The practice of occupational medicine has unique requirements of an EHR platform, as it is diverse in its scope and settings and has distinct categories, all of which have their own demands. It entails intensive practice of managing industrial injuries and illnesses, including the coordination of care among a number of specialists. In the practice of occupational medicine, there is a protocol-specific nature and longitudinal monitoring of occupational surveillance services that often involves more than one government agency. There are also the reporting/tracking and legal requirements of employee health services. An occupational medicine EHR has many unique needs (Table 5–1).
Table 5–1.Unique features of an occupational medicine EHR. |Favorite Table|Download (.pdf) Table 5–1. Unique features of an occupational medicine EHR.
Creates detailed, company-specific protocols
Bills insurers and companies differently
Includes supporting documentation with workers' compensation invoices
Ensures regulatory compliance
Secures emailing to insurers (eg, injury care reports) and employers (eg, work status)
Provides online portal for limited third-party access to EHR
Tracks lost time, claim duration, utilization, case costs, and patient satisfaction
Generates case summaries for insurers and employers
Generates patient lists by job code, date of injury, body part, examination type, employer, insurer
To address these needs, commercial products specific to occupational medicine practice are available. Large vendors have not sought to merge the needs of an occupational medicine practice with that of a general medical practice. As such, occupational health practices that function within larger group settings are often left to carve out workarounds to support their operations. An occupational medicine practice is not typically eligible for federal financial incentives as its practice does not entail billing through Medicare/Medicaid.
Another challenge facing occupational medicine providers is managing the access to employee health records in the digital age. This is especially important when the organization has multiple roles, which could include (1) employer, (2) health care provider, and/or (3) health plan.
Although the HIPAA privacy rule excludes employment records maintained by a health care organization in its capacity as an employer, there are federal acts and regulations that do guide the management of employee health records (Americans With Disabilities Act [ADA], Family Medical Leave Act [FMLA], and Occupational Safety and Health Act [OSHA]). The general standard is that employee health records must be maintained separately from the employee's general health records by the organization in its capacity as an employer. Individuals who have dual roles within the organization, such as an occupational physician or an occupational health nurse who also functions as part of the health care team in providing patient care, must be aware of the role in which they are accessing the electronic record and accordingly must limit their access.
For example, when acting as an agent of the employer (eg, post-offer placement examination), the occupational health professional must maintain a firewall to keep from accessing the employee's general health records, as state and federal regulations limit the history and examination to elements that are essential to the job function only. If the employee is seen for industrial care, access to the general health record is permitted. These adjustable firewalls for dual use are typically not available as part of an EHR platform and need to be created by the end-user. In regards to retention of employee health records, the most restrictive guidance is from OSHA (29 CFR 1910.1020), which requires retention of employee exposure records for 30 years. As the majority of organizations do not maintain OSHA records separately from employee health records, the OSHA guidance has become the standard for employee health (employment + 30 years).
As occupational medicine and general medicine EHR platforms have developed in silos, they typically do not share information that is relevant to each other's practice. In 2011, at the request of National Institute for Occupational Safety and Health (NIOSH), the Institute of Medicine appointed a committee on Occupational Information and Electronic Health Records to explore the need and feasibility for incorporating occupational information into an EHR. The committee's recommendation was that capturing occupational information supports the “meaningful use” of EHRs, as this information may be used to arrive at an accurate diagnosis, improve the management and treatment of conditions, facilitate return to work, enable more complete public health surveillance, and focus on preventative health efforts.
The committee made 10 recommendations to NIOSH, including but not limited to the following: information models for storing and communication occupational information should be established, the Standard Occupational Classification (SOC) and North American Industry Classification System (NAICS) coding standards should be adopted for use in EHRs, meaningful use and performance metrics for capturing and sharing occupational information should be created, clinician decision support and educational tools regarding return-to-work should be developed, and further study should be done on the ethical and privacy concerns of including occupational information in EHRs. As the specific measures and metrics for achieving stage 3 of meaningful use is yet to be finalized, there is an opportunity to have occupational information included. In 2012, The American College of Occupational and Environmental Medicine (ACOEM) issued an opinion paper calling for the inclusion of occupational health data in EHRs.