Women's Health Connection wishes to thank the community for their support during the 11 years that we welcomed and cared for patients in the greater Spokane area.
Our practice formally closed on September 16, 2016. Women's Health Connection was a dba of "Northwest Health Summit". The other divisions, including Metabolic Health Connection, and Northwest Psychiatry and TMS Services, also closed on that date. We were able to continue to employ a medical records clerk until October 27th, 2016, and most requests received on or before that date were sent out per your request as best we were able with diminishing human resources and fiscal resources. There is no longer an office nor employees at NWHS and the company is insolvent.
For Records Requests Received after October 27, 2016
The corporate officers and their representatives at NWHS have reached out to a HIPAA compliant third party custodian, Datified, to request that they carefully store the medical records and make records available on request to patients for the next 8 to 10 years. We have a Business Associate Agreement in place with them. However, we do not yet have possession of our medical records to pass on to that company as complete pdfs.
NWHS is experiencing delays in getting records to that custodian in that the practice's electronic medical records host (INHS) has not yet been able to turnover the records to NWHS in a format that is complete and easily readable by a human.
Initially INHS had in September 2017, told us that they would provide an archive of the patients records in pdf format as well as an Oracle database, and then expunge the records. They showed us an example of their archive, and when the medical directors had a look at this example they discovered that the archiving system had not been programmed to include chart notes, office visits, office procedures, surgical operative notes, dictations, psychiatry notes, or imaging reports, and was missing more than half of the labs. INHS said that their archiving system was compliant with GE Standards, however we challenged that, in that the standard of care for archiving is a complete record, and assumes that the programming will capture all of the items listed above. The medical directors determined that the archive, as provided by INHS was uninterpretable and grossly incomplete.
INHS told NWHS that it was going to give NWHS the archives in that format anyway, as well as an Oracle database (a system that is not readily readable as medical records, but for a significant cost could be set up in another live system as a new set of medical records - fiscally impossible for NWHS). They said they were then going to expunge the records.
NWHS, in response, put the company into a Chapter 11 bankruptcy (as it was insolvent anyway) to reach an agreement with INHS not to proceed in this way, for the sake of good patient care, and to turn over a complete set of records, readable by a human, as a pdf. INHS told the court that it knew it could not hold the medical records hostage for lack of payment from NWHS, and also told the court that it was willing to provide medical records directly to patients on request. These statements were recorded by the court and are public record. However a few days later, INHS told NWHS directly that it would not do that, despite what it had told the court. This led to further discussion.
INHS had since then been co-operating with NWHS to try to extract the patient data from their servers, but it appears to be stored by INHS in a manner in which it was embedded with other practice's data (INHS hosts electronic records for many practices). Extracting it into a database specific to NWHS patients, that can then be turned into a meaningful and readable record is a process that NWHS had been told will take several weeks to months for INHS to complete. Specifically what INHS had told us is that they began the process of extracting the data on December 28, 2016, and that it would take approximately 4 weeks to complete. (A few weeks ago, INHS updated NWHS that it would likely not be complete until mid-February, closer to 7 weeks from the date of that meeting). After that separation is completed by INHS, another company ("Ellkay") will need to help them convert that database into a single pdf of the complete medical record, readable by a human. That process, we understand, will take another 4-12 weeks approximately. INHS attempted to do this archiving process on their own, without outside help, when NWHS initially asked for their records back in September 2016. However the sample of a medical records archive they gave us at that time only contained about 20% of the patients record, in the estimation of the licensed providers who examined these records, and thus was not acceptable as an archive, in that it was so incomplete and difficult to read. It did not contain any of our signed chart notes, office notes, operative reports or imaging reports, just many tables of data points that were difficult to make sense of. So INHS told us they will need outside help and expertise - they had communicated to us that they do not have the expertise within their company at this time to complete this project of returning complete readable medical records to NWHS that would include our complete office documents. NWHS was able to locate expert outside help for INHS to do this conversion once they have the data extracted ("Ellkay"), but we have not yet confirmed that it will be an acceptable archive. We are hopeful though, based on initial conversations and meetings with Ellkay, and the fact that they have helped INHS to this in another similar situation in which INHS was unable to provide a complete archive on their own.
Once INHS has extracted the database the next two steps are to: (1) have the data converted into a readable medical record, as the physicians and providers had originally documented it, in a pdf format, as above and (2) to turnover the readable pdfs to a HIPAA compliant medical records custodian for release to patients on request.
In the meantime, INHS has provided ongoing live medical records access to the practice. But there are no longer employees or an office setting nor equipment for the practice to reproduce these records from the live system, nor any employees to manage the live system, nor any expertise or equipment to do this. So the corporate officers have been hard at work to try to find an interim solution while we wait for INHS to extract our patients records and return them to our closed practice so they can be turned over to a custodial company for safekeeping and for distribution to patients on request. In searching for a solution, we very recently discovered that Datified can print records from the live system to small pdfs for distribution from a live system as well.
We had a meeting with INHS and Datified earlier in January 2017 to discuss the access of the custodial medical records company, from INHS, and make sure that it is done in a tamper proof way. We have a BAA (Business Associate Agreement) in place with Datified, and were hoping to finalize the details of a contract with them early in the week of January 30th, 2017.
