quirements, etc. Based on this information, key questions
were raised: Do we need data in two places? What are the
terms of contractual agreements? What exactly are we
paying for? How can we retain required data in a cost-effective manner?
The Denver Health project manager, Patrice Chevalier,
first focused on compliance and potential legal ramifications. Weekly meetings included representatives from
compliance, legal, IT, financial, security, clinical, health
information management (HIM), and data storage to complete DRATs according to a comprehensive plan. The business manager assisted with contracts and budgets. The
data storage manager served as data architect to determine
how to manage data and report information in a meaningful way. Others offered input from various perspectives on
retention, legal, regulatory, and reporting requirements.
The goal of this collaborative effort was to create a retention
process based on consensus. As experts on data retention,
HIM held a key seat at the table.
HIM played an integral role, engaging end users and serving
as a conduit to reach consensus on retention decisions. Their
perspective provided “big picture” guidance on understand-
ing how data is used and how it flows, from what is collected
up front to what is needed on the back end. HIM’s participa-
tion was essential to DRAT development through their under-
standing of the designated record set, audit logs, compliance,
legal requirements, privacy, and all other elements of data
Examples of Challenges and Lessons Learned
Dealing with difficult challenges is an integral and enlightening aspect of system implementation and process improvement. At Denver Health, learning from the challenges eventually led to successful outcomes—including the following
Challenge #1: Building consensus among various stakeholders was no easy task. There was disagreement regarding
who should be the defining authority for retention decisions.
Should it be compliance, operations, business owners? Who
was most familiar with legal considerations, compliance regulations? From different perspectives came a collective concern—losing applications, not knowing how to find and access
data. Even though the data was available in the new system,
many users were more comfortable with old applications. Finally, the project team members took a harder stand, saying:
“You will lose this application. The data will be available in the
new system. This is the date it will happen.”
Lesson learned: As part of the DRAT process, communicate clearly to prepare users for legacy system shutdown.
For example: “Your system will be shut off in six months.
Seven Best Practices for Decommissioning a Legacy System
BELOW ARE SEVEN recommended best practices gleaned from Denver Health’s decommissioning project.
Build a multidisciplinary team. Include representatives from all departments to develop retention policies and procedures—HIM, IT, clinical, compliance, legal, financial, privacy, and security—with support from senior leadership to ensure
Make information governance a top priority. Once the team is assembled, define data and information management
responsibilities including proper conversion, access, retrieval, storage, and disposition. Complete DRATs for all systems. Determine what data you have, where it resides, how it will be used, and what will be converted. Do a detailed inventory of each
system/application inventory—name, implementation date, description, where data flows, and what data comes in and goes
out. Ensure understanding of laws that govern data retention and associated timelines. HIM plays a critical role in conveying
the interrelationships of all data.
Determine specific requirements for different types of records. In addition to the patient health record, consider other
types of data and information such as business office, legal health record, human resources, government entities, behavioral
health, and public health.
Understand your contracts. Communicate with vendors up front and early in the process to ensure a thorough understanding of contractual obligations and time frames. Document implementation dates and any requirements for prior notice
Implement dashboard and tracking tools. Use data analysis to track activities, monitor progress, and keep stakeholders informed. It is important to provide status reports on a routine basis to sustain a productive process and hold everyone
Conduct training and education. Train users at all levels to promote understanding of retention policies and procedures.
Address and alleviate their concerns regarding retention, access, and reporting. As part of the DRAT process, communicate
clearly to prepare users for legacy system shutdown.
Partner with experienced professionals. Consider engaging outside professionals who bring valuable experience and
expertise to help manage your project. These experts can devote focused time and attention, working collaboratively with
your team to understand concerns, address challenges, and seek the best solutions.