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DOI: 10.4338/ACI-2016-07-RA-0120
Screening Consolidated Clinical Document Architecture (CCDA) Documents for Sensitive Data Using a Rule-Based Decision Support System
Correspondence to:
Publication History
Received:
20 July 2016
Accepted:
04 February 2016
Publication Date:
20 December 2017 (online)
Summary
Background: The Centers for Medicare & Medicaid Services’ Stage 2 final rule requires that eligible hospitals provide a visit summary electronically at transitions of care in order to qualify for “meaningful use” incentive payments. However, Massachusetts state law and Federal law prohibit the transmission of documents containing “sensitive” data unless there is a new patient consent for each transmission.
Objectives: To describe the implementation and evaluation of a rule-based decision support system used to screen transition of care documents for sensitive data.
Methods: We implemented a rule-based document screening system to identify transition of care documents that might contain sensitive data. The transmission of detected documents is withheld until a new patient consent is obtained. The documents that were flagged as containing sensitive data were reviewed in two different time periods to verify that the decision support system was not missing documents or withholding more documents than necessary.
Results: The rule-based screening system has been in regular production use for the past 18 months. During the first evaluation period, 3% of 5,841 documents were identified as containing sensitive data (true-positive rate of 44%). After additional enhancements to the rules, the system was evaluated a second time and 4.5% of 6,935 documents were identified as containing sensitive data (true-positive rate of 98.4%).
Conclusion: The analysis of the system demonstrates that production rules can be used to automatically screen the content of transition of care documents for sensitive data. The utilization of the rule-based decision support system enabled our hospitals to achieve meaningful use and, at the same time, remain compliant with state and federal laws.
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Keywords
Clinical decision support - meaningful use - health information exchange - continuity of patient care
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Conflicts of interest
HSG is on the Scientific Advisory Committee for Clearsense in Jacksonville, FL and is a consultant for PSMI in Point Richmond, CA. The other authors declare that they have no conflicts of interest in the research.
* The study was conducted while the primary author was a Principal Medical Informatician at Brigham and Women’s Hospital
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References
- 1 Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology. 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology. Federal Register 2012: 77(171); 45 CFR Part 170.
- 2 Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 2. Federal Register 2012: 77(171); 42 CFR Parts 412, 413, and 495.
- 3 Health Level Seven International.. HL7 Implementation Guide for CDA® Release 2: IHE Health Story Consolidation. DSTU Release 1.1 (US Realm) Draft Standard for Trial Use July 2012.
- 4 Massachusetts Laws: HIV test; informed consent; disclosure of results or identity of subject of test. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXVI/Chapter111/Section70F. Last accessed on June 1st, 2016.
- 5 Electronic Code of Federal Regulations [Internet]. Available from: http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5;node=42%3A1.0.1.1.2. Last accessed on June 1st, 2016.
- 6 Cohen GR, Adler-Milstein J. Meaningful use care coordination criteria: Perceived barriers and benefits among primary care providers. J Am Med Inform Assoc 2016; 23 e1 e146-e151.
- 7 Rothstein MA, Talbot MK. Compelled Disclosure of Health Information. Protecting against the Greatest Potential Threat to Privacy. JAMA 2006; 295 (Suppl. 24) 2882-2885.
- 8 Rothstein MA. The Hippocratic Bargain and health Information Technology. J Law Med Ethics 2010; 38 (Suppl. 01) 7-13.
- 9 Sittig DF, Singh H. Rights and responsibilities of users of electronic health records. CMAJ 2013; 184 (Suppl. 13) 1479-1483.
- 10 Health Level Seven International.. HL7 Clinical Document Architecture. Release 2.0. Normative Edition – May, 2005.
- 11 Health Level Seven International.. HL7 Implementation Guide: CDA Release 2 – Continuity of Care Document (CCD) April 2007.
- 12 Healthcare Information Technology Standards Panel. HITSP Summary Documents Using HL7 Continuity of Care Document (CCD) Component HITSP/C32. 2009 July.
- 13 The Massachusetts Health Information Highway. http://www.mass.gov/eohhs/gov/commissions-and-initiatives/masshiway/. Last accessed on June 1st, 2016.
