AHIMA’s Position
AHIMA supports the right of individuals to access their accurate and complete health information in a timely manner. Health information (HI) professionals are the frontline professionals when individuals seek access to their health information, and they have the expertise and knowledge to inform and enhance public policy that seeks to improve individuals’ access to their health information. To enhance individuals’ access to their information, AHIMA believes that public policy that seeks to increase and automate individual access to health information must:
Guarantee an individual’s right to access his or her health information.
Policy must ensure that an individual has the right to access their health information regardless of where it is captured, stored, or exchanged.
Address complex record request workflows and processes.
Policy must take into account existing workflows and processes and allow providers to streamline and make their workflows and processes more transparent for patients.
Leverage application programming interfaces (APIs) and modern technical standards.
Policy must encourage adoption and implementation of APIs and standards, such as fast healthcare interoperability resources (FHIR) to foster the development of new applications (“apps”) and services that facilitate an individual’s seamless electronic access to and control of their health information. This includes the adoption of appropriate privacy and information security policies that ensure the privacy, confidentiality, and security of health information.
Encourage a common interpretation of the designated record set.
Policy must encourage a consistent, standardized interpretation of the designated record set (DRS) across federal agencies to reduce discrepancies between institutions, providers, and other stakeholders in the access, exchange, and use of electronic health information (EHI). Such interpretation must expand over time to include additional data elements, as standards to support such elements become electronically available and capable of being deployed.
Embrace the role of health information professionals.
New standards and approaches must recognize the expertise HI professionals have in facilitating and supporting individuals’ access to their health information while adhering to state and federal requirements.
Background
The ability of individuals and their caregivers to access, exchange, and use their health information is essential to managing their care. Today, nearly all hospitals provide patients with the ability to electronically view and download their health information. However, despite these technological advances and the right of individuals to access their health information under the Health Insurance Portability and Accountability Act (HIPAA), individuals continue to struggle with accessing their health information in a manner that is seamless, timely, and electronic. Enhancing individuals’ access to their health information could yield significant benefits, including improved patient outcomes and enhanced patient safety. However, certain challenges must be addressed including cumbersome, opaque record request processes for individuals. As policymakers aim to address this important issue, AHIMA members have the expertise to offer insight.
Key Points
To realize the benefits of individuals’ access to their health information, certain challenges must be addressed including:
Cumbersome and decentralized processes for individuals requesting records.
Today, the record request process may involve logging into a patient portal or going online, downloading an authorization form, printing it, and then mailing or faxing it in. On other occasions it may involve travelling to the provider’s location and filling out a form in person.
Lack of staff training and policies to facilitate individuals’ access to their health information.
New approaches to improving individuals’ access to their health information will require appropriate training and policies for patient-facing staff to reduce discrepancies in how requests are processed and fulfilled.
Lack of transparency during the record request process.
New approaches will require greater transparency regarding what information may be released, how it can berequested, the status of an individual’s request, how long the process takes, whether additional information may be required to process the request, and the potential costs associated with the record request.
Manual workflows for HI professionals in fulfilling access requests.
New approaches must take into account practices intended to protect the confidentiality of an individual’s health information in accordance with state or federal laws, while streamlining existing workflows to expedite an individual’s request for his or her health information.
Lack of common interpretation of the designated record set.
Healthcare organizations have interpreted differently and applied inconsistently information that may be included in the DRS. This variation has not only led to discrepancies and confusion in the information provided to individuals during the medical records release process but could lead to confusion and inconsistent application of the definition of EHI under the ONC Cures Act Final Rule.
Conditions that may limit individuals’ access to their records
Including geographic location, socio-demographic characteristics, internet access and use, and health conditions.
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