Apply the lessons of Y2K to patient confidentiality
Apply the lessons of Y2K to patient confidentiality
Now that the Y2K challenge has come and gone without any major disruptions, hospitals are facing another operational challenge of equal magnitude — developing a plan to deal with the sweeping mandates of the Health Insurance Portability and Accountability Act (HIPAA) of 1996. Alton Brantley, vice president and chief information officer for MedStar Health, a regional integrated system based in Baltimore, says hospitals would be wise to apply the lessons of Y2K to HIPAA.
Brantley reports that over a five-year period, MedStar developed strategies, plans, and approaches for dealing with the Y2K issue. Having coped with Y2K successfully, he advises hospitals to apply the following lessons to the coming HIPAA challenge:
Be neither first nor last. Brantley warns that hospitals that aim to be the first to become HIPAA compliant either will do too much or too little, and will sometimes wander into blind alleys. In the case of Y2K, those who started last benefited from the experience of others, but not without significant stress. Meanwhile, those who tried to lead the pack sometimes expended wasted energy, he says.
The "hard stuff" is not out-tasked. Brantley says that in preparing for Y2K, consultants often claimed they could effectively manage the most difficult tasks. But as those consultants began to realize they had legal liability for the work they performed, they began to temper those claims. "Ultimately, consultants ended up doing mostly well-defined, well-focused activities," he reports.
Break the project into multiple independent subprojects. Brantley warns that providers should guard against attempting to construct a single, enormous multimillion dollar, multiyear, multiorganizational, and multicomponent project. Y2K proved that it is too difficult to operate, monitor, and manage such an effort, he says.
It’s not over until it’s over. According to Brantley, MedStar is still working on Y2K, and that effort will not end until next year. "New regulations are going to continue to come out, and new issues are going to continue to surface. We are going to be at this for a considerable period of time." Nevertheless, Brantley says Y2K has demonstrated that projects with a fixed scope and timeline can be completed on time and on budget.
If you do it right, it looks easy. According to Brantley, most of MedStar’s staff now believe that Y2K was not an enormous effort because it was accomplished successfully. "Only those of us who worked in the trenches and behind the lines down in the boiler rooms making Y2K work know the endless energy we expended on it," he remarks.
Consultants and lawyers saw opportunities that did not materialize. Brantley says he typically received three to five phone calls per day from vendors, consultants, and legal firms offering to help solve the Y2K problem. "I listened to all of them, but I also took it all with a grain of salt," he says. "There was a very aggressive approach, but we realized that it didn’t pan out."
Best practices are moving targets. Brantley says the initial work plan for Y2K called for replacing entire systems. "But most of us found that we could not afford to do that," he reports. "We could not afford the time, and our people could not tolerate the pain." Instead of replacing entire systems, MedStar successfully managed the Y2K project primarily with stock replacements.
Vendors were late to the party, and they were all dressed wrong. According to Brantley, many vendors saw Y2K as major marketing opportunity. But he says Y2K presented a problem with a fixed goal and a fixed timeline. "You can’t always afford the luxury items, so you end up having to buy piecemeal approaches."
According to Brantley, vendors often "over-anticipated" the Y2K opportunity. "We were dealing with patches and fixes’ and the blood and guts’ of information technology right up until the last minute," he reports. "We were literally getting mandatory patches installed within the last two to three weeks."
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