How can your practice prepare for OpenNotes?
Have you heard? OpenNotes – a new, federal requirement mandating that clinicians make certain practitioner notes more available to patients – is fast-approaching, going into effect April 5, 2021. Preparing for OpenNotes and coming into compliance with this new program is an important opportunity for your organization to not only avoid noncompliance penalties, but also to improve patient engagement, reduce potential liability issues, and strengthen patient-physician relationships through increased transparency.
But what exactly do these new regulations mandate, and what are best practices for meeting and exceeding the requirements? We sat down with Medical Advantage’s very own OpenNotes expert, Chad Anguilm, to better understand this new requirement and to walk through his 5-step solution to a successful OpenNotes rollout in your organization.
This is the sixth episode in the Medical Advantage Podcast, where each we take time each episode to discuss the ideas and technologies changing healthcare, and the best practices your organization can take to stay productive and profitable. Subscribe wherever you get your podcasts to ensure you never miss an episode.
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More on this episode’s discussion:
- 5 Steps to a Successful OpenNotes Implementation at Your Practice
- “OpenNotes”: A Brand-New Practice Compliance Requirement Starts on Monday, April 5, 2021
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Full Episode Transcript
Medical Advantage Podcast: Welcome to the Medical Advantage podcast, where you can hear healthcare professionals, expert consultants, and industry thought leaders discuss the exciting new ideas and technologies that are changing the business of healthcare. Tune in to each episode as we hear from some of the most innovative minds in medicine about the future of healthcare and how your organization can stay profitable, efficient, and on top of industry best practices.
Celina DeFigueiredo-Dusseau: Welcome everyone to the Medical Advantage podcast series. I am your host, Celina Dusseau, and today we are joined by Chad, our vice president of in practice technology services here at Medical Advantage. Chad has well over 15 years of experience in healthcare and healthcare technology services. His wealth of experience and practice operations, EHR optimization and practice workflows has made him a truly incredible resource for today’s topic.
Today we will be discussing OpenNotes, what changes are taking place in 2021 and much more. So Chad, thank you for taking the time with us today. We’re very excited to discuss this topic. Would you like to introduce yourself a bit about what you do and what brings us here today?
Chad Anguilm: Thank you for having me, so my role within the Medical Advantage and the TDC group of companies allows me to constantly research plan and provide a path to success for 90, 000 plus clients. So, as new mandates come about, we dig into them and educate our clients so they can truly focus on patient care and not unlike OpenNotes, which brings us here today. There are constantly new requirements put on our clinicians, and it often becomes overwhelming to keep it straight. So, I look forward to providing some more insight with you today, Celina.
Celina DeFigueiredo-Dusseau: Thank you so much, Chad. So, as we dig into our content, obviously a hot topic is the coming mandate of OpenNotes. So, can you give us just a little bit of context and history to this? What exactly is OpenNotes? Who does it impact? Most importantly, why should a physician want to make the effort to do this?
Chad Anguilm: Absolutely, I mean, truly, the idea behind OpenNotes is that a patient’s visit notes will now be available to the patient at any time at no charge. So I look at it much like an expanded version of what we help medical practices set up in their systems and in their processes to provide visit summaries to comply with meaningful use over 10 years ago and honestly, now, instead of a summary, you’re allowing the patient to view the entire note, their, their entire record. The requirement to deploy OpenNotes was written into law under the 21st century care act in 2016, with a start date currently set for April 5th of 21. On this date, physicians will be required to be in compliance, and I mean, if you look at it currently with what we’ve been doing, just testing this and setting it up over the past few years since it came about in 2016, there’s now more than 8 million patients in the U. S. who have access to their clinician’s notes. What we found, the resulting increases in transparency have shown promise in improving care, patient outcomes, and preventing costs into the healthcare system, which we’re all looking at helping with.
Also what we found is that engaged patients are more motivated to follow their care plan and have higher rates of health literacy and increased patient engagement and studies have shown that after one year, 99 percent of patients who were surveyed wish to continue. If you think about it, Celina, we have an aging population with an increasing life expectancy and for many dealing with a sickness is like being in a foreign country unable to understand the language or navigate the roads to your destination. So OpenNotes can provide a detailed guidebook for patients and their caregivers.
Celina DeFigueiredo-Dusseau: That’s so important, Chad. I mean, of course, this year has brought so many changes as practices are trying to get back to normal and another change to workflows both for the practices and patients can be a little bit overwhelming, but really, this is designed to help practices drive better engagement and have more effective open conversations with their patients.
