Presentation on theme: "A Case Study: Implementing HIPAA at Kaiser Permanente"— Presentation transcript:
1 A Case Study: Implementing HIPAA at Kaiser Permanente HIPAA Summit West IIA Case Study: Implementing HIPAA at Kaiser PermanenteMary Henderson, MPH, MBANational HIPAA Program DirectorJohn DesMarteau, MD FACAKaiser Permanente Mid-Atlantic HIPAA Project
2 Kaiser Permanente: A Snapshot Kaiser Permanente has:Regions in 9 states and Washington, DC8.3 million members29 Hospitals423 Medical Offices11,345 physicians122,473 employeesMore than 3,000 applications that contain HIPAA relevant informationKaiser has a health plan and a medical group in each region. We also have hospitals in 3 regions. Since HIPAA applies to:health plansproviders andclearinghouseswe’ve got a lot of work to do.History of autonomy resulting in:a variety of legacy systemslots of decision-makerscomplicated processes for joint decision-making
3 The KP HIPAA ApproachNational sponsorship: Health Plan, Hospitals, Medical Groups and ITRegional sponsorship: Regional Health Plan Presidents, Medical DirectorsMulti-disciplinary core advisory group: Legal and Government Relations, Internal Audit, Public Affairs, IT Security, Health care operations, Labor Relations, Others as neededNational and Regional Teams: National directors for IT, Business, Health Care Operations; Regional leads for IT, Business, Health Care Operations; KP-IT Functional LeadsLegal expertise: Internal and externalAdvocacy: To achieve favorable interpretations
4 National Team Organization Regional Project Structure HIPAAProgramSponsorsRegional President& Medical DirectorHIPAA ProgramDirectorCore AdvisoryGroupRegionalBusinessLeadsRegionalHealth CareOps LeadsRegionalIT LeadsProgramManagement OfficePolicy AnalystCommunicationsBusiness TeamDirector (EDI)Health Care OpsTeam DirectorIT TeamDirectorRegionalBusinessLeadsRegionalHealth CareOps LeadsITFunctionalArea LeadsRegional ITLeads
6 Kaiser Permanente’s EDI Approach We are developing a “KP Clearinghouse” - a set of shared utilities - to translate specified information into HIPAA compliant format + modifying applications as needed.We chose the KPC approach because it is:significantly less expensive than modifying all applications affected,achieves economies of scale in the short and long run,allows for evolution of legacy systems and business processes, andfacilitates maintenance (e.g., the addition of new transactions and codes, changes to layouts)We believe that the KPC has a long term value even as applications are replaced.
7 Clearinghouse Utility for Achieving HIPAA Compliance: KP ClearinghouseAuthenticates that the tradingpartners are who they say theyare and they are authorized for transactions.External Trading PartnersHealth plansProvidersEtc.Send transactions via:WebExternal clearinghousesDirect interfacesValidates correct format,edit for content and syntax.Transactions (EDI, Disk, Tape, Web)TransactionsKP ApplicationsClaimsMembershipBillingEtc.Stores and validates reference data(examples are ICD-9, CPT4,Provider id’s, Implementation Guides.)Warehouse stores original transactionsand transformed inboundand outbound transactions.Indirect impactsMessage formatter translates and reformats dataDelivers transactions to legacysystems in most efficient manner.Clinical Systems,Provider Mgmt., othersManages data, format and transmissionerrors and trading partner, applicationand business processing rules.
8 KP Clearinghouse: Supports Compliant/Non-Compliant Applications Enables interface between applicationsKP ClearinghouseFullyCompliant ApplicationsAuthentication.Edits.Data Management.Non-Compliant ApplicationsWarehouse.InterfaceLogicTransformation.Delivery.Administration/Error Management.Clinical Systems,Provider Mgmt., othersRepresents an example of re-use of KP Clearinghouse utilities
9 So What Are the Challenges of the EDI Extension for KP Applying for the extensionReminding executive leadership that HIPAA doesn’t go awayRevising 2002 and 2003 budget plansRestructuring the work without losing momentumRedeploying staffWorking with trading partners who want to send compliant transactions in Oct. 2002
10 And Benefits from the Extension Spreading EDI over an extra year = need for less $$ in 2002 budgetMore time to test our workTime to reevaluate our approach and identify opportunities the delay may provide (90-day study)With privacy deadline barreling our way, able to redeploy some staff to privacy work
12 Value of Increased EDI Capabilities Potential cost reductions such as:Reduced phone inquiriesReduced processing of paper checksReduced manual keying of data and data verificationReduction of other manual processes such as scanning, fax responses, mailroom handling, etc.Sets the technical environment which allows for broader benefits. Full benefit realization would require significant changes in business processes (e.g., linking contracts, referrals and claims to permit auto-adjudication of claims)
13 Where is KP Now on EDI? Almost finished with 90-day study Proceeding on the KPC - alpha build in May 2002; full build Sept. 2002Modifying some applications in 2002; delaying some to 2003Considering how to approach EDI extension request - one KP request or several (KP Regions)Planning for April 2003 test dateContinuing to identify benefits
15 Challenges of Privacy Regulations Getting consent for treatment, payment and healthcare operations from all 8.3 million current members and patients Tracking consent, effective date, revocationEffectively and efficiently tracking disclosuresMinimum necessary - how to use subset of paper or electronic chartFinding privacy officersTraining staff prior to April 14, 2003National and regional multidisciplinary KP Work Groups developing approaches
16 Challenges of Security Regulations Estimating/securing resources prior to final regs (probably most costly area of HIPAA)Understanding current situation (i.e., multiple regions and varying policies)Assessing risk and making policy decisionsFinding security officersAdding an audit trailDealing with overlapping elements between HIPAA Privacy (deadline April 2003) and Security (no deadline yet) e.g., training and business associate agreementsClearly we don’t have time to talk about overcoming all of these, so I’m going to focus on our risk management approach as an example of how we’re moving this forward.
