Energizing (or Re-energizing) Your Information Governance Program

NCHICA 23rd Annual ConferenceSeptember 11, 2017

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• Why Information Governance? The business drivers• Case Study: Cone Health• Industry Perspectives

– Data Governance vs. Information Governance– Starting or restarting your IG program

• Discussion

Topics

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Business Drivers: Why Information Governance

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• Financial Incentives– Population health, publicly reported outcomes, and risk based contracts

make ensuring information integrity and accessibility imperative. • Staff and provider satisfaction

– People are frustrated with conflicting data and with lack of access to actionable information.

• Enterprise risk– Greater organizational complexity and joint risk arrangements with outside

entities necessitate in depth understanding of legal and compliance risks. – Privacy/security controls are crucial to patient and affiliate provider trust.

Business Drivers: Shift to Value-Based Payment ModelsCurrent CMS Innovation Models in NC

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Source: Innovation.CMS.gov/initiatives (2017)

Business Drivers: Controls vs Democratization of Data

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Controls Democratization

Larger data setsMore data sources

Diverse formats/typesMore timely/real-time data

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Business Drivers: Health System ownership of entities like ACOs and insurance plans

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All IG programs must be structured to comply with statutes such as Sherman

Anti-trust, Stark, and others.

Case Study: Cone Health

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Insurance Plan

100+ Physician practice

sites

Six Hospitals

Multiple Centers of Excellence

Three Ambulatory

Care Centers

Two Skilled

Nursing Facilities

Four Urgent

Care Centers

Three Outpatient

Surgery Centers

ACO

Case Study: Information Governance at Cone Health

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Catalysts for re-examination of Cone’s Information Governance Program were:

EDW

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Case Study: Cone Health’s IG Journey

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Initial efforts included– Creation of a Head of Data Governance role embedded in

the Analytics dept.– Creation of an Information Asset Steering Committee– Focus on data governance and EDW stand up– Selection of an Information Governance framework

(AHIMA’s IGAM)

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Cone Health: Adopting an IG framework

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Case Study: Cone Health’s IG Journey

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Next StepsCone conducted an enterprise wide self assessment of our IG maturity using AHIMA’s tool IGHealthRateTM.

Case Study: Cone Health’s IG Journey

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• Educate leaders

• Empower the new IG Council to hold stakeholders accountable.

• Reduce Organizational Risk

New Goals

• Quick Wins = Engagement

• A framework brings focus and understanding

• Top down effort

Lessons Learned

Information GovernanceData Governance

• Standard metrics, definitions, terminology

• Standard master & reference data

• Metadata/business glossary• Data quality monitoring, SLAs

• Data life cycle management policy/procedure

• External release of information policy/procedure

• Legal, compliance & risk management

• Data access & use• Security & privacy

Industry Perspectives

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Examples: Value-Based Care Use CasesUse Case Data Governance Needs Info Governance Needs

Identify outliers in cost/utilization • Clinical taxonomy• Normalized charge master• Define Key Performance Indicators (KPIs)• Define data quality KPIs • Role-based access policy

• Security/privacy policy & controls

• Data sharing agreements• Data retention policies• Data discovery/legal risk

assessment & requirements• Data quality SLAs & enforcement• Legal/regulatory risk assessment

(Stark, Sherman)

Identify gaps in care/preventative services

• Enterprise Master Patient Index• Provider master• Define process KPIs• Define data quality KPIs

Compare performance across clinicians / clinician performance incentives

• Define standard Clinical Quality Measures (CQM)• Define data quality KPIs for CQMs• Provider master• Provider attribution rules

Referrals analysis/ leakage analysis

• Define KPIs• Define data quality KPIs • Provider attribution rules

KPIs = Key Performance Indicators

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Challenges for ACOs/CINs

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• Awareness of information governance needs & risks• Community provider perceptions of the health system

– “I don’t want the health system to be able to access my data”• Changing the culture

– People are very territorial• Availability of staff with the right knowledge and skills• Lack of standards/consistent interpretation of standards• Trying to ‘boil the ocean’• Need for clinical documentation improvement across the network

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IG: Organization Structure Better Practices

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Who? What?

Existing executive leadership team

Multidisciplinary process & data owners with decision

authority

Standing & ad hoc teams of subject matter experts, data stewards, & data custodians

• Define strategy• Allocate resources• Advocate for change• Hold people accountable

• Define tactics/ plans• Operational oversight, issue resolution• Institute change / change management• Approve policies, standards, procedures• Hold people accountable

• Recommend policies, standards, procedures• Execute tactics/plans• Escalate issues• Coach/support front-line during changes

Executives

Steering Committee

Workgroups

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Where should we start (re-start)?

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Top Down

Bottom Up

• Educate executives• Conduct gap analysis/risk assessment• Align with strategic plans & initiatives• Develop a roadmap –practical, tactical, value-focused• Establish key roles & responsibilities• Allocate key resources

• Identify 1-2 strategic use cases and take them on as a pilot– Support a strategic initiative that is already resourced & has attention– Do the DG & IG work and educate the project participants

• Formalize ‘what works’ into the base for your IG program• Educate on/advocate for IG using the outcomes of the initial work

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In Summary

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• Information Governance is – Needed to effectively provide information needed to enable value-based

care– Crucial to manage and reduce organizational risk

• Information Governance is NOT a project– It needs to become engrained in ongoing, day-to-day work– Resource allocation & job descriptions need to account for this

• Each organization has unique challenges – driven by history, culture, and current strategic priorities– The ‘right’ approach will vary– Start focused on quick wins and grow from there

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Questions? Comments?

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Richard J. Pro, MBA, MS, FAHMrichard.pro@conehealth.comLaurie Norton, MPHlaurie.norton@conehealth.comPaula Edwards, Ph.D.pedwards@himformatics.com