This complex process can generate revenue, but the resources involved deserve a closer look.
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| Jonathan Arkin |
The electronic medical record and electronic document management systems are important steps in an overall electronic health record strategy. These systems offer a strong return on investment (ROI); electronic document management systems usually pay for themselves within two and a half years or less through decreased costs, increased efficiency and improved revenues. Vendors have begun to include the release-of-information process in ROI calculations for their systems, but the process and its potential revenue remain a source of confusion.
Rules and Regulations
Release of information is an important and often overlooked function of a health information management department. The release process includes logging, fulfilling and invoicing for medical record requests from patients, insurance carriers, attorneys, government agencies and other providers. Highly regulated and minimally reimbursed, the release-of-information function is outsourced in nearly 80 percent of hospitals nationwide, according to the Association of Health Information Outsourcing Services (AHIOS). Vendors who provide this service typically do so at little or no cost to the health care provider, instead relying on payments received from the record requester, typically $20 to $30 per transaction. In many cases, these transactions are non-billable, because they are part of day-to-day treatment, payment or operations.
EMRs have a positive impact on the release-of-information process by facilitating more complete record retrieval and better tracking of the request, functions which in some cases are highly integrated into the EMR and document management systems. All of these steps can be supported through technology. But they comprise only 20 percent or less of the entire process.
The remaining 80 percent includes deciding which data to send, packaging it up and sending it confidentially to the correct requester. In addition, expertise is needed to deliver quality customer service, invoice for services in accordance with a complex matrix of legislated fees, and successfully collect thousands of small-dollar invoices. All of these tasks must be taken into account when organizations decide whether to outsource the release-of-information function with an EMR.
The Health Insurance Portability and Accountability Act plays a significant role in release of information. Its rules and regulations, combined with a health care entity’s own procedures, dictate the parameters within which the release-of-information process operates. The steps include:
- Logging and tracking requests
- Verifying that the authorization is compliant with state and federal laws
- Retrieving information in various formats and from various locations
- Judging the information required to fulfill the request according to applicable laws
- Protecting sensitive information and data
- Reproducing information
- Packaging and delivering the information
- Invoicing and collecting fees from requesters
Each of these steps require judgment, knowledge of legal and liability issues, an intimate understanding of the health care organization, technological expertise and detective skills. Further, this process must be handled within the tight timeframes dictated by law or internal policy. This function is controlled by release-of-information professionals who are educated and trained to handle this mission. Two factors can complicate the picture.
First, these experts are often hard to find and retain. They must be well-versed in state policy and guidelines and provide excellent customer service. According to the American Health Information Management Association, 6,000 new health information management workers are needed every year but only 2,000 graduate annually from approved programs. Additionally, the U.S. Department of Labor and Statistics expects 49 percent more HIM professionals will be needed by 2010.
Second, the release of information function requires two skill levels: expert (as mentioned above) and clerical. It is a waste of precious resources to relegate to experts the clerical tasks such as preparing bills, invoicing and accounts receivable follow-ups.
Five Questions
Technology vendors often suggest that the release-of-information function can be performed by hospital staff and produce enough revenue to help justify an EMR or electronic document management system. The number of transactions is large enough to create a reasonable revenue stream. In theory, this would happen by bringing the release-of-information process back in-house.
In support of the in-house decision, the release-of-information process can be a byproduct of implementing an EMR and document management system. These systems can streamline the information retrieval step within the release process. Still, the health care organization should consider the following questions prior to including the release-of-information process in any ROI calculation:
- Will additional staff need to be hired and trained to bring or keep the release-of-information function in-house?
- Who will focus on ongoing compliance and regulatory mandates related to release-of-information to mitigate risk and ensure the privacy and confidentiality of protected health information?
- What are the annual costs of paper, printing and postage to fulfill requests? Can the EMR and document management systems fulfill and send requests electronically?
- Who will manage the invoicing and collections for the release-of-information process? What will be the costs of collection?
- Can all of these revenues and costs be segregated and measured to determine the return on such an investment, including the actual revenue collected from this process?
A Closer Look at Costs
The main concern behind an in-house release-of-information function is the “collectability” of revenue. As mentioned earlier, the typical bill is $30 or less. The organization needs personnel to track down non-paying attorney and insurance requesters. If it opts to pre-bill every invoice, it must budget for the extra postage and supply costs and prepare for requester calls regarding the delays with receiving records.
In addition, because the EMR improves the efficiency of this process, many states are revising the maximum amount chargeable for release-of-information services. AHIOS is working with several states to adjust these rates with a focus on fair and equitable compensation for both provider organizations and vendors.
Even if the health care organization has adequate staff to perform billing and collections, other expenses must be factored into any analysis. One example is printing requested records. Medical record systems are designed for clinician use and to support the legal health record, not necessarily for printing and fulfilling large volumes of outside requests. Converting the electronic information into paper format and sending it to the requester can be labor and resource intensive.
Vendors who provide release-of-information services have economies of scale in production to reduce the per-request cost. Further, they have a well-trained staff capable of ensuring adherence to HIPAA and other federal and state regulations and collecting delinquent receivables. For the health care organization, outsourcing the release-of-information process can lead to improved morale and productivity among existing employees, and time and space savings.
Health care organizations evaluating an EMR and document management system should take a detailed look at the vendor’s ROI calculations. If they include a line item for the release-of-information function, a careful analysis should follow. The question for executives to ask is whether the organization can make more or less money if the release-of-information process is performed within or outside of the facility.
There are many options where medical record technology and release-of-information intersect. Each organization must consider the positives and negatives of each. While the release-of-information function does not have to be completely outsourced in an electronic environment, the clerical tasks, including processing, sending, invoicing and accounts receivable, still make sense for a vendor partnership.
Jonathan Arkin is vice president, business operations, for HealthPort, Alpharetta, Ga.
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