Components of a Comprehensive Legacy Data Management Strategy: Challenges and Strategic Considerations A White Paper May 2016 Impact Advisors LLC 400 E. Diehl Road Suite 190 Naperville IL 60563 1-800- 680-7570 Impact- Advisors.com
Executive Summary Prior to go-live of a new enterprise EHR, there are many important decisions that need to be made about legacy data. Which data will be electronically converted directly into the new EHR? Which data will need to be manually abstracted into the system? How will the organization address archiving historical data from the legacy EHR to meet state and federal requirements? To minimize the disruption caused by an EHR replacement and ensure the transition does not jeopardize patient safety, Legacy Data Management strategies ideally need to encompass three distinct areas: Electronic Data Conversion, Manual Data Abstraction, and Legacy Data Archiving. Introduction A variety of factors are contributing to the recent increase in EHR replacements. Some providers are looking for next generation capabilities needed for success under new reimbursement models, while some feel growing pressure to switch EHRs amid concerns about the long-term viability of their current vendor. Other organizations are suddenly faced with replacing their enterprise system after a merger or acquisition, as the hospitals and health systems involved look to align on a single EHR. Given the turbulence in the EHR vendor market and continued mergers and acquisitions (M&A) among health delivery organizations, an increasing number of hospitals and health systems will be faced with an EHR replacement.! There are roughly 1,420 hospitals currently using a legacy EHR that their vendor will no longer support. 1! Total M&A activity in the healthcare delivery services sector grew 22% in 2015. There were 102 deals involving hospitals, and 88 deals involving physician practices. 2 Regardless of the underlying reason, replacing an enterprise EHR is an inherently disruptive process. New functionality needs to be tested and implemented. Existing workflows must be redesigned and deployed. In fact, from clinicians perspectives, it might feel as though the only constant throughout the entire transition is the data migrating from the old system to the new one. Effective management of legacy data is critical to minimizing the disruption of an EHR replacement and ensuring the transition does not jeopardize patient safety. For example, important patient data such as allergies and medications need to be brought into the new system and in a structured format so decision support alerts will trigger properly. Recent lab and radiology results need to be accessible at the point of care without clinicians having to toggle between multiple systems. 1 Acute EMR Market Share: How Did My Vendor Fare in 2014? KLAS, Aug 2015 2 Health Care M&A Deal Volume and Value Exploded in 2015. Irving Levin Associates, Jan 26, 2016 Components of Comprehensive Legacy Data Management Strategy 2
The benefits of Legacy Data Management are not achieved via a simple plug and play process, though. Success requires careful planning and execution across three distinct areas: Electronic Data Conversion, Manual Data Abstraction and Legacy Data Archiving. Clearing Up Confusion Although the terms Conversion, Abstraction and Archiving are often used interchangeably in the healthcare industry, there are important differences. Electronic data conversion and manual data abstraction focus more on continuity of patient care and provider adoption of the new system, whereas legacy data archiving is driven by complying with federal and state regulations and maximizing ROI. (See Figure 1 below.) Figure 1. Three distinct components of effective Legacy Data Management Electronic Data Conversion Automated migration of key clinical / revenue cycle data elements from the legacy system to the new EHR. Usually begins and ends prior to go-live. Often includes data elements such as: MPI, encounters, lab results, radiology results, transcriptions Manual Data Abstraction Manual data entry of key clinical / revenue cycle data elements from the legacy system into the new EHR. Usually begins prior to golive but some abstraction can continue for weeks / months after go-live. Often includes data elements such as: appointments, active orders, allergies, medications, immunizations and problem lists. Legacy Data Archiving Automated effort of storing historical data from legacy systems being retired, primarily to meet state and federal regulations. This is a separate effort from Conversion and Abstraction. Strategy needs to be developed before or during the implementation phase. Includes virtually all historical data. Components of Comprehensive Legacy Data Management Strategy 3
Components of a Successful Legacy Data Management Strategy There are unique challenges and strategic considerations associated with each component of Legacy Data Management. Electronic Data Conversion In an EHR replacement, a certain amount of legacy data is usually electronically converted directly into the new EHR. The primary reason is to maintain continuity of care for patients during the transition. Although the electronic conversion process itself is automated, the actual planning and execution can be extremely complex. Electronic data conversion usually begins and ends prior to go-live, to ensure as much patient information as possible is available to clinicians on go-live day. Decisions such as which specific data elements to include in the electronic conversion plan can vary widely, depending on how certain data elements are structured and the clinical needs of the organization. At a minimum, electronic data conversion usually includes data with defined standards, such as lab, radiology results and report transcriptions. One of the biggest challenges with electronic data conversion is managing the scope of the effort. Some legacy data especially