What happens when a physician (or other healthcare provider) leaves a group practice?
Will the remaining physicians assume the ongoing management of the records? If the exiting physician intends to practice elsewhere and requests access to his or her patients' records, how will this be accommodated? In what media? Hard copy, electronic, image files, text? At what cost? Who will assume the cost? The departing physician, the patient, or the remaining physicians?
The development and use of a shared Electronic Health Record (EHR) is complex.
The primary purpose of the EHR is to document the care provided to the patient. The maintenance of these records, particularly when more than one user (or custodian) has access to them, is even more challenging and requires proactive communication between the EHR users. Each user must ensure the following:
- The information is maintained in a confidential and secure manner
- The data is easily retrievable for continued care
- The use must meet the physician's fiduciary and statutory obligations
When a physician documents information in the EHR, he or she becomes the custodian of that specific data. If more than one physician was involved in the care of the patient, this may mean that there are multiple custodians for each record.
To help manage the use of the EHR and patient records in a group practice, use these six steps: Meaningful Use Stage 2 is your friend.
The standards for the 2014 Edition certified EHRs have improved your ability to share and transfer records. Patient data should be easily exported in CCDA format for use in any other 2014 Edition certified EHR. Depending on your vendor you may need assistance in exporting and/or importing the data, but to be 2014 Edition certified the vendor must provide this capability.
It's never too late to start! If you missed any of these steps in your group practice, do them now!
- Have a clear understanding of how patient records in a shared EHR database are controlled.
- Have a Business Associate Agreement with the EMR software vendor. Typically, there is one named individual on the contract from which the software vendor can receive instructions on how to manage the records. in the database.
- As a group healthcare practice, have a clear understanding and written agreement that sets out how patient records will be collected, used, and disclosed during the group practice and whenever the membership of the group practice changes. This provides direction to the named individual on the contract with the EHR vendor. (see step #2)
- Take a pro-active privacy role and inform patients how their information will be protected during the routine practice operations and when healthcare providers are added--or leave--the practice.
- Decide how you are going to decide about the on-going operational changes to how the software will be used in your practice.
- Identify in the EHR software who is the primary (or default) healthcare provider for each patient. Talk with your software vendor how best to record this. This will help to identify which patient records ‘belong’ to the healthcare provider when they leave the practice.