For the first time in more than 40 years, Indian Health Service (IHS), a federal agency within the Department of Health and Human Services (HHS), is getting a new electronic health record (EHR) system. The multi-year health IT modernization initiative will replace the organization’s homegrown Resource and Patient Management System (RPMS) with a more robust commercial solution. The plan is for a new enterprise EHR system to deploy in 2024. Tribes recognized as Compacted Shares will choose to implement their own commercial EHR or to adopt the enterprise system chosen by the IHS. The IHS serves 2.6 million members from 574 federally-recognized tribes of American Indians and Alaska Natives. These members span twelve physical service areas across the county. There are plans underway to ensure the transition to the new EHR goes well. There also needs to be a thorough plan to ensure the legacy health records currently in RPMS are accessible to meet patient care and retention requirements. RPMS, like other older EHRs, has technical limitations. Data silos and a lack of interoperability. RPMS lives onsite in databases at local facilities across the country. This makes record sharing a challenge and creates additional problems for patients who need to share information with new providers when they are referred to a new facility, seek emergency room care or move to a new location. A study of 2000 RPMS users from IHS, Tribal, and Urban sites concluded that it needs to upgrade with new technology or completely replace it (with another EHR). In addition, 40 percent of respondents rated the electronic sharing of information with patients through a portal as “very poor” or “somewhat poor.” Shared technology with the VA would eventually require a costly IT programming investment. Even though RPMS is certified to the most recent 2015 Edition criteria published by the Office of the National Coordinator for Health Information Technology (ONC), future criteria could require significant investments. “A unique challenge for RPMS is that it was developed with a Graphical User Interface (GUI) provided through a collaboration with the Department of Veterans Affairs (VA). The GUI code base over time will need support that would require additional investment by the IHS as the VA is moving forward with Oracle Cerner,” shared Mitchell Thornbrugh, CIO, IHS in an interview. He also says the agency’s next EHR needs to include a more patient-centered design. Specialized rules for IHS records management dictate new EHR functionality needed. As a recognized federal agency, the IHS must follow Federal agency rules to preserve records that contain health and organizational information. Record retention requirements for the IHS follow the General Records Management Program issued by the National Archives and additional requirements detailed in the Disposition Schedule. A few points to note: Ownership. All records are property of the Federal government and must be managed according to applicable laws and regulations. Annual inventory. All records held by an IHS Office must be inventoried on an annual basis using a specific Records Management Inventory Worksheet. Active record retention. Medical records are required to be retained in IHS health care facilities from three to seven years after the last episode of care. There are specific instances that vary from this rule, including dental records and lab reports, emergency room files, and others. Records may be retired to the Federal Records Centers (FRC) after three or more years of inactivity (depending on the facility’s available filing space and research activities). Inactive record retention. After three years of inactivity, a record is considered inactive and sent to the Records are required to be batched and electronically transferred on an annual basis and maintained for 75 years. RPMS replacement calls for a legacy data management plan. With the upcoming replacement of RPMS and its ancillary systems VistA Imaging (VI), ICare, Laboratory Services, Clinical Reporting System (CRS) and Electronic Dental Record (EDR); a decision must also be made about what to do with legacy data. In a recent presentation, three priorities for the Modernization Data Management Needs were outlined: Continuity of care. Only a small subset of data will be moved to the (new) enterprise EHR – basic demographics and recent core clinical data (Problems, Allergies, Medications, Procedures, Immunizations, and some clinical notes). Providers will need to reference older records on occasion, and they should not have to access old RPMS boxes to do that. Interoperability. Accessing data on shared patients, both within the IHS, Tribes and Urban (I/T/U) designations and with private/public sector. Medical record retention. . This may change, but it is unrealistic for RPMS or any EHR to hold that much data. Therefore, facilities will need An active archive supports IHS legacy data priorities. An active archive, such as HealthData Archiver™, is a go-to companion solution for any EHR system replacement. Archiving is a common industry practice in healthcare. More than 70 percent of CIOs from mainstream healthcare delivery organizations surveyed reported they have an archive in place and have more archiving on their to-do lists. Generally, there are two paths forward for data housed in a current EHR system: Migrate and convert data to the new go-forward system. Usually about 24 months of key clinical data will move forward to the new system. Archive the legacy data. Due to cost and complexity of data conversion, it makes sense to archive historical data in HealthData Archiver® and include a Single Sign-On from the go-forward EHR for ongoing and immediate accessibility of the records. There are many cost, security, and workflow efficiencies that come with including an active archive solution in a legacy data management plan. Another benefit is that archived records are activated for interoperability with other systems, entities or patients via HealthData Integrator®, which provides a set of tools or APIs based on common industry standards such as USCDI, FHIR, HL7, C-CDA, XML, or Direct. Are you an RPMS user that is part of the IHS, Tribes, or Urban Indian Organization (UIO)? Our team delivers strategic planning, tactical execution, and day-to-day support for healthcare organizations of all sizes. Since 2006, our US-based team of experts has worked with over 550 unique clinical, financial, and administrative brands. Our core values are simple and meaningful. We seek to do the right thing, be easy to work with, exceed expectations, serve humbly and never stop improving. These values have helped guide us to be named the number one data extraction, migration, and archival healthcare IT company in the nation for the past four years. We are ready to help the IHS facilities move forward. Please reach out to schedule an introductory call.