Confidentiality policy protects patient identities
What's in a name? Potential embarrassment for celebrities, employees, or anyone else whose treatment at a hospital is made public against their wishes. Miami's Jackson Memorial Hospital last July provided a much-publicized example of a confidentiality breach when it was discovered that hospital employees were peeking at the electronic medical records of Italian fashion designer Gianni Versace, admitted after being fatally shot outside his Miami Beach villa.
Most hospitals admit celebrities of Versace's renown only rarely, but it's not uncommon to encounter local VIPs or hospital employees who wish to conceal their identities during a hospital stay. A simple workable alias policy should be part of any access management policy book.
The University of Texas Medical Branch (UTMB) in Galveston has a confidentiality policy that protects the identities of patients who want their hospital stay kept under wraps while ensuring quality patient care. The policy allows patients to use a fictitious name, which masks their identity throughout their stay. Many patients who use aliases at UTMB are having cosmetic or other elective procedures done at one of the its day surgery clinics, says Melanie Mencacci, RN, assistant director of patient financial services. "They don't want their name to show up on the OR schedule. Every unit sees that."
The policy makes use of the hospital's electronic master patient index, which allows staff to set up a fictitious name then substitute the patient's real name after discharge. (See insert.) In effect for several years, the policy "was triggered by having several patients that for various reasons needed to have their identities protected," says Diana Barr, RRA, associate director of health information. They have included local VIPs, a witness protection program member, staff, and a gang member. "Any patient who feels the need to be seen under a fictitious name," she says, can use the policy.
When a patient is admitted and asks for his or her identity to be concealed, the medical center's master patient index is searched to see if that patient has been admitted previously as an inpatient or an outpatient. If the patient has not, a new medical record number is assigned and the chosen fictitious name is affixed to the record.
If the patient already has a medical record number, the real primary name in the master patient index is changed to an alias, and the fictitious name is added to the master patient index as a primary name during the hospital stay. It will be noted in a comment screen during registration that the person is coming in under an alias, but access to that screen is limited to admitters, financial counselors, and case managers, Mencacci says.
Note that a distinction is made between an alias - such as a maiden name or nickname - and a fictitious name, which bears no relation to the real name. So Jane Johnson's medical record may list Jane Carson - her maiden name - as an alias, which remains part of her medical record. A fictitious name would be affixed only if requested to hide her identity - and only during the hospital stay. When she is discharged, the master patient index is adjusted to show her real identity, and the fictitious name is listed as an alias in the master patient record, Barr explains.
Under the policy, only hospital staff who need to view a record bearing a fictitious name may do so. "If under normal circumstances someone in billing would have access to that [confidential] record, they would continue to have access if the role calls for it," Barr says. If staff use that access inappropriately, "then that would be dealt with because of their using their authority to access this information for reasons not related to the job," she says. A system of computerized audit trails shows who accesses medical records, so inappropriate access would raise a red flag.
At UTMB, a celebrity record isn't flagged, says Jim Braden, MBA, director of health information management. "It's just treated as a standard record - for good reason. We don't want to attract attention to it," he says. For that reason, fictitious names such as John Doe or Jane Smith are avoided. "That would draw attention to it. They come up with whatever name they want to use; something that wouldn't draw attention."
The UTMB policy requires additional time to update the medical record after discharge. "Having to go back in and make the change at the time of discharge, creating an alias with the fictitious name, adjusting the medical records to show the real identity"- those tasks contribute to extra hours spent enforcing the policy, Barr says.
A team of admitting, health information, risk management, outpatient, and information systems department staff at the medical center consulted with other health information management departments and legal counsel to develop the policy, Barr says. Then it was submitted for review by the hospital policy and procedure committee, which has members from departments including legal, hospital admitting, and physicians.
"We view this as part and parcel of an overall strategy of ensuring the accuracy and integrity of our master patient index, and we view the master patient index as an extremely important strategic tactic," adds Carl Hula, associate director, health information management.
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