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Achieving Legacy System Retirement and Data Consolidation

Session 184, February 13, 2019

Lisa Stump, SVP and CIO, Yale New Haven Health

Bill Hudson, ACIO and VP of IT Operations, John Muir Health

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Lisa Stump

Has no real or apparent conflicts of interest to report.

Bill Hudson

Has no real or apparent conflicts of interest to report.

Conflict of Interest

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• Learning objectives

• Background

• Deciding on an archive strategy

• The path to success

• Principles of archiving: what to archive

• Data governance: structure for a plan

• Engaging Operations: foundation for a plan

• Recommendations and lessons learned

Agenda

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• Illustrate the advantages and challenges of consolidating legacy

data in a central archive

• Illustrate how to build the business case for legacy system

retirement and consolidation of legacy data into an active archive

• Define the organizational roles to involve in the process to achieve

successful adoption of a solution

• Define the critical principles of legacy data consolidation and

legacy system decommissioning and discuss how to apply them

• Show the lessons learned from a legacy data consolidation and

retirement program

Learning Objectives

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Drivers for Enterprise Legacy Retirement & Archiving

Healthcare Market Transformations

• Federal mandates

ICD-10

Meaningful Use

• Acquisitions and mergers

• Budgetary pressure to consolidate applications

• Data-driven healthcare

• Streamline, Simplify, Save

Legacy Application

Replacement &

Retirement

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Drivers for Enterprise Legacy Retirement & Archiving

• Compliance: 7 – 28 years

• Continued need for access to clinical data

• Revenue cycle: billing continues

• Audits: RAC, Medicare, Medicaid, commercial carriers

• Research

• Cost of maintaining legacy applications

• Data spread over disparate systemsLegacy Retirement

Active Archiving

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Enterprise Legacy Landscape at JMH

• Reviewed all 500 of our applications

• Identified 162 candidates

• Worked with key staff to identify data elements to retain and applications to decommission

• We focused for 3 – 3 ½ months on the “Legacy Application Decommissioning Assessment”

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Enterprise Legacy Landscape at YNHHS

• Prioritized legacy clinical and revenue cycle applications post-EMR consolidation

• Timing based on data size and legacy maintenance cost

• Worked with key staff to identify data elements to retain

• Emphasized clinical benefit of extending longitudinal record back in time

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Why use an enterprise, centralized, active archive?

Reduce data footprint through selective archiving

Create single point of access/retrieval

Maintain data usability

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Active vs. Static Archive

Will the data be accessed often?

Examples: HIM staff responding to ROI requests;

Billers accessing for billing functions;

HR staff responding to audits;

Clinicians accessing clinical records

Is seamless access via other applications important or beneficial?

Example: Access lab records held in the archive via the new EMR

If YesIf Yes ActiveActive

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Use Cases & Secondary Use

• Archive used for day-to-day functions

Release of Information

Revenue cycle, billing

Patient care

HR functions

• Archive used to mine data for special requests, such as CDC study requests

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Archiving Options Considered

• Expensive and difficult to manageRetain the legacy

system

• Non-compliant, high risk, and expensiveDecommission the legacy system and

destroy data

• Print to paper, archive to PDFBackup raw data

• Static

• ActiveEnterprise archive with end user GUI

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Why We Used an Enterprise ActiveArchive

• Not a “typical” archive

• Includes workflow functionality

Billing accounts for active A/R (2+ years after last DOS)

Release of Information

Interoperability

• Allows for real-time end user access

• Reporting

• Discrete data elements and document images

• Secondary use of data

• Consistent workflow

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The Path to Success

• Building a business case

• Establishing data governance

• Engaging stakeholders

• Overcoming archiving challenges

• Project planning

• Choosing the systems to retire

• Choosing the data to archive

• Moving quickly to ensure adoption

• Communicate, Communicate, Communicate

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Critical Success Factors

• Achieve leadership support for sun-setting all applications

Involve department leadership to avoid resistance to decommissioning

• Successful data migration into active archive completed before decommissioning – key dependency

• Teamwork

Utilize efforts among many departments instead of maintaining dedicated resources

• Technology

Active archive, ability to handle required workflow

• Effective communications

Scope is broad and timeline is long

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Building a Business CaseUse Cases

Revenue Cycle Clinical

Data

Retention

Guidelines

Reimbursement/payment

history records: 10 years

Master patient index/visit

history: permanently

Adult records: 10 years

from most recent visit

Minor records: 28 years

Use Cases

Billing accounts; payment

posting

Financial reporting

Interface with billing

systems

Insurance & cash

collections

RAC audit responses

Physicians need to

reference for point of care

clinical history

HIM staff ability to

respond to ROI requests

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Building a Business Case Expected components of cost savings

Software support fees (top priority)

Hardware support fees

Internal support/help desk staff

Hardware refresh

Data center costs

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Building a Business Case Annual Cost Savings

$0

$500,000

$1,000,000

$1,500,000

$2,000,000

$2,500,000

$3,000,000

$3,500,000

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Pre-project legacy costs Post Project Costs

Annual Savings

Yale JMH

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Yale JMH

Annualized Legacy Support Fees only $2,980,000 $2,780,000

Annualized Active Archive fees/costs

(Including new equipment)* $326,000 $304,000

Net Savings $2,654,000 $2,476,000

Additional cost savings not calculated:

• Net hardware refresh & data center costs

• Net savings on internal support/help desk staff

* For Yale, no new equipment; for JMH, new hardware figured into

self-hosted datacenter costs; Cost of learning new system:

negligible, easy to use.