So can you tell us just in a little bit more detail how physicians have to make this information available to their patients and how that falls into place? into compliance with the OpenNotes legislation?
Chad Anguilm: Absolutely. So to comply, medical practices need to unblock or really just make available new categories of your patient’s health care information. So the sharing of these notes should feel very similar to the sharing of visit summaries. There are eight types of clinical notes that must be shared now. So consultation notes, discharge and summary notes, history and physical. imaging narratives, lab report narratives, pathology report narratives, procedure notes, and progress notes. So exempt from the new rule are psychotherapy notes and information compiled in anticipation of lawsuits. You may not wish to share those, honestly, and you don’t have to. It’s really up to you as a provider and your organization of what you want to share. If you have a risk management team, designed. around ensuring that OpenNotes are successful. Options exist to you in giving guidelines about what you want to share and what you don’t want to share. So really get with that committee, get with that team. If you don’t have one, create one. Addressing liability and practicing safe medicine is, is truly the main goal with OpenNotes.
So this is all meant to be positive with patients having an opportunity to review their own notes, there are opportunities for mistakes and errors to be corrected with more accurate records. There are improved patient outcomes and reduced liability. There truly are a lot of positives with this if you think about it as a patient and most of us on this pod today, understand the medical industry, we understand the lingo.
If we go into a doctor’s office, we pretty much can understand what the physician’s telling us and you have to think those that may not be in this industry or may not understand, it’s completely overwhelming when you’re told about a new medical condition and you have all this trust in your physician but truly may be incomplete fear if you hear of something that you may not understand or you haven’t heard before. Then. Everything beyond that within that discussion keeps building and you just aren’t understanding. Then when you get home and you start mentioning it with a loved one or a family or a friend you may not remember everything you were told. So that’s what OpenNotes is all about. It’s the convenience of being able to jog your memory at that time of need about the visit provider’s instructions from here on health.
Celina DeFigueiredo-Dusseau: That’s such an important point, Chad. And, you know, I think something we’ve discussed in the past too, is kind of easing that transition by creating a plan and sort of having a timeline between now and that April 5th of 21 date that, you know, is coming up so quickly and I think at the top of everyone’s mind is that timeline. So, Why don’t we talk about that a little bit? When does everybody have to do this? When should we start planning? And what does that timeline look like for implementing OpenNotes? And when those regulations come into place, what are the penalties for non compliance?
Chad Anguilm: Great question, Celina. So, the deadline for clinical notes to be shared is April 5th of 2021 and the deadlines for those same notes to be shared with a third party app or portal that may be downloaded to a smartphone, for instance, is October 6th of 2022. So getting into the penalty side, a current proposed rule would allow for penalties of up to a million dollars for non compliance. Although as of now, penalties are delayed for 2021 and they aren’t laid out, but that doesn’t mean they aren’t going to exist down the road. We’re really in that transition period and you should use this period as an opportunity to bring yourself into compliance and get your policies and procedures in place.
Like I’ve mentioned, we’ve been working with health systems for years now to get this in place in many cases. And, and there are some heavy lifting when it comes to your, your policies and procedures and training your staff and getting signage and everything that goes along with it.
Right and we know this process can seem a bit daunting, as we mentioned before, any changes can be a little bit overwhelming and disruptive to your workflows. Chad, I’d love to hear if you have any general advice for coming into OpenNode smoothly, in compliance, and where to go if I need help.
There are several key best practices in implementing and maintaining compliance with OpenNotes. It will impact everything from how the practices record notes to your IT network security. If you don’t currently have a patient portal in place, it gets more complicated. One option to achieve compliance is allowing patients to access their files on your EHR with strong user specific security, make sure your portal is optimized, or you may be able to add patient portal functionality to your EHR system.
If you were looking for an outsider, standalone portal, striving for transparency and clarity throughout the entire OpenNotes process is one of the best practices. So if you think about that, being honest and clear in your notes, you write, we’ll help you address both liability. and more effectively communicating serious conditions with your patients armed with information, patients will do better. These more accurate records will result in improved patient outcomes and reduce liability.
Celina DeFigueiredo-Dusseau: All right. So with that, let’s jump into the second part of our session for today. As I mentioned, we’re going to do a full breakdown of this implementation into five really simple steps. So starting with number one, being educating patients and staff about clinical note transparency, regulations for compliance and benefits. So Chad, let’s hear some detail about what this means in practice.
