Ethics Memo Sanderson
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GENERAL HOSPITAL
INTEROFFICE MEMORANDUM
TO:
APRIL HOWARD, CEO; MORGAN EDWARDS CMO
FROM:
MAY SANDERSON, HIM DIRECTOR
SUBJECT:
DEPLOYMENT OF EHR DATE:
JANUARY 23, 2024
CC:
JOSEPH CARDWELL, VP HIM
I am sending out this memo to address an issue with the new EHR system that was recently purchased. There has been some pressure to deploy this new system quickly, however, upon review by the HIM department there were several issues found. As a medical facility, we are required to comply with applicable federal privacy and security standards such as the Health Insurance Portability and Accountability Act (HIPAA). Failure to comply poses legal, ethical and liability risks for the hospital, the patients, and the staff. During the testing period it was found that the EHR system has several flaws that compromise the privacy and security of all patient information. For example, the EHR system does not have encryption on any of the protected health information (PHI). There is no safeguard
against unauthorized access. There is not a program that will track who is accessing any PHI. The network is unstable and will close without warning. The stakeholders involved in these issues involves are: The hospital who is responsible for providing safe and effective care to the patients, complying with the federal privacy and security standards, and maintaining its financial and operational viability. Patients who are
stakeholders have the right to have their PHI protected from unauthorized use and disclosure, and to access and control their own health information. The staff also have the duty to respect and safeguard the PHI of the patients, and to use the EHR system appropriately and ethically. Evaluating the options available there are several we could take.
(a)
Proceed with launching the EHR program as is, despite the issues.
(b) Delay a couple weeks to launch the EHR program until the privacy and security issues are resolved. Working closely with the programmers to ensure compliance with
all laws and regulations.
(c)
Reject the EHR program. Start looking at other companies that can provide a program
that is certified and compliant with security standards and privacy laws. Out of those options I recommend (b). Delaying the launch will be the most beneficial for
the hospital. The first step is to review the contract that we have with the programming company.
There should be a way to ensure their compliance. A clear understanding of the principles and guidelines within the AHIMA code of ethics. Also, the hospital should enlist a multidisciplinary and collaborative team for the EHR system implementation goes with this delay. This issue should involve the HIM professionals, the CIO, the CMS, the staff, the planning, testing, training, and evaluation processes. It is important that the hospital have a robust and ongoing monitoring and auditing system for the EHR system, and ensure the privacy and security of the PHI, the accuracy and completeness of the documentation, and the compliance with the federal privacy and security standards. There needs to be a continuous and proactive improvement approach for the new EHR
2
system, with feedback and suggestions from the staff and the patients and implement best practices and innovations to enhance the quality and efficiency of care. We can discuss any other changes or additions we need to address at the meeting in one week. Then we can discuss the options and decide on the necessary changes that need to be made. 3
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