We all know that healthcare providers want to encourage patient engagement to ensure patients have the information they need to manage conditions and share information with other providers. There has been a longstanding push for the adoption and maintenance of personal health records for many years to give patients the power to share and disseminate information wherever it is needed. We have seen a remarkable new interest in this with Meaningful Use and population health initiatives. Since HIM professionals are charged with maintaining and producing legal copies of records, we are aware that the tasks surrounding these processes can be very expensive. This is especially true if any of the tasks are not handled properly and breaches of protected information occur.
My concern is that lately I have heard many discussions that are pushing for more access yet with fewer costs to patients to encourage patient engagement. Some are even pushing for patients to have “free” access to records- paper or electronic. Don’t get me wrong, I am a huge proponent for patients having copies of their records and I personally keep copies of my own records. The Office of Civil Rights (OCR) recently published further guidance on charging for records. In a nutshell, the OCR says: “copying fees should be reasonable. They may include the cost of labor for creating and delivering electronic or paper copies; the cost of supplies, including paper and portable media such as CDs or USB drives; and the cost of postage when copies of records are mailed to patients at their request.” The OCR actually has the authority to audit the costs of producing records if they feel your organization is violating this patient right and overcharging for release of information.
Living in a state such as Florida where the state law has allowed facilities to charge up to $1 per page means most facilities have charged $1 per page without blinking an eye. The latest OCR guidance has led to questioning if that amount is actually “reasonable” or true to cost. Afterall, HIM professionals must use expensive systems, supplies, and labor costs to produce these records. Many organizations have outsourced release of information functions (another cost) but it is still the responsibility of the custodian of records to oversee the processes for compliance.
That being said, it is beneficial for HIM departments to evaluate the expenses and methods used to produce records as technologies and laws change. Dr. Karen Desalvo of the Office of the National Coordinator (ONC) strives to lead the EMR interoperability movement. At the top of the ONC’s list of commitments is consumer access to records. HIM professionals should continue to assist in the quest for interoperability and electronic data sharing at the notion of patient engagement. We must lead patients to use EMR patient portals and facilitate the efficient electronic data sharing among healthcare providers. We must be creative in lowering overhead costs to produce and maintain the records in order to ensure costs are affordable for healthcare consumers. There will always be costs associated with this important task, whether on the provider’s end or the patient’s end, just as costs are incurred with most services or products in every industry.
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