Components of a Comprehensive Legacy Data Management Strategy: Challenges and Strategic Considerations A White Paper May 2016 Impact Advisors LLC 400 E. Diehl Road Suite 190 Naperville IL 60563 1-­‐800-­‐680-­‐7570 Impact-­‐Advisors.com Executive Summary
Prior to go-live of a new enterprise EHR, there are many important decisions that need
to be made about legacy data. Which data will be electronically converted directly into
the new EHR? Which data will need to be manually abstracted into the system? How
will the organization address archiving historical data from the legacy EHR to meet state
and federal requirements?
To minimize the disruption caused by an EHR replacement and ensure the transition
does not jeopardize patient safety, Legacy Data Management strategies ideally need to
encompass three distinct areas: Electronic Data Conversion, Manual Data
Abstraction, and Legacy Data Archiving.
Introduction
A variety of factors are contributing to the
recent increase in EHR replacements.
Some providers are looking for next
generation capabilities needed for success
under new reimbursement models, while
some feel growing pressure to switch
EHRs amid concerns about the long-term
viability of their current vendor. Other
organizations are suddenly faced with
replacing their enterprise system after a
merger or acquisition, as the hospitals and
health systems involved look to align on a
single EHR.
Given the turbulence in the EHR vendor
market and continued mergers and
acquisitions (M&A) among health delivery
organizations, an increasing number of
hospitals and health systems will be faced
with an EHR replacement.
! There are roughly 1,420 hospitals
currently using a legacy EHR that
1
their vendor will no longer support.
! Total M&A activity in the healthcare
delivery services sector grew 22% in
2015. There were 102 deals
involving hospitals, and 88 deals
2
involving physician practices.
Regardless of the underlying reason,
replacing an enterprise EHR is an
inherently disruptive process.
New
functionality needs to be tested and implemented. Existing workflows must be
redesigned and deployed. In fact, from clinicians’ perspectives, it might feel as though
the only constant throughout the entire transition is the data migrating from the old
system to the new one.
Effective management of legacy data is critical to minimizing the disruption of an
EHR replacement and ensuring the transition does not jeopardize patient safety.
For example, important patient data such as allergies and medications need to be
brought into the new system – and in a structured format – so decision support alerts will
trigger properly. Recent lab and radiology results need to be accessible at the point of
care without clinicians having to toggle between multiple systems.
1
2
“Acute EMR Market Share: How Did My Vendor Fare in 2014?” KLAS, Aug 2015
“Health Care M&A Deal Volume and Value Exploded in 2015.” Irving Levin Associates, Jan 26, 2016
Components of Comprehensive Legacy Data Management Strategy
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The benefits of Legacy Data Management are not achieved via a simple “plug and play”
process, though. Success requires careful planning and execution across three distinct
areas: Electronic Data Conversion, Manual Data Abstraction and Legacy Data
Archiving.
Clearing Up Confusion
Although the terms Conversion, Abstraction and Archiving are often used
interchangeably in the healthcare industry, there are important differences. Electronic
data conversion and manual data abstraction focus more on continuity of patient care
and provider adoption of the new system, whereas legacy data archiving is driven by
complying with federal and state regulations and maximizing ROI. (See Figure 1 below.)
Figure 1. Three distinct components of effective Legacy Data Management
Electronic Data
Conversion
Manual Data Abstraction
Legacy Data Archiving
Automated migration of key
clinical / revenue cycle data
elements from the legacy
system to the new EHR.
Manual data entry of key
clinical / revenue cycle data
elements from the legacy
system into the new EHR.
Usually begins and ends prior
to go-live.
Usually begins prior to golive but some abstraction can
continue for weeks / months
after go-live.
Automated effort of storing
historical data from legacy
systems being retired,
primarily to meet state and
federal regulations. This is a
separate effort from
Conversion and Abstraction.
Often includes data elements
such as: MPI, encounters,
lab results, radiology
results, transcriptions
Often includes data elements
such as: appointments,
active orders, allergies,
medications, immunizations
and problem lists.
Components of Comprehensive Legacy Data Management Strategy
Strategy needs to be
developed before or during the
implementation phase.
Includes virtually all
historical data.
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Components of a Successful Legacy Data Management Strategy
There are unique challenges and strategic considerations associated with each
component of Legacy Data Management.
Electronic Data Conversion
In an EHR replacement, a certain amount of legacy data is usually electronically
converted directly into the new EHR. The primary reason is to maintain continuity of
care for patients during the transition. Although the electronic conversion process itself
is automated, the actual planning and execution can be extremely complex.
