Further Access to Patient Information Presents New Challenges and Opportunities for Hospital Fundraising Database Administrators

in Press Releases

By Bill Mountcastle and Dan Barney

The U.S. Department of Health and Human Services (HHS) Office of Civil Rights released the prepublication copy of the final rules on the Health Insurance Portability and Accountability Act (HIPAA) on January 17. With the release came much anticipated clarity regarding the use of health information for hospital fundraising. The recently announced modifications provide for greater patient awareness and control of their information by broadening opt-out information.

The most significant change of interest to healthcare philanthropy is hospital fundraising offices now have the opportunity to obtain new patient information in relation to:

  • Department of service
  • Treating physician
  • Outcome information

Previously the only permitted Protected Health Information (PHI) for fundraising purposes included patient demographic data, health insurance status, and dates of patient services. That’s why this HHS announcement promises to give hospital fundraising offices new opportunities and access to important data they can now utilize to advance their donor-prospecting, improve grateful patient relationships, expand physician participation in the process, and further donor stewardship.

What are the biggest opportunities and challenge to be faced with this arrival of new patient information for Hospital Fundraising Database Administrators (DBA)?

The donor and prospect database is arguably the most important fundraising and research tool any fundraising office has to advance philanthropy and increase fundraising revenue. This access to new information creates many opportunities for hospital fundraising offices – some of which may have been envisioned already. The stakeholders who will ultimately utilize this information have dreamed of the day when they could speak to prospects about the value the cardiac care unit brought to their lives. They have already seen in their mind’s eye vast targeted campaigns designed to connect the donor to that new MRI machine, wing, program, initiative.

The key element in managing any successful database is to ensure that the integrity of the system is maintained in a consistent fashion. We must be cautious to give the new HIPAA allowance the due consideration it deserves, but we must also do so expeditiously.  Recognize and appreciate this is not episodic; this new set of data is organic. It will live and breathe and your fundraisers will thrive if their work is properly facilitated with accurate, timely and meaningful information.

What should Hospital Fundraising Database Administrators be doing right now?

HIPAA modifications provide a clear path to what kind of data hospital fundraising offices can use to customize outreach.  For optimal effectiveness, here are several practical tips we suggest:

1. Start immediately

The new modifications went into effect on March 26, 2013 and have a compliance date of September 23, 2013.  Begin right away managing the new information on donors and prospects to take full advantage of your database.

2. Involve stakeholders

Knowing how information will be available, in what format and when is critical. The patient information services manager is a key ally. What can you do to make their job easier such that the increasingly frequent requests for data will be met with minimal resistance?  As mentioned, the fundraisers have already envisioned some of what they could do with this information, but we need to respect that we cannot possibility anticipate the full breadth and depth of their intentions. Understanding use cases is critical.  Having the conversation between database manager and relationship manager is important.  Further, once the Board considers the possibilities, the options may seem endless.  With this in mind, a team of internal stakeholders should be assembled to ensure that the data is structured in such a way as to be flexible and scalable.  We cannot anticipate all needs out of gate, but recognizing there are more requests to come can position DBAs to respond in effective ways.

3. Consider Form and Function

Broadly speaking, the concerns are the same as any new set of data.

• Does this require a new “part” or an expanded use of an existing aspect of the database?

• What are the component parts and how are they related (Category, Code, Date, Comment, Physician, Outcome)?

• Will ancillary or subjective information be include, i.e., was the process or procedure life-changing and/or life-affirming?

• On what table will it be stored?

• In what screen can users see it?

• How are we going to acquire it?

• How will the initial transfer take place?

• How will the information be maintained – by whom, when and in what interval?

• How will the data need to be extracted for use?

• What is the anticipated depth of analysis? Linear reports? Cross-tabs? Pivots? Summaries? Groups? Trends? Correlations?

• Who will have access to it?

• How will it be secured?

• Is it a running list or a singular characteristic (a movie or a picture)?

The answers to some of this will be mandated by the mechanics of the database or the skills of the team.  Truth be told, it is not unlikely these will be significant factors.  As such, priority ranking should be given to each of these factors and considered in terms of cost/benefit.

4. Designate ownership

One person within the hospital fundraising office should be responsible for creating reports and programming new fields.  Keep a tight rein on the ability of others to add records.  This will streamline the process and ensure the new data entry is not compromised.  Singularity (with some functional redundancy to avoid process loss during transition and turnover) is most important during the initial integration of this information into the organization’s data culture.