17 Privacy and Security: Perspective from the Frontline AdministratorCorrespondenceClaims DatabaseWeb ServerMail ServerPhysiciansMedical Research DatabaseAdmission DataPhysiciansDMZPediatric NurseSwitchFirewallVPNHost Based IDSRemote ClinicInternetRouterConfidential PatientInformation DatabaseNetwork IDSCritical System PasswordsBusiness AssociatesClinical Trial DataPayroll &Personnel filesSwitch
18 Privacy and Security A Matter of… PeopleSystemsTechnologyRegulationsEvolution… And the Clock is Ticking
19 Privacy - For almost 5000 years The patient tells another person:no documentationno privacy“My left foot is numb and I have this incredible thirst.I’ve been kind of depressed lately.”Nevertheless…
20 Privacy FearsSteven—you are to begin therapy, as your blood test indicates 25% risk of teenage depression based on your genetic profile.Father just got a telemarketing call from a home blood sugar monitoring service. But I don’t think he ever followed up on that office visit to the doctor!
21 Over The TopAnd now, Mr. Jones’ scores from our health insurance judges…
22 Elements of Privacy Management AdmissionAuthenticationAccess controlsAdministrationAccountabilityAudits (before not after)ApprehensionFor example…C
23 Someone has to write the rules1 Someone has to run the audits2 Someone has to be accountable1the rules have to be meaningful2the audits have to be meaningfulC
24 Privacy Officer Needed Necessary for the practice to be HIPAA compliantNecessary as a good business practiceMaking certain that the practice remains HIPAA compliantRisk assessmentGathering consentsProper disclosuresProper securityInterface with patientsCan be the “office manager”HIPAA expertise abounds (print, internet, consultants)
25 Keeping Health Information Secure Information is a health industry assetInformation can be critical and/or sensitiveLoss of confidentiality, integrity, or availability can have financial implicationsLoss of Integrity or availability can cost a life!Donn Parker, SRIIntegrityConfidentialityAvailability
26 How is Security Threatened? What is a threat?Possibility, or likelihood, of an attack against your organizationPotential for damage to your organizationAccidental vs. intentional threatsThreat formsHuman ErrorsMalicious ActsSystem FailuresNatural Disasters
27 Security ‘Vulnerabilities’ ItemPaperDigitalLack of policies and procedures44Incorrect policy implementation44No intrusion detection44Software bugs/ design flaws4No firewall or poor implementation4No virus protection/ poor implementation4
28 Information Security Hierarchy: Best Practices Approach AdministrativePolicy & ProcedurePersonnel SecurityTechnicalNetwork ConnectivityVirusesAuthenticationAuditBackup and RecoveryEncryptionPhysical SecurityStep 6ValidationStep 5Auditing, Monitoring and InvestigatingStep 4Information Security Technologies and ProductsStep 3Information Security Awareness and TrainingStep 2Information Security Architecture and ProcessesStep 1Information Security Policy and Standards
29 Top Ten ‘Reasons’ to Defer Security “Compliance is in the eye of the beholder”1. “We trust our staff and our physicians”2. “Security expense cannot be cost-justified”3. “Our software vendor is responsible for EDI security”4. “We have a firewall!”5. “Our IT Provider is handling our network security”6. “Our information assets are not at risk”7. “We can’t afford another Y2K of IT expenditures!”8. “We have a solid consent and authorization process”9. “If someone really wants to crack our system……”10. “The HIPAA Security Standard is not finalized!”
31 Security and Privacy Regulations: Risk Management Challenge Interventions or ToolsBad Outcome(e.g. misuse ofconfidential info.)Harm to individualSanctionsFinesCriminal chargesReputation“Flaw” ininterventionor toole.g., inadequate trainingOtherAudittrail ofon lineaccessPhysicalsecuritye.g. lockson medicalrecords roomVARIABLESWhich eventsNumber slicesSize of holesTimingRisk/$$Rolebasedaccess toapplicationsRiskTriggering Evente.g., curious employeePolicies and TrainingDiagram modified from James Reason’s“Accident Causation Model”
32 HIPAA Risk Management Approach Provides a baseline of data and information for future initiativesAllows us to build a rational, replicable model for risk managementAcknowledges that total elimination of risk may not be possible
33 Contributing to the Success of HIPAA at Kaiser Permanente HIPAA is in alignment with Kaiser Permanente valuesActive national and regional sponsorshipDedicated national and regional HIPAA TeamsMulti-disciplinary approachKP is a “learning” organizationOur 55-year history of providing high quality health care service to diverse populations