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It's important for healthcare organizations to establish how information is processed within a system - that is, how it is transmitted, stored and so forth and clearly communicate to users how the system should operate. Healthcare organizations in particular should have a low tolerance for abnormal system behavior. They should provide users with a way to quickly report problems whenever systems don't operate as expected. Spear calls this "preventative care for business processes," adding: "This puts a lot of pressure on IT to respond to a lot of little things, but by responding to a lot of little things, you avoid the big things. You end up with a lot of aberration, but you're not dealing with a catastrophe."

In addition, he says, one employee should be designated as "owner" for each system; that person can help report abnormalities or problems as they arise.

Just as important as being sensitive to unexpected system behavior is the need recognize when processes aren't doing anything to help achieve HIPAA compliance or meet other critical goals.

"Healthcare organizations need the ability to look at a process, recognize that they didn't anticipate a variable and have the flexibility to make a change to the process," says Christine Leyden, chief accreditation officer of the health care accreditation and education organization URAC (previously called the "Utilization Review Accreditation Commission," the organization is now known simply by its acronym). And there are plenty of variables, given the extent of human involvement in a variety of roles: resident healthcare personnel, patients and family members, representatives from other healthcare organizations who may need access to PHI.

"The biggest challenge is to think beyond the inner walls of where the care is provided and to think about how that information is going out to the community," Leyden says. All key stakeholders involved in information processing should understand the information-sharing guidelines so that they're better equipped to make informed decisions. And, Leyden reiterates, they need the flexibility and empowerment to determine whether they need to make changes to the process.


Recognizing the need to make changes isn't always enough. A feedback system must fit naturally within the users' workflow. Spear recalls the case of a healthcare organization that asked personnel to log inconveniences that could impede patient safety. For example, if a nurse had difficulty finding medication during a slow time of day, then chances are the task could be even more difficult during busy periods or when the medicine was needed in a hurry. However, the process for reporting such a problem took 10-15 minutes. "To ask a nurse to spend 10 minutes logging an inconvenience actually magnifies that inconvenience," Spear notes.


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