Securing legal counsel is an important preparatory step in creating a new population health business unit for an internal employee or member-based accountability program. Step 4 in this 10-step guide will help you begin conversations with legal and compliance departments regarding personal health information use in a PHM program.
Top 10 Steps to Population Health Management (PHM): Data Sharing Intricacies Require Legal Oversight (Step 4)
In the article “Top 10 Steps to Take Before Launching a Population Health Management Program” we shared that legal counsel is an important preparatory step in creating a new population health business unit for an internal employee or member-based accountability program. To target care for a population, the more health information available for the provider, the more appropriate care (right amount of care, right time, right engagement route) can be delivered.
Historically, the EHR has been the primary data source for providers, but with a push to value-based care, the additional data from outside of the EHR found in claims helps drive evidence-based care. Not only do medical and pharmacy claims reveal whether the person is taking appropriate prescriptions or receives age/gender recommended preventative services, but also a lack of claims for a given eligibility list presents more opportunities to target individuals for care.
When obtaining health plan data, remember that sharing protected health information (PHI) must be compliant with HIPAA, HITECH, state privacy laws, Anti-trust and other laws and regulations. This article in no way substitutes for legal guidance but instead is meant to explore uses of health plan data and arrangements the provider may desire that will explain the importance of legal review.