral.com
Hawaii
Marlisa Coloso, RHIA, CCS
Wailuku, HI
(808) 442-5509
mcoloso@hhsc.org
Missouri
Angela Talton, RHIA, CCS
Florissant, MO
(314) 276-4180
afranks@swbell.net
Idaho
Mona P. Doan, RHIT, CCS-P
Boise, ID
(208) 484-7076
monadoan@hotmail.com
Montana
Vicki Willcut, RHIA
Kalispell, MT
(406) 756-4758
vwillcut@krmc.org
Illinois
Teresa Phillips, RHIA
Effingham, IL
(217) 347-2806
teri.phillips@hshs.org
Nebraska
Shirley Carmichael, RHIT
Fairbury, NE
(402) 729-6854
shirley.carmichael@jchc.us
Utah
Vickie Griffin, RHIT, CCS
Bountiful, UT
vickie.griffin@Parallon.com
Vermont
Charmaine S. Vinton, RHIT, CCS, CPC
West Chesterfield, NH
(603) 357-0170
cvinto@bmhvt.org
Virginia
Darcell Campbell, RHIA
Hampton, VA
(757) 788-0052
DACampbell@cox.net
North Dakota
Tracey Regimbal, RHIT
Grand Forks, ND
traceyregimbal@hotmail.com
Washington
Sheryl Rose, RHIT
Spokane, WA
(509) 624-4109
sherylrose622@hotmail.com
Ohio
Gail Wright, RHIT
Mansfield, OH
(419) 526-0439
gail.wright@kindred.com
West Virgnia
Kathy Johnson, RHIA
Sinks Grove, WV
(304) 772-5312
kjohnson@care-communications.com
Oklahoma
Christy Hileman, MBA, RHIA, CCS
Mustang, OK
(405) 954-2824
christy.hileman@faa.gov
Wisconsin
Susan Casperson, RHIT
Cecil, WI
(715) 853-1370
susan.casperson@thedacare.org
Oregon
William Watkins, RHIA
Oregon City, OR
(503) 867-5173
william.w.watkins@kp.org
Wyoming
Kimberle Johnson, RHIA
Gillette, WY
(307) 682-1251
kim.johnson@ccmh.net
Pennsylvania
Laurine Johnson, MS, RHIA, FAHIMA
Sarver, PA
(724) 295-9429
ljohnson@peakhs.com
Puerto Rico
Yanet Soto, RHIA
Arecibo, PR
(787) 879-2835
ysoto@wilmamed.com
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E-mail changes to your listing to journal@ahima.org

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13.QC.2371_1_13.QC.2371_1 7/8/13 12:14 PM Page 1
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AHIMA Career Center

For classified advertising information, call Alyssa Blackwell: 410-584-1961 | e-mail: ablackwell@networkmediapartners.com
While the ads in this section are deemed to be from reputable sources, the publisher accepts no responsibility for the offers made.
All copy must conform to equal employment opportunity guidelines, and the publisher reserves the right to reject, withdraw, or modify copy.
A current rate card is available on request.
Advertise in the
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Contact Alyssa Blackwell
at 410-584-1961
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Adreima is seeking FT
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/ Journal of AHIMA October 1
14
14_October.indd 92
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MEDICAL CODING PROFESSIONALS
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EOE Minorities/Females/Protected Veterans/Disabled
14/93
Journal of AHIMA October 14
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AHIMA Career Center
Want to fill your open position, or promote

your office as a great place to work?
Contact Alyssa Blackwell at 410-584-1961 for pricing and options, or leave her an email at
ABlackwell@NetworkMediaPartners.com.
Upcoming Issues:
November/December
E-Compliance
January
The Year Ahead
Limited space available

for 2015!
Contact Alyssa Blackwell at
410-584-1961 to reserve your space.
Custom Packages available to fit your
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Journal of AHIMA October 14
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Addendum
The Comparative Cost

