3.2.3HIE Policy and Procedure for PHR

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Section 3.2 Exchange - Interoperate

HIE Policy and Procedure for PHR

This tool offers suggestions for policies and procedures related to nursing homes

where residents or their family members actively engage in the use of personal health

records (PHR).

Instructions for Use1. PHRs are becoming popular, especially among those with chronic illness and for

those who must care for an elderly relative.. PHRs can be valuable aids for your residents and their families and for improving

your facility!s ability to collect accurate and complete information.

". #se the statements below to evaluate how your organi$ation wants to support

PHRs and%or their content, and develop your policy. &s with any policies youdevelop, ma'e sure it is approved by appropriate authorities within your

organi$ation.

Fors of PHRsollowing are two forms of PHRs

PHRs that are connected to a provider or health plan, such as *edicare. This form

of PHR is generally considered to be the most accurate because it is constructed in

a standard, computeri$ed system with providers contributing information to it

directly. re+uently, the structure does not permit an individual to alter anyinformation in the PHR from such sources. ndividuals may add to these records,

fre+uently adding information on use of over-the-counter medications, theirmedication schedule and response to medications, diet, blood sugar readings, etc.

ndividuals may print out information from such a record, or provide someoneelse, such as a clinician in your facility, direct access. This 'ind of PHR is

generally considered to contain protected health information under HP&&

because it is maintained by a covered entity. f this PHR is supplied through a

commercial PHR supplier, but offered by a provider and essentially maintained bythe provider for the individual, the content is still considered protected health

information, even though the relationship between the provider and commercialsupplier may be that of a HP&& business associate.

tandalone systems. These systems may include miscellaneous documents retained

by the individual or family or a computeri$ed system into which an individual maycontribute directly, as well as allow a provider to contribute to. /ther formats

also e0ist, such as a *edic-&lert bracelet, an organi$ed hard copy file of provider

documentation, or a computer file with e-fa0ed or scanned documents.

ecause computeri$ed PHR systems are not under the control of a provider, the

personal health information they contain is not protected health information underHP&&, and the supplier of the PHR is not a HP&& covered entity, or even a

business associate of a covered entity. 2hile this lac' of HP&& status means more tothe individual than a provider recipient from the standpoint of privacy and security

protection, some providers are concerned about the accuracy of PHR information and

the volume of information3especially when it may not be feasible to perform a

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professional review of all the information, leaving the organi$ation potentially liable

for content that has not been reviewed.

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PHR #cceptance Policy $ptions4onsider one or a combination of the following policy options

$ption "% PHR &ata is a Personal Resource

Personal health records are valuable aids for residents or their families to use tomaintain health information and to ma'e personal health care decisions. Their content

is not considered a part of the paper-based or electronic health record system wemaintain on behalf of our residents.

1. &s such, we recogni$e the e0clusivity of the information contained in a PHR andwill not attempt to append or accept any content directly from an individual!s PHR

into our health record system without consideration as described below in 5.. ndividuals should be encouraged to reference their PHRs when discussing their

health care with their providers. Providers may summari$e such information orre+uest a copy of specific parts of the PHR for inclusion in our health record

system if applicable. 2hen a copy is made of specific information (even if it is a

copy of another health care provider!s record content), it will be mar'ed 6copy

from 77name of individual77 PHR, reviewed by 77name of clinician acceptingcopy and date77.8

". hould an individual re+uest that our organi$ation accept PHR content into our

health record system, we will as' that the individual maintain his or her own PHRand use it for reference purposes. ndividuals have the right to re+uest anamendment to the health records we retain on their behalf.

9. &n individual wishing to re+uest an amendment to the e0isting content of the

health record in our system should be referred to 7777777777777777, who will

process the re+uest for amendment per HP&& regulations.:. n performing +uality reviews of our health record system, information accepted

from a PHR without authentication of a licensed health care professional will bedeemed 6signature deficient8 and returned for completion. 4ases of such

acceptance of PHR content also will be brought to the attention of our

documentation improvement program.

$ption 2% PHR &ata is a Priary Source of Inforation for the $rgani'ationPersonal health records are valuable aids for residents or their families to use to

maintain health information and to ma'e personal health care decisions. &s such, wesupport the development and use of PHRs in structured form, and will accept content

derived from an electronic PHR into our health record system in the following manner1. n accordance with standards of health care practice, we will offer, via a secure

portal or 'ios' directly connected to our information systems, the ability for ourresidents or their designated family member to update their contact and insurance

information, enter structured self-administered health history information, add

applicable substances to a current medication list, record dates and times of self-

administered medication ta'en, record dates of visits to other health care providers,

list immuni$ations, and provide other health information we determine to beappropriate and for which we provide a structure for receipt through the electronicinformation system.

. /ur secure portal or 'ios' will include specific information concerning how and

when we will use the information supplied, especially indicating that it will not be

accepted into our health record system unless and until it has been reviewed,validated, and accepted by a licensed health care professional. &pplicable health

care professionals will receive notification of newly entered information from theirdesignated residents via the dashboard or in-bo0 feature in our information system.

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&t that time, it must be reviewed, validated, and electronically signed by the health

care professional. f there are any +uestions concerning its accuracy, an annotation

stating 6this information was supplied by the resident ;or family representative

Documents

3.2.3HIE Policy and Procedure for PHR