Every second counts in healthcare – beginning from the time a patient makes appointments to looking up health records and documenting treatment. In an age of digital record keeping, the transfer of Electronic Health Records (EHR) should be seamless. This belief was put into law in 2016 with the passage of the 21st Century Cures Act, codifying that the exchange of Electronic Health Information (EHI) should be seamless and secure.  The hope of increasing health record access is to foster a market-like atmosphere that could create competition and drive innovation so patients would have more options in their healthcare.

One of the primary motivations for the 21st Century Cures Act was to encourage health care organizations and the developers of Certified EHR Technologies (CEHRT) to collaborate on the seamless exchange of information. Interoperability is the “ability of computer systems and software to exchange and make use of information.” Prior to the Cures Act, patients served as a manual fix to the variety of software platforms between different healthcare systems, requiring more legwork to bridge privacy gaps.

Similar to medical records software, there have been many examples in US history where the government facilitated a common standard to promote growth.  Only with a common railroad gauge did it become possible to travel from New York to California on one track.  A standard methodology is needed for health IT to advance and disparate EHR platforms to talk to one another.

What’s included in EHI?

In order to find a better solution, let’s first define the information being exchanged. EHI stands for “Electronic Health Information” and is currently defined as the US Core Dataset for Interoperability v1.0.  A major change is happening on October 6, 2022 when the definition of EHI will change from USCDI v1.0 to the entire designated record set (DRS). The only exclusion is psychotherapy notes and information compiled in anticipation of legal proceedings. It is important that those providers that are not covered entities under the HIPAA Rules know the definition of what is included in a designated record set to adhere to privacy standards. For additional clarity on what is considered a part of the DRS, please refer to the following diagram, originally found here.

The 21st Century Cures Act and defining DRS in the wild west of healthcare interoperability

You can find further information on the definition of EHI as it relates to the DRS, in this report from AHIMA, AMIA, and EHRA.

What about the Little Guy?

Sifting through DRS definitions and scope of health records can take time and resources—even for the largest organizations. How are smaller practices to keep up? Even without the extra help or budget, small and medium practices still need to adhere to the rules and know what EHI and the designated record set are.

One tip is to read up and familiarize staff with information blocking rules – handouts like this one from AHIMA are helpful references. Another tip is to make note of the discrepancy between the certified EHR deadline for compliance and when providers must comply.

Training and Perfect Practice

How to keep the train moving?

  • Check your policies often, make sure your organization has a designated record set policy, and educate staff, so information is handled according to the set policy.
  • Make sure staff can identify potential information blocking issues and can test workflows to accommodate the eight exceptions.
  • Make sure your business associates know your policies. While business associates may not be actors at this time, their actions will still affect your organization. They may even provide a mutually acceptable form or format for patients as well.
  • Keep up to date with the latest news, ensuring your staff and organization is adhering to industry standards and keeping up with the latest developments. A few trusted organizations to follow include AMIA, AHIMA, HCCA, HIMSS, ONC, and the Sequoia Project.

And finally, should you need additional help understanding the definition of DRS, or added support in keeping track of EHI, reach out to your HIM partner or continue following ScanSTAT for timely updates and resources.

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