of Inadequate Protection
Healthcare Breaches Ranked the Most Expensive
THE US HEALTHCARE INDUSTRY has the unfortunate
distinction of having the highest per capita cost of data
breaches, recent reports suggest.
A May 2014 Ponemon Institute analysis found that the
per capita cost of a healthcare breach was $359 per record. The overall mean across industries such as education, pharmaceuticals, media, and communications, was
$145 per record. According to Ponemon, the most heavily regulated industries had the highest costs, whereas
public sector and retail industries had the lowest.
However, the healthcare industry fared better in other
security scenarios. Despite the recent headline-grabbing cases of Chinese hackers breaching US healthcare systems, a study published in The Economist put
healthcare much lower on the list of targeted industries.
Healthcare ranked second to last, just above metals and
mining industries.
The Economists report also warned of the susceptibility of medical devices to hacking. The report highlights
the case of a diabetic security researcher who discovered that he could hack his own insulin pump and remotely adjust the levels of insulin injected into his body
through the pump.
The authors of The Economists report suggest that
prevention against breaches is more effective than dealing with the cost of a breach.
Experts outlined possible courses of action:
Ensure that only approved programs can run on any
given system

Industry stakeholders should change their tone
when it comes to tackling cybercrime. Instead of
referring to efforts as a war against cybercrime,
and all its attendant language that surrounds talk of
war, they should look at it as a matter of prevention and taking precautions

As increased connectivity in professional settings
grows, companies need to develop robust policies
for the security of connected devices
$359
$294
$227
$206
$177
$160
$155
$145
$141
$138
$137
$122
$121
$105
$100
$0
$119
PER CAPITA COST, PER RECORD OF A BREACH BY INDUSTRY CLASSIFICATION
$400
H
EA
H
E
IO
L
IC
IO
IO
AT
EU
C
A
IA
IC
AT
LT
N
A
ED
PH
L
IA
ER
ST
SU
ES
LI
AT
RT
LO
IC
FI
IN
RV
SE
ER
EC
IA
TA
I
SP
ED
EN
O
SP
EA
ES
R
IL
IC
A
ET
BL
PU
Source: Ponemon Institute. 2014 Cost of Data Breach Study: Global Analysis. http://www-935.ibm.com/services/us/en/it-services/security-services/cost-of-data-breach/.
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OCTOBER 2014

USING GOVERNANCE TO MANAGE

Where is Your Organization Hiding the Data?

This months video extra shines a light on three places HIM

San Diego, CA | September 27October 2

Read All About It!

Follow the news from the AHIMA Convention

Call 888-647-4440 or visit www.trucode.com and

Contents October 2014

Vol. 85, no. 10

By Sofia Empel, PhD

The Way Forward

Tracking HIEs Ever Evolving Operational

By Kathy Callan, MA, RHIA; Jan Fuller, RHIA, CPHIMSS, FAHIMA;

Slow to the Information Governance

Word from Washington

Leading Your Facility Through the ICD-10

AHIMA Career Center

Contents October 2014

Navigating Privacy and Security

e-HIM Best Practices

By Lou Ann Wiedemann, MS, RHIA, CPEHR,

AHIMA members may earn continuing

By Janet Franklin, RHIT, CCS, CCS-P, CHC

The ABCs of HHS-HCCs

Reliable Coded Data Require a Reliable Coding

Information Governance Offers a Strategic

The Way Forward

Tracking HIEs Ever Evolving Operational Models

Reliable Coded Data Require a Reliable Coding

4/Journal of AHIMA October 14

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Contents October 2014

Video: Where is Your Organization

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6/Journal of AHIMA October 14

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The Journal of AHIMA is an official publication of AHIMA

Lynne Thomas Gordon, MBA, RHIA, FACHE, CAE, FAHIMA

ART DIRECTOR Graham Simpson

EDITORIAL ADVISORY BOARD

8/Journal of AHIMA October 14

Reinventing Clinical Documentation

IG Allows Organizations to Embrace

AS AN EDUCATOR, I often find myself

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10/Journal of AHIMA October 14

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ART DIRECTOR Graham Simpson