- 14 Goldberg HS, Paterno MD, Rocha BH, Schaeffer M, Wright A, Erickson JL, Middleton B. A highly scalable, interoperable clinical decision support service. JAMIA 2014; 21 e1 e55-e62.
- 15 SNOMED CT. Available from: http://ihtsdo.org/snomed-ct. Last accessed on June 1st, 2016.
- 16 RxNorm.. Available from: http://www.nlm.nih.gov/research/umls/rxnorm. Last accessed on June 1st, 2016.
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- 20 Confidentiality of Substance Use Disorder Patient Records. Available from: https://www.regulations.gov/#!documentDetail;D=HHS-OS-2016-0005-0001. Last accessed on June 1st, 2016.
Correspondence to:
-
References
- 1 Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology. 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology. Federal Register 2012: 77(171); 45 CFR Part 170.
- 2 Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 2. Federal Register 2012: 77(171); 42 CFR Parts 412, 413, and 495.
- 3 Health Level Seven International.. HL7 Implementation Guide for CDA® Release 2: IHE Health Story Consolidation. DSTU Release 1.1 (US Realm) Draft Standard for Trial Use July 2012.
- 4 Massachusetts Laws: HIV test; informed consent; disclosure of results or identity of subject of test. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXVI/Chapter111/Section70F. Last accessed on June 1st, 2016.
- 5 Electronic Code of Federal Regulations [Internet]. Available from: http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5;node=42%3A1.0.1.1.2. Last accessed on June 1st, 2016.
- 6 Cohen GR, Adler-Milstein J. Meaningful use care coordination criteria: Perceived barriers and benefits among primary care providers. J Am Med Inform Assoc 2016; 23 e1 e146-e151.
- 7 Rothstein MA, Talbot MK. Compelled Disclosure of Health Information. Protecting against the Greatest Potential Threat to Privacy. JAMA 2006; 295 (Suppl. 24) 2882-2885.
- 8 Rothstein MA. The Hippocratic Bargain and health Information Technology. J Law Med Ethics 2010; 38 (Suppl. 01) 7-13.
- 9 Sittig DF, Singh H. Rights and responsibilities of users of electronic health records. CMAJ 2013; 184 (Suppl. 13) 1479-1483.
- 10 Health Level Seven International.. HL7 Clinical Document Architecture. Release 2.0. Normative Edition – May, 2005.
- 11 Health Level Seven International.. HL7 Implementation Guide: CDA Release 2 – Continuity of Care Document (CCD) April 2007.
- 12 Healthcare Information Technology Standards Panel. HITSP Summary Documents Using HL7 Continuity of Care Document (CCD) Component HITSP/C32. 2009 July.
- 13 The Massachusetts Health Information Highway. http://www.mass.gov/eohhs/gov/commissions-and-initiatives/masshiway/. Last accessed on June 1st, 2016.
- 14 Goldberg HS, Paterno MD, Rocha BH, Schaeffer M, Wright A, Erickson JL, Middleton B. A highly scalable, interoperable clinical decision support service. JAMIA 2014; 21 e1 e55-e62.
- 15 SNOMED CT. Available from: http://ihtsdo.org/snomed-ct. Last accessed on June 1st, 2016.
- 16 RxNorm.. Available from: http://www.nlm.nih.gov/research/umls/rxnorm. Last accessed on June 1st, 2016.
- 17 FDB Enhanced Therapeutic Classification System. Available from: http://www.fdbhealth.com/fdbmedknowledge-foundations. Last accessed on June 1st, 2016.
- 18 Meystre SM, Friedlin FJ, South BR, Shen S, Samore MH. Automatic de-identification of textual documents in the electronic health record: a review of recent research. Available from: http://www.biomedcentral.com/1471-2288/10/70. Last accessed on November 7th, 2016.
- 19 Stubbs A, Kotfila C, Uzuner O. Automated systems for the de-identification of longitudinal clinical narratives: Overview of 2014 i2b2/UTHealth shared task Track 1. Journal of Biomedical Informatics 2015; 58: S11-S19.
- 20 Confidentiality of Substance Use Disorder Patient Records. Available from: https://www.regulations.gov/#!documentDetail;D=HHS-OS-2016-0005-0001. Last accessed on June 1st, 2016.