April 15 inspires fear and loathing in many Americans, but this year's tax deadline provided nothing but relief for Paul Brown, HIPAA compliance officer for the New Mexico Department of Health (DOH). That's not surprising since Brown finished a two-year project linking the DOH's entire computer system -- 2,800 PCs using a dozen legacy systems in 198 permanent, temporary and mobile offices around the state -- just the day before.
This overhaul was needed to meet federal guidelines created by the Health Insurance Portability and Accountability Act (HIPAA). Although HIPAA passed in 1996, Congress didn't approve the first set of rules -- those relating to transaction and code sets, which standardize labels for all medical services -- until October 2000. States originally had two years to implement each HIPAA rule, but the due date was pushed back to October 2003.
In the meantime, Congress issued a privacy rule for HIPAA with an accompanying deadline of April 14, 2003 -- the first finish line states had to cross.
A Healthy Re-Evaluation
HIPAA's broad goal is to give citizens more control over their health information -- from diagnosis to treatment to payment. To do so, however, health-care providers must notify citizens of their rights, maintain the security of this information and be able to compare their data with that of other providers. "As a government agency and health-care provider, we're required to institute higher levels of confidentiality," said Brown.
New Mexico, which has one of the nation's few centralized public health systems, is covered by HIPAA three ways:
- The state is a provider, giving services to clients.
- The state is a payer, covering the costs of health services for selected clients.
- The state is a clearing-house, accepting client information from one organization and forwarding it to another.
Under HIPAA's privacy rule, Brown said, "We have to provide a notice of privacy practices to every client we serve. We also have to track the authorization clients give before we can release information for reasons other than treatment and payment." In addition, New Mexico must provide clients with a list of every organization that has received information about them from the state.
This last requirement proved especially challenging given the lack of communication between the state's residential hospitals, nursing homes, behavioral health centers and other offices. "The Dale Atkinson who went to a doctor's office for a diagnosis and the Dale Atkinson who was receiving behavioral health treatment may or may not be the same person," said Dale Atkinson, CTO of POD Inc., an Albuquerque-based technology firm.
To solve that problem, POD developed a client correlation system -- the Integrated Client Data System (ICDS) -- that could identify whether two clients were actually the same person or possibly the same given similarity in their data. "In one system with twelve years of records, they had roughly 10 percent of data that was duplicated, basically situations where a person got married, changed his name, or started a new record at another office," said Atkinson. "Across all the systems, we found even higher duplication, sometimes as high as 70 percent to 80 percent." By reducing client duplication, ICDS gave New Mexico its first accurate client count.
ICDS also pulls together data from New Mexico's other state health agencies: the Human Services Department, which deals with Medicaid programs; the Children, Youth and Families Department, which is responsible for child protective services; and the New Mexico Retiree Healthcare Authority, which is the health plan for all state retirees.
The state rewrote its policies and procedures regarding client privacy, but an ICDS training module allowed the Health Department's 4,000 employees and volunteers to open a Web browser over the DOH intranet and take the training on the new procedures in their own office. "We'd been migrating toward Microsoft Windows 2000 for the basic operation of our network, so when people logged in, the network knew who they were and whether they had completed the training," Brown said.
The technology at the heart of the ICDS is Microsoft's BizTalk Server 2000, BizTalk's HIPAA Accelerator and SQL Server 2000.
"BizTalk is a universal translation system that can take information from different systems, translate it into XML [extensible markup language], and put it in whatever system you're currently using," said Julia White, a Microsoft product manager. "It's optimized for the situation New Mexico faced. People do not want to change their legacy systems, because they're expensive to touch, and this serves as the magic black box that does the 'anything-to-anything' translation needed to make the information meaningful to everyone."
New Mexico's next HIPAA deadline is October 2003, at which time the state -- and every other health-care system -- must begin using industry standard transaction claims whenever it applies for or receives payment on health-care claims. With 450,000 residents lacking health insurance coverage, New Mexico interacts with Medicare and Medicaid constantly, but not every transaction goes smoothly. "Some of our departments use standard codes, but others use local codes that they've developed over the years," Brown said.
A gap analysis undertaken by DOH and POD revealed a chasm between what's ideal and what's in place. "They had basically three different payment systems in operation and a half-dozen different billing systems," Atkinson said. The BizTalk translator at the core of the ICDS will now take the idiosyncratic codes generated by each office and standardize them.
"Ideally we'll all be using the same transaction standards, [both the state and the hundreds of contractors it works with], and greatly simplify the way clients have to deal with health care," said Brown. "We're idealistic that this will speed up the processing of claims."
Once More Under the Knife
In addition to meeting the transaction rule, DOH has begun work on the recently issued HIPAA security mandates and awaits a rule creating a uniform system for identifying health plans. "I'm looking at this position as a long-term career option," Brown joked. New Mexico's budget for HIPAA implementation has risen from $3 million in the fiscal year ending June 30, 2002, to $6 million in 2003 and $12 million in 2004.
That may sound like a lot of money, Brown said, but it takes time and research to figure out how to meet each rule. "I'd like to say it was smooth as silk, but any time you're trying to do a multiagency project, you have to coordinate with the management of each agency," Brown said. "Plus we had a new governor come in Jan. 1, so we had to go through an education process on why HIPAA is important."
The biggest challenge, Brown said, was getting HIPAA information out to the rank and file. With flyers in paychecks, a poster campaign and newsletters, he thinks DOH workers have caught on to why they should care about the changes to New Mexico's health-care system. "We have to put ourselves in our clients' shoes," he said. "After all, we are our own clients."
W. Eric Martin is a freelance writer in southeastern Massachusetts.