Info Blocking means inpatient and outpatient progress notes released immediately to patients, along with lab results, CT/ MRI/ PET scan results, pathology results. Immediately. Ready?
Click here to view my 1-page White Paper on why and the 4 following pages on how/what.
What Is Changing?
The 21st Century Cures Act has an Information Blocking regulation that addresses the concern that some health systems or facilities delay or block patient information from other treating health systems, or from the patient. Of immediate concern to this CMIO is the impact this rule has on our health system, to wit:
We are an Open Notes organization, since 2016, releasing outpatient provider progress notes to patients immediately upon signature. This applies to ED and urgent care notes, also to hospital discharge summaries. We’re happy with this, and proud to lead the charge in Colorado for information transparency. Same with immediate release of the vast majority of lab test results.
However, we still delay some results 4 days, 7 days or 14 days depending on category (see above). The new Info Blocking regulation stipulates that systematic delays like this will violate the Info Blocking rule, and that the potential penalty for such delay is $1 million.
This is great news for patients and patient advocates; they have long stated the maxim: “Nothing about me without me.” I love this idealism. Practically? We have struggled with how to make this happen. Now the feds have conveniently stepped in with a mandate. This makes the conversation easier.
Our Big Struggles Ahead
- Teach our inpatient providers to write notes that are ready for patients to read each day they’re in the hospital.
- Teach all our providers how to anticipate patient concerns and the range of possible results coming from pathology (biopsies and PAP smears and other results that may show cancer or severe disease). Same with complex imaging like CT scans, MRI’s, PET scans, mammograms. Same with lab results that may show genetic variants, like Down’s syndrome.
How I made this
Beyond the specifics of the Info Blocking rule, this also illustrates the value of Form Factor and Communication Strategy. My mentor always taught me: if you write a white paper executive summary, every additional page beyond one side of one page cuts your readership in half.
So, for my white paper, I have written a one-page summary of why this is important and what action is needed. For those who just need “at a glance,” the color grid in the center tells the story of exactly what is changing. And because data alone does not change minds, the call-out box at the bottom includes a few quotes from selected leaders, telling a brief story.
Finally, if you get to the end of the page and are interested in doing something, I have 4 more pages of how and what to take you to the next level.
This, combined with a road show, where I am going to every major physician leadership meeting, is how I’m getting the word out. There is, of course, much more work to do at the individual provider and manager and service and clinic level, but I’m trying to give everyone a running start. There’s not much time left.
In case you’re still working through this, here are some documents (some updated) that we used. Some are actually named Information sharing instead of blocking, just a more hopeful attitude. I hope these might help you.
Information Blocking Exec Overview (Oct 2020)
Information Blocking Exceptions at UCHealth (updated 3/14/2021)
Even better, our colleagues at OpenNotes.org are doing some terrific office hours with experts online where you can hear the real-life experience of leaders already doing this work in various fields, successfully.
CMIO’s take? We all have hard work ahead. This is a federal mandate, so 4,000 hospitals, countless health systems and clinics will be facing this as well. The link to my white paper here (and above) is my contribution. I hope this helps you get to the right place with this regulation AND with doing the right thing for our patients.
[This piece was originally published on The Undiscovered Country, a blog written by CT Lin, MD, CMIO at UCHealth and professor at University of Colorado School of Medicine. To follow him on Twitter, click here.]