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EHRs, Data Integrity and the Critical Need for a Data Governance Plan
EHRs, Data Integrity and the Critical Need for a Data Governance Plan
By Steven Blumenthal | 01-28-2015

In its Information Governance Principles for Healthcare, the American Health Information Management Association (AHIMA) advocates that healthcare providers adopt a data governance policy that addresses the following principles:  accountability, transparency, integrity, protection, compliance, availability, retention and disposition. AHIMA highlights data integrity, saying that trust plays a critical role in healthcare delivery, and that trust depends on the completeness and correctness of data.

I agree with AHIMA: data integrity is the issue that drives all others.

Data integrity issues have particular impact on mobile health apps. Mobile health apps generate significant amounts of potentially helpful patient health data. However, a healthcare provider would increase its risk of medical malpractice by simply including that data in the applicable patients’ electronic health records. Here’s why:

  • Accuracy and reliability issues.  According to The New York Times, “Some of the attempts to turn the iPhone into a medical device are little more than toys.” Including inaccurate data from an app in a patient’s EHR could lead to inaccurate diagnosis and improper care.
  • Data provenance issues.  Not all data is created equal, and clinicians need to understand the source of the data (its “provenance”) to know how much weight to give it. According to a 2013 report issued by the National eHealth Collaborative, methods for recording and preserving the provenance of patient-generated health data as it flows through systems and processes for handling it are not yet mature.
  • Data overload issues.  Once data is incorporated into a patient’s EHR, the healthcare provider is responsible for knowing that data and the relevance of that data to patient care. According to Rishi Diwan in his article “Measuring Malpractice in Modern Mobile Medicine,” a clinician may face the threat of malpractice suits arising from her non-delegable duty to be aware of reasonably available medical information significant to the health of her patient prior to administering treatment.
  • Unrealistic expectations.  Patients’ expectations of the value of their mobile app health data and the ability of their clinicians to review and use it are probably out-of-sync with the current reality, a point underscored in both the National eHealth Collaborative’ s 2013 report and Mr. Diwan’s article.

So, what should you do?

  • Develop and implement a data governance plan. In their March 2014 article, Alisha R. Smith and Rita Bowen, recommend first establishing a steering committee that includes the CIO, all data administrators and representatives from HIM, patient access, the legal department and risk management. I’d add someone from business development/planning to share insights about business priorities and timing.
  • Conduct a pilot program for a single mobile health app. A pilot program can help you identify protocols for integrating mobile health app data and for determining the value of the data collected. Even an unsuccessful pilot has an incidentally positive side-effect – it’s evidence that you are keeping abreast of new technology and making a reasoned decision to not pursue it.
  • Take care of the less exciting work first. Don’t put the exciting opportunities offered by mobile health apps ahead of the less exciting work involved in setting up an effective framework for managing your data.
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Author Information

Steven E. Blumenthal
615.850.8809
steve.blumenthal@wallerlaw.com
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