non-hl7 data will not be ideal for electronic conversion simply due to lack of standards. Conversion efforts are often costly and resource-intensive, so it is impractical from a budget perspective to include all legacy data in the electronic conversion plan. These realties might be at odds with the expectations of clinicians, who often want as much historical perspective as possible available in the new EHR. Strategic considerations for successful Electronic Data Conversion: Key Decision Points for Electronic Data Conversions:! What specific data elements will be converted? What is that data s integrity in the legacy system?! What source system will be used for each data element?! How much legacy data will be electronically converted into the new EHR?! Engage key stakeholders from the beginning. Conduct regular conversion workgroup meetings to manage expectations that electronic data conversion will require significant time and resources. Ensure broad participation from a wide range of stakeholders including leadership from HIM, pharmacy, lab, and radiology. Physicians should be included as well, to help the workgroup understand data conversion needs in the context of patient care requirements.! Carefully manage scope and expectations. Conversations with clinicians and department leaders about how much data needs to be electronically converted might be difficult. However, converting more data means more validation will be needed and more commitment from subject matter experts and operational resources will be required. Consider compromises to ensure the actual benefits are worth the cost and resources involved. For example, if clinicians request 10 years of lab data, start by electronically converting the most recent 2 years to see if that meets their needs. Components of Comprehensive Legacy Data Management Strategy 4
! Ensure thorough testing and validation. A comprehensive validation strategy is critical. Identify dedicated application and departmental subject matter experts as well as physician and nursing staff to validate converted data throughout each phase of the conversion process and ensure there are no data integrity issues.! Engage legacy vendors early in the process. Getting cooperation from a vendor that is being replaced can be understandably challenging. Be sure to engage legacy vendors while they are still contracted for support to avoid significant delays in the delivery of data extracts. Manual Data Abstraction For most organizations, it will not be feasible to electronically convert all legacy data into the new EHR particularly if the data is not standard. Some data will instead need to be manually entered into the new system via abstraction. In this process, specific data elements that are not part of the electronic conversion plan but that providers still want available in the system at go-live are manually collected and transcribed into discrete fields in the new EHR. The amount and type of information that is abstracted depends on the scope and extent of the organization s electronic data conversion efforts. Generally, there is an inverse relationship between data conversion and abstraction data that are electronically converted do not need to be abstracted. However, even with a comprehensive electronic data conversion plan, clinicians frequently want to have additional data manually abstracted to the new EHR. Manual Data Abstraction often includes important information needed to influence medical decision-making at the point of care or to trigger patient safety alerts, such as active or standing orders, allergies, medications, immunizations, scheduled appointments, problem lists, and patient histories. The scope of the planning process may also involve identifying key paper-based clinical documents that will be scanned into the new system. Generally, manual data abstraction begins prior to go-live, with as much of the high priority data identified by the organization entered into the system as early as possible. Manual data abstraction frequently becomes a routine part of patient care well after golive as well. For example, practices might use manual data abstraction to prep the charts for new patients or to add outside information to an existing patient s record. One of the biggest challenges can be defining a standard set of data that will be abstracted organization-wide, while also ensuring that the abstraction plan addresses specialties with unique needs outside the standard set of data. For example, oncology clinics often need a manual abstraction of chemotherapy plans, while OB practices will have unique needs based on the kind of pregnancy care they provide. Managing expectations with stakeholders is also critical. Organizations need to carefully strike a balance between clinicians who want their patients entire record and the cost and time involved in manual chart abstraction. Components of Comprehensive Legacy Data Management Strategy 5
Strategic considerations for successful Manual Data Abstraction:! Start planning efforts early in the process to determine scope and budget requirements. What standard set data will be abstracted across the organization, by whom, and when? Are there any special abstraction needs for sub-specialties (e.g., oncology, OB, ophthalmology)? Which patients will have their charts abstracted? Ensure that the budget is realistic given the abstraction scope and vice versa.! Define oversight and management. Who will manage the abstractors? How will they be trained? Will there be a quality review to ensure abstraction is accurate?! Have a plan for when the abstraction project is complete. How will ongoing abstraction needs be handled at the practice level after the abstraction project has ended? As new practices are acquired down the road, are there defined policies and processes for how their data will be abstracted into the EHR? Legacy Data Archiving A significant amount of data from