Building the Business CaseIllustrate Savings with ROI Analysis

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What to ArchiveWorkflow and User Access

No workflow,

no GUI

No workflow,

no GUI

Replicate legacy

look, feel, and

workflow

Replicate legacy

look, feel, and

workflow

0% 100%Seek a balance based on need of

specific data set.

We retained essential workflow as

determined by end users and

governance group.

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What to ArchiveAmount of Data to Retain

Discard all data from

applications

Discard all data from

applications

Keep all data from

applications

Keep all data from

applications

0% 100%

Seek a balance based on need

of specific data set.

Legal and Compliance agree on

data to retain.

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Enterprise Data GovernanceModel employed at Yale New Haven Health

• All projects led through IT, providing consistent leadership

• IT had over-arching responsibility for selecting applications to retire and data to be retained, with input from business units and compliance

• SMEs from the business units performed data validation and software testing/acceptance

• SMEs who knew the legacy systems but had moved on to analyst roles within the organization were tapped for the enterprise archiving project

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Enterprise Data GovernanceModel employed at John Muir Health

• Governance board developed that selected applications to retire and data to retain

Comprised of Compliance, Legal, IT, HIM, Revenue Cycle, Clinical

Needed guidance and buy-in by all data stakeholders

• IT led the projects, with SMEs for testing and validation

• JMH employs an active archive expert who knows and supports the enterprise archiving system, just like any other major application

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Engaging OperationsEvaluating Data for Enterprise Archiving and Applications for Retirement

• Legacy application-specific questionnaire completed for each application (JMH)

• RFP conducted for archiving options

• Confirmed data retention periods through Legal, HIM, and Compliance sub-committees

• Project planning prioritized based upon cost reduction and contractual obligations

Stakeholders

Clinical

HIM

Research

Legal

Compliance

Revenue Cycle

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• Types of questions: how the information was used, any reporting needs, their perception/interpretation of what the future requirements would be

• Who was interviewed: direct operational users and their supervisors

• Departments:

– HIM: any legal medical record retention requirements

– Legal: regulatory/legal considerations

– Compliance: any retention requirements related to HIPAA and other regulations

– Treasury: advise regarding the financial systems

Interviewing Operations

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Business EngagementLegacy Retirement Planning Discussions

Stakeholders

Clinical

HIM

Research

Legal

Compliance

Revenue Cycle

• Set expectations: not an identical replication of the legacy application

• Involved operations team in archive decision

• Decided on an ActiveArchive

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Project OverviewNext phase after new HIS

An active archive was selected to address the following requirements:

• Provides longitudinal patient records that indicate original legacy

system

• Supports EMR integration – patient context viewing

• All YNHHS financial data will remain in an “active” state (complete

billing functionality) to accommodate compliance, billing, and

collection functions for a minimum of ten years

• All YNHHS clinical data will be available to providers, auditors, and

researchers for a minimum of ten years

• Meets ITS security and infrastructure standards

• Enables retirement of legacy systems post migration to the active

archive, realizing cost savings

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Overcoming Enterprise Archiving Challenges

• As an enterprise program, projects are rolled out over time

• Worked with vendor to test and stage the data ahead of

migrating it into the database, minimizing any downtime

• Managing end user expectations

Actual needs, define use cases

Central v. local storage

Archive will not replicate legacy system

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Enterprise Archive Cycle

Determine which applications to decommissionDiscovery

• WHO: Involve business unit leadership, Compliance, Legal

• WHEN: Shortly after selection of new HIS

• WHAT: Set criteria, identify use cases for legacy data: clinical, revenue cycle, ERP

Choose technology and service – Enterprise Active ArchiveSolution

• Involve business units in decision

• Get a “partner” to help solve problems; technology to manage workflow

Plan retirement phasesPlanning

Migrate data to Enterprise Active Archive & Retire Legacy AppsImplement

• Phased in over several years

Active Archive Progression at YNHHS

SCM

Jan ‘16

Cerner

Sept ‘16

3M Chartview

Oct ‘17

Centricity EMR

Sept ‘17

QuadraMedInteGreate

(McKesson)

HAC (Horizon

Amb Care -McKesson)

Med-Informatix

Medipac

Feb ‘16

SDK

July ‘16

Meditech

May ‘18

Clinical Data (read only)

Financial Data (read/write)

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Enterprise Active Archive Integration with new EMR

Easy access to legacy data from

within new EMR under the

navigator section “PreEpicEMR”

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Quick Adoption

Uneventful go-live – no calls from users, including physicians

The Active Archive was easy to use

• Configured for end users

• Use cases were satisfied

Stakeholders were included in the selection and implementation process

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• Start early – ideally at the same time as selection of new HIS or during merger

• Include the business unit stakeholders: Revenue Cycle, Clinicians, HIM, Finance/HR, IS

• Manage expectations within the organization with a clear vision, project plan, and budget

• Engage in data retention ‘roadmapping’

• Set expectations early – active archive vs. the legacy applications

• Ensure a successful program with your own internal project manager/coordinator

• Ensure data validation beyond a simple record count test

Recommendations/Lessons Learned

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Thank you! Please complete your online session evaluation!

Questions?

Lisa Stump

Senior Vice President and CIO

lisa.stump@ynhh.org

Bill Hudson

Associate CIO, VP of IT Operations

bill.hudson@johnmuirhealth.com