Journal of AHIMA - February 2012

Health information from the closed location will be entered into the new system only upon patient return, therefore access to the MPI and the health information must be preserved.

Patient identifiers from one of the previous facilities may be used, or an entirely new set of identifiers may be implemented as of a certain date, such as the date of the merger. If an entity decides to implement new identifiers, it must decide whether to renumber all existing records, renumber the past few years’ records, or simply link them in the MPI. The cost of renumbering all existing records may outweigh the benefit.

All components of the health record must be available for continuity of care purposes during and after the transition. Unit records must be maintained if required by state licensure. The new entity should discuss the requirements for unit records with state licensing authorities. After that discussion, it may want to develop a plan to unite all existing records or only the past few years’ records or establish a new unit record system as of a certain date, such as the effective date of the merger, for returning patients.

It may be cost prohibitive to unite all existing records. Organizations should consider destroying all records beyond the mandatory retention period prior to the merger or acquisition.

Mergers and Acquisitions Resulting in Two or More
Locations with a Single License

A merger or acquisition resulting in two or more locations and a single license may require consolidating records into a unit record and creating a single MPI with a single patient numbering system, depending on the types of care offered at each site and state licensing requirements. Patient health information must be available at all sites. This will necessitate the transportation of paper records and access to all electronic systems.

If all sites provide acute care, health information must be available at any site when the patient presents. If one or more of the locations provides only skilled nursing, long-term care, rehabilitation, or subacute care, it may not be necessary to establish a unit record.

In order to promote patient safety and facilitation of a longitudinal health record, combining health records from a variety of settings is recommended.

If information systems will be consolidated, it may be efficient to consolidate HIM functions into a single department as well. If all HIM functions will be consolidated into a single department, appropriate plans must be made for displaced staff members. If there will be more than one HIM department, it must be determined which functions will be located at each site.

Mergers and Acquisitions Resulting in Two or More
Locations with Separate Licenses

If the new entity will operate from more than one location under separate licenses, the facilities must determine whether the HIM function will be consolidated into a single department, a central department with one or more satellite locations, or two or more independent departments. Planning should address

compliance with all regulatory and licensure requirements for each licensed facility.

Recommendations

When two or more facilities are involved in a merger or acquisition, all HIM requirements should be reviewed to ensure compliance with state licensure and regulatory requirements, accrediting standards, and Medicare Conditions of Participation (if applicable).

Appendix A in the online version of this practice brief, available in the AHIMA Body of Knowledge at www.ahima.org, provides a checklist of information management activities; appendix B provides a checklist when setting up a new clinic.

To ensure availability of health information to all authorized users, health records must be consolidated or linked in the MPI. A minimum of five years of MPI data should be maintained.

A record retention policy that includes logs, indexes, and registers must be developed and implemented to meet the needs of patients and other legitimate users and ensure compliance with legal, regulatory, and accreditation requirements. If health information from closed facilities will be stored for a period of time, its integrity and confidentiality must be preserved, and it must be readily accessible for patient care.

The compatibility and functionality of existing information systems should be assessed, and a plan should be formulated for the integration of systems to the extent possible. Such integration may be essential for the organization to successfully meet the demands of integrated delivery systems. Existing databases should be maintained in an accessible form to meet anticipated future needs.

With their expertise in health information systems and understanding of user needs, HIM professionals can make significant contributions to the evaluation and integration of these systems. ¢

Note

1. Sassano, Paul. “From the M&A Front: Address Tax Considerations Early in the Process.” December 2009. www. jeffersonwells.de/FinanceandAccounting/Articles/ FromtheMandAFront.pdf.