the legacy system might never be moved into the new EHR at all. For example, an organization might decide that lab results older than 3 years do not have enough clinical value to justify the cost of bringing them into the new system. However, clinicians and staff might still want access to legacy data (especially in the months following go-live) and by law, health delivery organizations are required to keep certain historical data, so it can be provided to patients upon request. A Legacy Data Archiving strategy serves three purposes:! Provides a common place to store legacy data.! Offers a lower cost alternative to maintaining legacy systems.! Provides a solution that could enable clinicians to access data from legacy clinical systems. Maintaining a fully functional enterprise EHR solely to store historical patient information is rarely practical. For most hospitals and health systems, it is a more cost-effective strategy to extract historical data from the legacy system and store it in a stand-alone archive solution. The potential savings from effective Legacy Data Archiving can be significant. Although there will be costs associated with extracting data from the legacy system and implementing a data archiving solution, the substantial maintenance and support fees from legacy EHR vendors are usually much greater. Maximizing savings from legacy data archiving while still complying with state and federal rules requires a full understanding of the provider organization s unique needs. How much data will have to be extracted from the legacy system? How long must the data remain available? Who needs to access the data? Which applications qualify for archiving? Will the archived data need to be modified or updated? Will the system be hosted remotely by a third party or stored locally onsite? Components of Comprehensive Legacy Data Management Strategy 6
The answers to these questions can vary widely depending on the definition of the legal medical record, state law, and retention policies. For example, the strategy for archiving clinical information from a legacy EHR for clinician access will differ from a plan to archive payroll or financial data. Location plays an important role, too. In some states, certain clinical information must be retained for decades; others have less stringent retention requirements especially for financial and operational data. Research adds another level of complexity. Strategic considerations for successful Legacy Data Archiving:! Account for your organization s unique archiving needs. State requirements can vary widely, so understand what data your organization is legally required to keep. Concentrate on retiring clinical and revenue cycle systems and identify which roles need access to legacy data and for what purpose. Billing staff might need access to legacy financial data for posting payments and tracking accounts receivables for six months after transitioning to the new system; the HIM department might need access to legacy clinical data for years in order to respond to patient requests for information. There are three distinct states in which legacy data can be stored in an archive system: 1. Active quickly accessible data that can be modified 2. Static quickly accessible view only data 3. Cold Storage infrequently accessed data retained for legal purposes only! Understand the effort involved to extract the data. Before data can be moved to an archiving solution, it must be extracted from the legacy system which can be extremely challenging and unpredictable. Factors such as whether or not the legacy system database is a proprietary format or open source make a significant impact on project complexity and cost.! Don t delay legacy data archiving. Start developing a strategy for archiving in conjunction with EHR implementation planning. Monthly maintenance and support fees from a legacy EHR vendor can be substantial and access to key data must be maintained by law. More so, retaining internal legacy system subject matter experts to provide crucial data management insight will be challenging after the transition to the new EHR is complete. The Bottom Line Replacing an enterprise EHR is an inherently disruptive process that requires careful planning and execution to ensure patient safety and continuity of care during the transition. Many important decisions need to be made about the legacy system data. Some legacy data will need to be electronically converted, while some will need to be manually abstracted into the new system. Other legacy data will need to be extracted to a stand-alone archiving solution in order to be compliant with state and federal regulations while avoiding significant maintenance and support fees. To be successful, EHR implementation strategies need to consider all three components of Legacy Data Management, with careful attention to how the organization s unique goals and priorities influence key decision points. Components of Comprehensive Legacy Data Management Strategy 7
About Impact Advisors Impact Advisors provides high-value strategy and implementation services to help healthcare clients drive clinical and operational performance excellence through the use of technology. We partner with industry-leading organizations to identify and implement improvements in quality, safety and value. Our Associates are experienced professionals with deep domain expertise and a commitment to delivering results. For more information visit: www.impact-advisors.com Follow us on Facebook and LinkedIn Copyright 2016 Impact Advisors, LLC. All rights reserved. These materials are provided to you by Impact Advisors as a professional courtesy for personal use only and may not be sold. Please appropriately credit/cite your source as Impact Advisors, LLC. All copying for commercial use requires written prior permission secured from impact-advisors.com. Components of Comprehensive Legacy Data Management Strategy 8