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“Active” Record Retention and Legacy
System Decommissioning:
Use Cases and Lessons Learned from Successful Projects
NMHIMA Spring Conference
April 18, 2017
Presented by
Tony Paparella, President
The Triumph and the Party….
New EMR and revenue cycle systems installed concurrently
Staff highly engaged in the new HIS implementation
Considered a great success!
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
… and there was celebration and great merriment across
the organization after a successful implementation….
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
…Then the Hangover 100’s legacy applications that were no longer needed
….and the associated costs
CURE: retire legacy applications, retain the data in an active archive
•Establish good data stewardship
•Identify data to archive and identify data to destroy
•Archive the data to retain its original meaning, essential active functions, and make accessible to users
•Decommission the legacy systems
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Critical Factors for Success Legacy Retirement
& Data Retention
• Active leadership support for retiring applications
• Buy-in from departments and users
• Expectation setting among users & departments
• Technology: “Active” archiving, ability to handle
workflow & use cases
• Migrate data prior to decommissioning
• Prioritize the projects in line with new systems
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Drivers of Change in Healthcare Market
Healthcare Market
Transformations:
o Federal Mandates (ICD-10 and Meaningful Use)
o Acquisitions and Mergers
o Budgetary Pressures to Consolidate Applications
o Data Driven Healthcare
Data Retention Drivers:
o Federal/State Compliance and Retention Requirements for Clinical Records
o Continued Need for Accessing Clinical Records
o Audits: RAC, Medicare, Medicaid, Commercial Carriers
o Billing Requirements
Legacy
Application
Challenges
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
The Lifecycle of Data
Database Archiving for Long-Term Data Retention
http://www.tdan.com/view-articles/4591, accessed January 2010
Healthcare adds “post
production workflow”
General perception: keep patient data for 7 yrs.
In actuality, many different regulations, laws and guidelines
range from 2 to 30 years, some examples:
– 5 – 10 years for Medicare, Medicaid and Commercial carriers
• RAC Audits, MSP Audits, Commercial “take backs”
– HIPAA: 6 years for PHI requests & disclosures
– State Laws: 6 – 30 years, e.g.:
• Massachusetts was 30 years
• Pennsylvania 6 years
• Mississippi: 10 years for adults, up to 28 years for Children
– Pediatric Care: up to 28 years (age 21 plus 7 years)
How Long to Keep data?
Data to Archive
No workflow,
no GUI
Replicate legacy
look, feel and
workflow
0% 100%
Retain essential
workflow
Workflow & User Access
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Systems to retire
Goal:
- Decommission all legacy applications
- Make well informed decisions on what data needs to be retained and most
appropriate method for doing so taking into consideration:
- Retention requirements
- Use cases for accessing the data
- Cost for storage of data
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Patient Accounting –Sustain cash flow with
extensive, robust active patient accounting
functionality. Continue to post payments, submit
claims, add notes, and manage interfaces.
Clinical – Patient centric longitudinal view of
clinical records compiled from multiple legacy
systems
HIM – Easy to respond to Release of Information
(ROI) requests
ERP – Human Resources, Payroll, General Ledger,
etc.
Typical use cases
Building a Business Case
Revenue Cycle
• Reimbursement/ Payment History Records (10 years)
• Master Patient Index/ Visit History (permanently)
Clinical:
• Adult records (10 years from most recent visit)
• Minor records (28 years)
Data Retention Guideline
Revenue Cycle
•Billing/Payment Posting
•RAC Audit Responses
Clinical:
• Physicians need to reference for point of care clinical history
• HIM staff ability to respond to ROI requests
Use Case
ERP
• 10 years
ERP
• EOE audits
• HR, Payroll/pension inquiries
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Building the Business Case ROI Analysis
Example: legacy costs:
Software maintenance fees $120,000
Infrastructure Support $50,000
Hardware refresh (annualized) $6,000
Internal help desk (partial FTE) $12,000
Data center costs $12,000
1 Yr. Total $200,000
Legacy Cost for 7 years $1,400,000
Example: Archive cost:
Data extract & migration (vendor) $80,000
Project management, internal $10,000
New software (7 years, SaaS) $336,000
7 Yr. Total, Active Archive $426,000
ROI: Savings over 7 years: $974,000 (70%)
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Build the team: Steering Committee
IS
HIM
Research and Education
Clinical
Legal, Compliance Guidance from each
of the following
areas is needed on
an application by
application basis, as
appropriate
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Rev Cycle
Other Dept. heads
Conduct Inventory of Existing Applications
Identify data type
Identify key owners of the data
Document key contract dates and termination options
Assess hardware/software stability risk
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Conduct Analysis of Existing Applications
Dis
covery
Sess
ions
Document Use Cases for Data
Confirm Data Retention Guidelines
Identify Contract Extension/Termination
Options
Option 1
Option 2
Option 3
End Goal = Determine
Data Archival Options
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Using an Active Archive
Not a “typical” archive
Includes workflow functionality
• Billing accounts for active A/R (2+ years after last DOS)
• Release of Information
• Interoperability
Allows for real-time, end user access
Reporting
Discrete data elements and document images
Secondary use of data
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Execute Plan
Charter steering committee for overall initiative
Identify project specific resources needed
Develop project plan/timeline
Migrate data as appropriate
Decommission legacy application
1)$ millions saved per organization
2)Legacy systems decommissioned (a few to 100+,
depending on organizational initiative)
3)Data retained and consolidated
4)Workflow retained: billing, ROI, clinical, reporting,
other;
5)IT landscape simplified
Legacy Retirement & Data Retention Program Results
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Start early – ideally at the same time as selection of new HIS or during merger
Include the business unit stakeholders: Revenue Cycle, Clinicians, HIM, Finance/HR
Manage expectations: time, budget & archive functionality
Engage in data retention ‘road mapping’
Ensure a successful program with your own internal project manager/coordinator
Ensure validation beyond a simple record count
Lessons Learned
Presented to NMHIMA, 4/20/17 Copyright, MediQuant
Questions?
Tony Paparella, President