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Transparency: What It Means in Information Governance

By Lydia Washington, RHIA; Lesley Kadlec, MA, RHIA; and Barb Glondys, RHIA

AHIMA has developed the Information Governance Principles for Healthcare (IGPHC)—adapted from ARMA International’s Generally Accepted Recordkeeping Principles—to guide health care organizations in managing all types of information on an enterprisewide level. The IGPHC, developed with input from more than 80 subject matter experts, provide a foundation for health care organizations seeking to realize full value from all different types of information the data collect, create, use, and share—by developing the capabilities afforded by an information governance program. The program aims to give organizations a framework for decision-making regarding information management throughout its lifecycle while also describing who is accountable for what when it comes to managing information.

An information governance program in health care should be based on the following eight principles: accountability, transparency, integrity, protection, compliance, availability, retention, and disposition. These attributes are familiar to many HIM professionals. However, probably among the least understood is the principle of transparency.

Transparency calls for an organization’s processes, activities, and information governance program to be “documented in an open and verifiable manner.” It states that an information governance program must do the following:

• document the principles and processes that govern the program;
• accurately and completely record the activities undertaken to implement the program;
• be written or recorded in a manner that clearly sets forth the information recorded; and
• be readily available to legitimately interested parties.

Documentation of the organizationwide processes for governing and managing information should be available to health care consumers, workforce, and other appropriate parties based on need-to-know/right-to-know policies. For instance, although HIPAA regulations stipulate a patient’s rights to access his or her personal health information, patients are not always aware of these rights, and barriers are still encountered when trying to legitimately obtain information. However, to demonstrate transparency, patients should be able to readily access their own health records to help them make decisions about their own care.

Information also should be made available to consumers that describes the organization’s performance related to patient safety and customer satisfaction scores. This can help health care consumers determine which health plan to select, the best hospital to use for the proposed treatment, which care provider can best meet their needs, or what alternatives may be available to suit individual requirements or preferences. Policies on the use of patient information for purposes such as fundraising or research should be available for review. Privacy practices should be posted and disseminated. There must be information on hand that describes how a patient may report a concern should any problems or questions arise, and staff should be available to provide explanations if needed.

The IGPHC principle of transparency ensures that the policies and procedures regarding access to health records are documented and available to consumers.

Transparency could be demonstrated as follows:

• ensuring accountability and clarity on how records and information are created, collected, maintained, used, and disclosed;
• promoting consumer engagement, ensuring access to and the appropriate use of health information;
• implementing practices that foster transparency of health information and HIM practices;
• ensuring HIM processes and practices recognize the balance between protecting confidential information and its use; and
• training and educating the workforce on transparency.

In addition to the health care providers and staff, a number of regulatory agencies, auditors, payers, and even health care consumers may have a legitimate interest in understanding the processes related to information management and the efforts that are being undertaken to implement and sustain them.

The expectation that organizations define the uses of data and information is a departure from the ARMA Generally Accepted Recordkeeping Principles and are a good example of how the principle of transparency was adapted for health care by AHIMA. Principles for other industries do not necessarily have the ethical obligation or business need to ensure that consumers and stakeholders understand all the ways in which their personal and deidentified data are used.

The underlying building blocks of the information governance program and its outcomes should be available and understandable to those interested parties who have a legitimate reason to access the information.

For a detailed look at all eight Information Governance Principles for Healthcare, as well as other information governance resources, visit www.ahima.org/topics/infogovernance.

— Lydia Washington, RHIA, is senior director of HIM practice excellence at AHIMA.

— Lesley Kadlec, MA, RHIA, is director of HIM practice excellence at AHIMA.

— Barb Glondys, RHIA, is director of HIM practice excellence at AHIMA.