Chad Anguilm: Sure. The first step is all about communicating the benefits of OpenNotes to the relative stakeholders within your organization, such as your leadership team, your colleagues, your staff, and any patient advocacy groups that you may have in place. Honestly, it’s a great first step. Medication adherence is one of the most tangible and great examples of why OpenNotes is a good thing. Better notes prevent deaths from the health and healthcare system cost increase by helping patients adhere more closely to the regimen and that’s always the number one lead in that I go when I’m implementing OpenNotes at an organization or even having the, the initial discussion, because everybody understands what you’re talking about with the struggle that all organizations have with medication adherence.
So being able to go home, See what you talked about during the visit and go through those notes. It’s absolutely going to help you be more engaged as a patient and understand what your provider is trying to do. Further benefit, you can expect less questions from patients between visits. Patients being more prepared, involved, and informed. Also possibly offloading the workload that frees up capacity at the practice. So that’s a great selling point to your team. So if you’re talking through what are some of the advantages, I want to gain buy in from my team. I want those within my practice to really buy into OpenNotch and see the advantages.
One of them is if you better educate the patient when they’re in front of you, and then when they leave you, they’re much more prepared to take on their health care. They’re much more or much less likely then to reach back out and say I didn’t understand when my physician said this or my nurse said this. They’re able to then log on to their patient portal and take a look at the treatment plan So there’s a lot of reasons to do this both the health care of your patient , offloading some of the work that you typically take in on a daily basis with all of those phone calls and emails
Celina DeFigueiredo-Dusseau: Yeah, you’re exactly right, Chad and as we all know, every practice has a different approach to running their business and interacting with their patients. So step two is incredibly important to consider in the context of your practice and your patients. That is, planning what OpenNotes will look like in your practice. So, Chad, let’s hear how this might look different amongst unique practices.
Chad Anguilm: I would say this stage, the second step really planning what it will look like in your practice is the most important and most time intensive. You have to remember that no two practices are the same. You really have to take Time to develop policies that will work for your unique practice. I can tell you this from consulting and practices all over the country for 15 years. No two practices are the same and this really sets the stage for your organization’s procedures as you approach OpenNotes. So we recommend you get in front of this work with your EHR vendor or system to get your patient portal aligned with your new policies.
Get your procedures, technology, and workflow in harmony as soon as possible. And consider if you should make changes to your EHR or optimize it to get ready. I can absolutely tell you that there’s many steps that you’ll need to take to do so. So think about questions like. How will you manage your patient’s requests? How will patients and their proxies access the notes? How will patient requests to change notes be managed? Who on your team will be responsible for educating and enrolling patients and introducing them to OpenNotes? So all of these questions must be addressed prior to rollout and of course, you may need to adapt the plan later on as more things change and we’ll talk about that as we continue through these five steps.
Celina DeFigueiredo-Dusseau: Exactly, Chad. Having a plan in place is so important to doing this right the first time. You have to be sure there’s enough time to agree on a plan. Then ensure your staff and patients have time to get on board, which brings us to step number three. Prepare your practice and patients. Chad, let’s hear a little bit about how practices can raise awareness of this change and how giving them a fair heads up can actually help reduce pushback.
Chad Anguilm: Raising awareness is the number one way to reduce pushback for your staff. Answer questions about the need for OpenNotes and for transparency. Post information in the practice and have team meetings to educate your staff on OpenNotes. Then thinking through your patients, use email and portal information to promote the adoption of OpenNotes on social and other channels. Engage with all stakeholders to impress upon them the benefits of this new technology and how proper use will benefit all. Again, referring back to my reference of meaningful use 10 years ago, it’s the same thing. It’s getting everybody engaged, everyone on board, you get your elevator speeches prepared, you get everyone excited, realizing how this would benefit them, and you’ll be successful.
Celina DeFigueiredo-Dusseau: Exactly and after you take some time to prepare your practice and patients for OpenNotes, you’ll have a great opportunity to assess your own needs for making this a smooth transition, bringing us to step number four, adapting your documentation style as needed. Now, while many clinicians may not need to make many changes in this area, others will be able to use this opportunity to reflect and improve. So Chad, can you talk to me about some of the considerations practices should be making in this step?
Chad Anguilm: I get it already overburdened clinicians fear that making these notes accessible to their patients will add to their workload. I totally understand it. What we found in all the studies that have been done thus far in the groups that we’ve worked with only, you know, 12 percent of physicians have actually said that they’ve had to spend more time and there’s very few specialties where we found that to be true. So don’t fear. While many physicians are worrying, you know, that they’re going to have to change their writing and the style in which they make their notes, just because patients can now view it doesn’t necessarily mean that you’ll have to change the way that you write. Generally, be positive and supportive not judgmental or labeling or any commentary that could be seen as such, and reduce the use of technical jargon. So, write for a layman so your patient can fully understand, and this will increase the overall effectiveness of OpenNotes. Of course, it will now be important to think carefully about the language that you use and describe things like abuse, mental health, substance abuse, driving privilege, privileges, or suspicions of life threatening conditions, as patients will be reading their own notes.