At that point, patients will be able to access records directly from that company, who will access and extract data from the live system that INHS is maintaining for NWHS until INHS can get the records given back to NWHS in a complete readable format.
The only drawback is that from the live system, the records can only be reproduced line item by line item as many dozens of individual pdf files for each document on each chart. This is a problem that our clinic struggled with for years when it was open. It required more than one full time employee to reproduce records on request because the process of extracting records from the live system is relatively inefficient. In some cases, these records need to be extracted as hundreds and hundreds of little pdf files for each patient record. This rather inefficient process will continue to be the way that records need to be printed to pdf until INHS provides the practice with a complete pdf archive of the record and discontinues the live system.
The need for Datified to have to print the existing records line item by line item from the live system as multiple small pdfs (one for each line item on the chart) has potential to add cost for patients, over their usual fees. The other potential problem is that it is very difficult to make sense of because it is not all on a single orderly document, and needs to be sent out as many different secure encrypted emails. But Datified has indicated that they can combine this into one document. All of this will need to be tested before we roll it out, but we are hopeful.
We are still looking forward to a time when INHS can give the company back its records, in a readable single pdf format, that can be given to the custodian, instead of having them try to access a live system. That will make this process is much easier and less time consuming.
NWHS is planning to return the medical records requests to patients and/or their new providers that were received after October 27th, 2017, (or before, but that were not fulfilled prior to that time because of rapidly changing financial circumstances). NWHS has not been able to fulfil these requests to date for the reasons above and does not anticipate being in a position to do this going forward. NWHS is now able to patients with an alternative way to obtain their records through Datified, as above. We are planning to include a Datified medical records request be sent to patients whose request for medical records was received between October 27th and January 23, 2017. Alternatively, medical records from NWHS can be ordered through Datified using their website, www.OrderMedicalRecords.com or by one of the methods below. The contact number for Datafied is on this records request form and on their website.
Once a contract is in place between Datified and NWHS, all future medical records requests can be made directly to Datified by the following methods:
1. Email: firstname.lastname@example.org
2. Mail: PO Box 18116, Anaheim, CA, 92817
3. Fax: (800) 922-3892
4. By portal at www.ordermedicalrecords.com
Datified's pricing and turnaround times are available on their website.
January 29, 2017 update
INHS has informed us that they are cancelling our Business Associate Agreement (the agreement between INHS and NWHS that allows them to share patient information) effective January 26, 2017. However, they continue to maintain the live system and provide access to outside parties such as Datified and Ellkay since that date. The letter from their representative states that they have tried to return the records many times, but it has not been possible since we have no employees. As multiple email conversations and court documents carefully detail, this is not the case. The corporate officers have been pushing hard for the turnover of these records since August of 2016 and have not been given these by INHS.
The letter of January 26, 2017 from the INHS representative also states that INHS has a set of archives ready to turnover to NWHS at this point. Since they have not yet involved Ellkay, NWHS is concerned that the same flaws in how they extracted the data last September may still be present, but the corporate officers will pick up the hard drive and have a look at these records in the upcoming week. The previous attempt INHS had made to archive the records of NWHS last September was missing chart notes, operative notes, procedure notes, imaging reports, dictations, and most of the lab values. The letter from the INHS representative did not indicate if the data separation had been completed, and was thus ready for Ellkay to extract the complete set of notes. It further said that INHS would maintain the live system for another 45 days to allow for "NWHS's third party vendors" to extract the records. The representative seems to be confused about the role of the third party vendors in the letter, and does not seem to acknowledge that we are still waiting for INHS to separate the records (a process we were told would take until mid-February). Since we had not received word yet that INHS was finished separating our patient's data from all the other clinic's data, we have not had a chance to let these Ellkay test to see if they would be able to extract the data in an acceptable format.
If the archived records that INHS says is now complete and available for NWHS to pick up truly is complete, we will be very happy. If it is not, Ellkay will need to be involved, which will take another 60 to 90 days, approximately.
In addition, NWHS has concerns that the system we had worked out with Datified to print copies of the medical records to pdf for patients from the live system while we wait to obtain complete archives, may not be HIPAA compliant now that INHS has cancelled our Business Associate Agreement effective January 27, 2017. Without a new BAA, or reinstating the previous one, we are hesitant to proceed, for HIPAA compliance reasons, particularly since this involves an ongoing transfer of information between INHS and Datified, that we would need to approve. We will need to put this interim solution on hold while we research this matter further.
The representative of INHS seems confident that the live system can be maintained and access given to Datified for purposes of distribution to patients until complete records are turned over to NWHS, without a Business Associate Agreement. NWHS is questioning that, and researching further before signing a contract with Datified to access the records for distribution purposes.
NWHS appreciates your patience with this process which is proving to be rather challenging. It seems that electronic medical records systems and hosts are great for organizing and for securing putting patient information into the chart, and hosting the chart, and providing IT support for this process, but not so good at extracting it back out again when it needs to be extracted or transferred for patient care reasons. NWHS continues to inform and work with the Department of Health and Washington State Medical Association with updates on this process.