Electronic data conversion usually begins and
ends prior to go-live, to ensure as much patient
information as possible is available to clinicians
on go-live day.
Decisions such as which
specific data elements to include in the
electronic conversion plan can vary widely,
depending on how certain data elements are
structured and the clinical needs of the
organization. At a minimum, electronic data
conversion usually includes data with defined
standards, such as lab, radiology results and
report transcriptions.
Key Decision Points for Electronic
Data Conversions:
! What specific data elements will
be converted? What is that
data’s integrity in the legacy
system?
! What source system will be used
for each data element?
! How much legacy data will be
electronically converted into the
new EHR?
One of the biggest challenges with electronic
data conversion is managing the scope of the
effort. Some legacy data – especially non-HL7 data – will not be ideal for electronic
conversion simply due to lack of standards. Conversion efforts are often costly and
resource-intensive, so it is impractical from a budget perspective to include all legacy
data in the electronic conversion plan. These realties might be at odds with the
expectations of clinicians, who often want as much historical perspective as possible
available in the new EHR.
Strategic considerations for successful Electronic Data Conversion:
! Engage key stakeholders from the beginning. Conduct regular conversion
workgroup meetings to manage expectations that electronic data conversion will
require significant time and resources. Ensure broad participation from a wide
range of stakeholders including leadership from HIM, pharmacy, lab, and
radiology. Physicians should be included as well, to help the workgroup
understand data conversion needs in the context of patient care requirements.
! Carefully manage scope – and expectations. Conversations with clinicians
and department leaders about how much data needs to be electronically
converted might be difficult. However, converting more data means more
validation will be needed and more commitment from subject matter experts and
operational resources will be required. Consider compromises to ensure the
actual benefits are worth the cost and resources involved. For example, if
clinicians request 10 years of lab data, start by electronically converting the most
recent 2 years to see if that meets their needs.
Components of Comprehensive Legacy Data Management Strategy
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! Ensure thorough testing and validation. A comprehensive validation strategy
is critical. Identify dedicated application and departmental subject matter experts
– as well as physician and nursing staff – to validate converted data throughout
each phase of the conversion process and ensure there are no data integrity
issues.
! Engage legacy vendors early in the process. Getting cooperation from a
vendor that is being replaced can be understandably challenging. Be sure to
engage legacy vendors while they are still contracted for support to avoid
significant delays in the delivery of data extracts.
Manual Data Abstraction
For most organizations, it will not be feasible
to electronically convert all legacy data into
the new EHR – particularly if the data is not
standard. Some data will instead need to be
manually entered into the new system via
abstraction. In this process, specific data
elements that are not part of the electronic
conversion plan – but that providers still want
available in the system at go-live – are
manually collected and transcribed into
discrete fields in the new EHR.
The amount and type of information that
is abstracted depends on the scope and
extent of the organization’s electronic
data conversion efforts. Generally,
there is an inverse relationship
between data conversion and
abstraction – data that are
electronically converted do not need to
be abstracted. However, even with a
comprehensive electronic data
conversion plan, clinicians frequently
want to have additional data
manually abstracted to the new EHR.
Manual Data Abstraction often includes
important information needed to influence
medical decision-making at the point of care
or to trigger patient safety alerts, such as
active or standing orders, allergies, medications, immunizations, scheduled
appointments, problem lists, and patient histories. The scope of the planning process
may also involve identifying key paper-based clinical documents that will be scanned
into the new system.
Generally, manual data abstraction begins prior to go-live, with as much of the high
priority data identified by the organization entered into the system as early as possible.
Manual data abstraction frequently becomes a routine part of patient care well after golive as well. For example, practices might use manual data abstraction to “prep” the
charts for new patients or to add outside information to an existing patient’s record.
One of the biggest challenges can be defining a standard set of data that will be
abstracted organization-wide, while also ensuring that the abstraction plan addresses
specialties with unique needs outside the standard set of data. For example, oncology
clinics often need a manual abstraction of chemotherapy plans, while OB practices will
have unique needs based on the kind of pregnancy care they provide.
Managing expectations with stakeholders is also critical. Organizations need to carefully
strike a balance between clinicians who want their patients’ entire record and the cost
and time involved in manual chart abstraction.