So keep their emotional and informational needs in mind. Also, be mindful when recording Notes with potentially litigious patients and just think through that. We talked about that as as a few of the types of notes earlier that you don’t necessarily have to share. So just be mindful and what’s being shared and again, that all goes back to the policies and procedures that you put in place as a as a health system.
Celina DeFigueiredo-Dusseau: Right. Of course, with any change, there’s challenges and concerns. And of course, one in particular is how to handle these challenging topics. Now, of course, as clinicians, you are accustomed to overcoming difficult conversations in person, but this can be a little bit daunting to put it on paper in front of your patients for them to see. So step five here in the implementation process is learning how to tackle those difficult topics in an OpenNotes environment. Chad, let’s hear your thoughts on
Chad Anguilm: Like I just mentioned, you know, this is a difficult piece of it. So in an era of transparency and honestly exemplified now with the advent of OpenNotes, some of these challenging topics, like I talked about abuse, substances, life threatening injuries, etc. You have to decide if those, are worth sharing and I’ve talked to a lot of specialists in this area, many have said, if it’s important enough to talk about, it’s important enough to put in the note. At this point, many believe you’re building trust that open communication, these conversations about challenging topics and conditions are hard, but they’re worth having and if you’re writing about them, talk to your patient about them. Honesty and transparency always results in better outcomes. Having said that, don’t be uncomfortable making a determination about what and what not to include based on the exemptions you have available. Lastly, consider how your patient will view the terminology jargon.
A great example that many have brought up is SOB, putting shortness of breath in a note. You know, the acronym SOB can be seen in many different ways and some not so positive. So generally work on your jargon, work on writing out terminology, even defining them. We’ve helped many organizations do this with macros and templates and different things where we’re able to just have the clinician pop in a quick explanation with the click of a button.
So generally offer a balanced perspective, describe the patient’s strength. Progress and achievements in a language that your patient can understand. This is a great counterbalance to the more technical focus aspects and honestly, the result of all this will be better physician patient relationships and an increase in their engagement in their own healthcare.
Celina DeFigueiredo-Dusseau: Yeah, Chad, this has been so informative and I really think these five steps give a solid action plan for approaching OpenNotes as April 5th gets closer. As we start to close up here, do you have some advice on general best practices for implementation and how Medical Advantage can help ease this transition?
Chad Anguilm: Striving for transparency and clarity throughout the entire OpenNotes process is one of the best practices. Be honest and clear with the notes that you write, and it will help you address both liability and more effectively communicating serious conditions to your patients. They will be much more armed with information. Patients will do better. These more accurate records will result in improved patient outcomes and reduced liability. Medical Advantage is here to assist you throughout the launch of your OpenNotes program. For more information, our website offers insights including blogs, our podcast series, and other explainers and resources in thought leadership.
Our team is there for you and ready to assist you with your needs. Contact myself or one of our SMEs for further assistance.
Celina DeFigueiredo-Dusseau: Chad, thank you for walking us through this. Changes are always daunting, but we truly hope that this step by step process helps to ease some of practice’s concerns. We really appreciate your insights and making this a little bit more digestible.
Chad Anguilm: Absolutely. Thank you for having me.
Celina DeFigueiredo-Dusseau: To our audience, I just want to remind you that Medical Advantage is here to assist you throughout the launch of your OpenNotes program. For more information, our website medicaladvantage.com offers insights, including blogs, rest of our podcast series and other content and readers and resources and thought leadership.
Our team is here for you and ready to assist with your needs. Feel free to contact Chad or one of our subject matter experts for further assistance. Should you have any questions coming out of this podcast today, feel free to reach out to us at info@medicaladvantage.com. With that, I’d like to thank you, Chad, for your time today and thank you always to our audience for listening in.
See you next time.
Medical Advantage Podcast: Thanks for joining us this week on the Medical Advantage Podcast where we discuss the ideas and technologies changing healthcare and what they mean to your organization. For more information, visit us at medicaladvantage.com and make sure to subscribe to the podcast on iTunes, Spotify, or wherever you get your podcast, so you never miss a show.