5. Track the sources of information

Keep track of the source of the information: data pull, patient self-disclosure, physician shared info, etc. Code this into your database for later reference. Tracking this information over time will help identify methods of follow-up. It can also be used to analyze the effectiveness of translating information into interests, donations and broader affinities, as well as determining data validity and longevity.

6. Validate existing data

Confirm what you know about your current grateful patient donors. Your current donors are the first step in prospecting new donations. Most fundraising offices think they already know who their current donors are and why they are connected to their hospital and physicians. We are sure you will find a few surprises when you do an analysis of your existing donor base. There may be physician relationships you never knew existed – both positive and negative. This validation is important to perform. Then, once you know who your current grateful patient donors are, you can use the profile of your best donors to better define and acquire new donor prospects.

7. Establish a common index

Pushing information into one system from another is painful enough. Now, consider that the operational mandate is to do so quarterly, monthly or weekly. Every system has a unique identifier – patient ID, donor ID, index value. Determine which system will be the generator of this common field and ensure that the other system can receive, store, maintain and protect the values resident in this field. And, avoid using something sensitive – such as a Social Security number. There are utilities available which can intelligently act as a common clearinghouse of all things database.

8. The one and final truth

Determine what is the one and final truth. Is the care-side sourced data or the relationship-side sourced data? Is it based on date of information acquisition? Is there a methodology to make this determination and share it in both directions? Is a two-way sharing environment necessary? Certainly, anyone can pick up the telephone and speak to the patient to see if they live in apartment 1A or if they moved from Main Street to Maple Lane. At what point does this make sense? “Touches” for the sake of administrative record keeping have the potential to damage relationships. There is also the added sensitivity of solicitation tracks and cultivation steps. If a prospect is “in play” with a major gift officer, that relationship needs to be considered before making a poor data management decision which could adversely affect the success of the pending ask.

9. Stop redundancy before it begins

Duplicate constituent records are a part any database. Presumably there is a process in place to monitor and address these occurrences. Synchronizing with a system external to the fundraising database will likely increase the risk of creating duplicates when matches are not found using the aforementioned indexing system. This seems pretty straightforward and is a part of our normal data management processes.

What isn’t necessarily a part of our normal operations is an environment where we could import redundant patient-related information. Do we only import new patient information? Or, wait until the care has been completed? Neither is ideal. The first is void of results and the later may take years. A system must be established to address this issue. Data-specific import parameters could be employed, or source records can be flagged as having been successfully transferred. Whatever method is used, however, we must be able to track progress and – in the case of data/process corruption – undo it.

10. Establish a Deletion Rule

Clearly define a “deletion rule” and deletion procedures.  Determining the requirements which must be met in order for an item of new data to be deleted is essential.  Naturally, a process must also be agreed upon that safeguards the totality of the database.  When will the delete process take place?  Who will do it?  Is a full system-wide backup necessary?  Perhaps a targeted archive of patient information can be run instead to protect against data lose.  Unnecessary or inadvertent deletions can disrupt the data.

Perhaps a softer interpretation of the deletion rule is management of the patient’s right to opt-out of communications.  Keeping the constituent record on the system becomes increasingly critical when they opt-out, so new records are not inadvertently created during the synchronization and subsequent creation of non-matching records.  This opt-out must be managed on the system along with any nuances associated with; this is commonly handled via a suppression code, although it may be important to track the magnitude of the request within the context of HIPAA.

In addition to the database strategy matters, are there other issues hospital fundraising database administrators should be attending to?

The hospital fundraising database administrator should be a key promoter for the expanded patient information understanding and usage and help excite gift officers about the impending benefits.  Usually the best gift officers focus on detailed qualifying. The more information you have about a grateful patient prospect, the more excited your gift officers will be about getting out to the prospects to build relationships with them.  Encouragement and enthusiasm will have a significant impact on gift officers and will cause them to want to engage with your database and data management team further.

This article is meant to serve as an educational resource for database professionals and in no way constitutes legal advice. If you require legal advice, please consult a qualified attorney.

About the Authors:

Dan Barney is a relationship management system expert and a leader in the philanthropy information industry. He founded Barney & Associates Consulting Services and specializes in assisting organizations integrate technologies to build better relationships and increase donations.

Bill Mountcastle is an expert on hospital fundraising and health-related philanthropy. He is the founder of the specialized health-related fundraising consulting firm, Health Philanthropy Services Group and a noted expert in healthcare capital campaign planning and grateful patient and physician engagement for fundraising results.

For more information, contact Dan Barney at dan@barneyacs.com or Bill Mountcastle at wmountcastle@health-philanthropy.com.

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