Components of Comprehensive Legacy Data Management Strategy
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Strategic considerations for successful Manual Data Abstraction:
! Start planning efforts early in the process to determine scope and budget
requirements. What standard set data will be abstracted across the
organization, by whom, and when? Are there any special abstraction needs for
sub-specialties (e.g., oncology, OB, ophthalmology)? Which patients will have
their charts abstracted? Ensure that the budget is realistic given the abstraction
scope – and vice versa.
! Define oversight and management. Who will manage the abstractors? How
will they be trained? Will there be a quality review to ensure abstraction is
accurate?
! Have a plan for when the abstraction project is complete. How will ongoing
abstraction needs be handled at the practice level after the abstraction project
has ended? As new practices are acquired down the road, are there defined
policies and processes for how their data will be abstracted into the EHR?
Legacy Data Archiving
A significant amount of data from the legacy
system might never be moved into the new EHR
at all. For example, an organization might decide
that lab results older than 3 years do not have
enough clinical value to justify the cost of bringing
them into the new system. However, clinicians
and staff might still want access to legacy data
(especially in the months following go-live) – and
by law, health delivery organizations are required
to keep certain historical data, so it can be
provided to patients upon request.
A Legacy Data Archiving strategy
serves three purposes:
! Provides a common place to
store legacy data.
! Offers a lower cost alternative
to maintaining legacy systems.
! Provides a solution that could
enable clinicians to access
data from legacy clinical
systems.
Maintaining a fully functional enterprise EHR
solely to store historical patient information is
rarely practical. For most hospitals and health systems, it is a more cost-effective
strategy to extract historical data from the legacy system and store it in a stand-alone
archive solution.
The potential savings from effective Legacy Data Archiving can be significant. Although
there will be costs associated with extracting data from the legacy system and
implementing a data archiving solution, the substantial maintenance and support fees
from legacy EHR vendors are usually much greater.
Maximizing savings from legacy data archiving – while still complying with state and
federal rules – requires a full understanding of the provider organization’s unique needs.
How much data will have to be extracted from the legacy system? How long must the
data remain available? Who needs to access the data? Which applications qualify for
archiving? Will the archived data need to be modified or updated? Will the system be
hosted remotely by a third party or stored locally onsite?
Components of Comprehensive Legacy Data Management Strategy
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The answers to these questions can vary widely depending on the definition of the legal
medical record, state law, and retention policies. For example, the strategy for archiving
clinical information from a legacy EHR for clinician access will differ from a plan to
archive payroll or financial data. Location plays an important role, too. In some states,
certain clinical information must be retained for decades; others have less stringent
retention requirements – especially for financial and operational data. Research adds
another level of complexity.
Strategic considerations for successful Legacy Data Archiving:
! Account for your organization’s unique
archiving needs. State requirements can
vary widely, so understand what data your
organization is legally required to keep.
Concentrate on retiring clinical and
revenue cycle systems and identify which
roles need access to legacy data – and for
what purpose. Billing staff might need
access to legacy financial data for posting
payments
and
tracking
accounts
receivables
for
six
months
after
transitioning to the new system; the HIM
department might need access to legacy
clinical data for years in order to respond
to patient requests for information.
There are three distinct “states” in
which legacy data can be stored in
an archive system:
1. Active – quickly accessible
data that can be modified
2. Static – quickly accessible
“view only” data
3. Cold Storage – infrequently
accessed data retained for
legal purposes only
! Understand the effort involved to extract the data. Before data can be moved
to an archiving solution, it must be extracted from the legacy system – which can
be extremely challenging and unpredictable. Factors such as whether or not the
legacy system database is a proprietary format or open source make a significant
impact on project complexity and cost.
! Don’t delay legacy data archiving. Start developing a strategy for archiving in
conjunction with EHR implementation planning. Monthly maintenance and
support fees from a legacy EHR vendor can be substantial – and access to key
data must be maintained by law. More so, retaining internal legacy system
subject matter experts to provide crucial data management insight will be
challenging after the transition to the new EHR is complete.
The Bottom Line
Replacing an enterprise EHR is an inherently disruptive process that requires careful
planning and execution to ensure patient safety and continuity of care during the
transition. Many important decisions need to be made about the legacy system data.
Some legacy data will need to be electronically converted, while some will need to be
manually abstracted into the new system. Other legacy data will need to be extracted to
a stand-alone archiving solution in order to be compliant with state and federal
regulations while avoiding significant maintenance and support fees. To be successful,
EHR implementation strategies need to consider all three components of Legacy
Data Management, with careful attention to how the organization’s unique goals and
priorities influence key decision points.
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