Confidentiality, Privacy & Security

1.  Health Info Exchange

Posted 9 days ago

​Hello,
Our IT department is setting up our electronic record to deliver patient records to a health information exchange.   There are hundreds of organizations and people who may then look at our patients' records.  So you must have been through this, so may I ask:
1.  Should we find and offer a way for patients to "opt out" of this?
2.  Should we add Health Info Exchange to our Notice of Privacy Practices as something we are going to do with their info (whether they like it or not)?
Thank you!

Joanne



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Joanne Soreng
Director, Health Information Management
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2.  RE: Health Info Exchange

Posted 9 days ago
Joanne,

I would check with the health exchange governance.   The exchange should have in place a process for patients to "opt out" at the exchange level.   I would definitely add to your Notice of Privacy Practices that you participate with this exchange.  I think it is a patient's right to know.  We did so with ours.

Here is the phrasing that we added to our Notice and I believe it also covers our mutual sharing through PACs arrangements.

Health Information Exchange:  We participate in arrangements of healthcare organizations which have agreed to work with each other, to facilitate access to health information that may be relevant to your care. For example, if you are admitted to a hospital on an emergency basis and cannot provide important information about your health condition, these arrangements will allow us to make your health information from other participants available to those who need it to treat you at the hospital. When it is needed, ready access to your health information means better care for you.  We may store health information about our patients in a joint electronic medical record with other healthcare providers who participate in the arrangement. You may contact the Privacy Officer for a list of healthcare providers who participate in these shared arrangements.


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Nancy Davis, MS, RHIA, CHPS
Director of Compliance & Safety
Door County Medical Center
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3.  RE: Health Info Exchange

Posted 9 days ago
​Thank you very much!  IT is also inviting payors to be part of the exchange, that is to read medical records from any source.  I have not yet heard back about how they make sure payors can only see THEIR clients.  Nor have they replied on the audit trail, way to account for such disclosures, and so forth.  I feel that I need to insist on these things, but a hundred groups have already signed up, no strings attached.  I guess I'm just old fashioned.
Joanne

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Joanne Soreng
Director, Health Information Management
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4.  RE: Health Info Exchange

Posted 5 days ago
​Your state should have regulations for Opt In/Opt Out.  We did also add it to our Notice of Privacy Practices, and added the information where the patient could submit, in writing, their wishes to opt out (as California is an Opt Out state).  If the patient indicates they will be opting out, we have a location in our EHR (Nextgen) where this is indicated so CCDs are not automatically uploaded to our HIE.

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Lisa Craig, BSHI,RHIA
Health Information Services Director
Shasta Community Health Center
lcraig@shastahealth.org
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5.  RE: Health Info Exchange

Posted 2 days ago
​Thank you, everyone!

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Joanne Soreng
Director, Health Information Management
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