The following appeared a few days ago.
HDM Breaking News, April 21, 2011
By Mark Vreeland, Executive Director, Advisory – Healthcare, Ernst & Young LLP
With the Patient Protection and Affordable Care Act being implemented in stages through 2020, there has never been a more critical need for effective information governance at health care organizations in the United States. A powerful information governance program—one that sets forth clear structures, policies, processes and controls for managing data and information as business assets—offers significant benefits to health care organizations working to meet the new rules and requirements of health care reform.
Information governance allows for consistency of information to be used for analysis and reporting. It establishes the first line of action for data quality, metadata (the intersection between business definitions and physical data implementation) and master data management (a structured approach to managing specific data domains as master data associated with core business entities). Effective governance enhances enterprise agility by allowing for easier migration. It improves the customer's experience, lowers management costs through reducing data redundancy, offers impact analysis across the organization for change requests, and enhances the organization's ability to analyze and report on enterprise information.
On the flip side, the absence of a strong information governance program can pose serious risks to a health care organization, particularly as provisions of the Patient Protection and Affordable Care Act take effect. Inconsistency in reporting and analytics can lead to noncompliance with reporting requirements of the Act. Noncompliance, in turn, could trigger substantial financial penalties for the organization.
An example of insufficient information governance at one organization
Recently, while assessing a health care payer’s analytical environment, our team discovered an anomaly that is all too familiar among payers: no one person or group at the client was solely responsible for compiling per member, per month numbers. In fact, various groups were using different definitions of PMPM and producing conflicting counts for analysis and reporting. As a consequence of a lack of governance over PMPM, the organization had inconsistencies across a number of reports and analytics. In the health care industry, PMPM is a hugely significant calculation—it affects 40 to 50 different analytical functions. So when PMPM numbers are reported incorrectly or inconsistently, the various analytical functions that rely on these numbers will be out of kilter and the situation could lead to noncompliance with reporting requirements.
Fortunately, at this organization, we were able to help them implement a program that addresses proper governance over PMPM calculations. The payer now relies on its actuary group alone to define PMPM for internal use and external reporting. This is just part of the organization's broad new effort toward a significantly upgraded information governance program.
But that's just one organization. Too many others in the health care industry are needlessly at risk because they remain stalled in an early, fairly undeveloped stage of information governance and lack momentum toward a fully realized, mature and highly effective governance program.
A framework for effective information governance
Successfully managing enormous amounts of data and creating actionable information from that data are daunting challenges for most health care organizations. Yet these challenges become far more manageable when approached under the guidance of a carefully designed framework for effective information governance.
What does such a framework look like? It consists of three main disciplines that together support the entire life cycle of information at the organization: the Business Information Discipline, the Systems and Network Discipline and the Information Asset Discipline. Each has its own unique combination of people, process and technology. And each is supported through a defined metadata management strategy.
The article above is talking about Health Information Governance but I would submit the problem we have in Australia is even broader than just information governance - it covers also the governance of the whole e-Health initiative in this country.
At a national level we lack the frameworks, mechanisms and expertise to create a coherent vision of how we should move forward. We also because of this do not have the leadership and political commitment to follow through on already developed plans - let alone refine and develop new and improved versions.
At a State level we suffer badly from the private / public divide and initiatives seem to somehow not reflect the desired integration of health services at the point of care to optimise the patient experience during their care journey.
At the level of Standards setting we find messiness with NEHTA, Standards Australia, DoHA and Industry lacking the overall frameworks and leadership they need to really move forward with some confidence.
We also lack the sustained and transparent funding commitments that are needed for major investments to be made by actors external to the Government Sector.
Of course we also have information governance issues also with the AIHW working manfully to get comparable and trustworthy information on the Health Sector from both the States and the Private Sector - all of which have reasons to obfuscate to a greater or lesser degree.
All in all a bit of a mess. If it isn’t fixed you can be sure the PCEHR and its support infrastructure will wind up being a waste of time and money I believe.