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Archiving Compliance with Q-Path
pererap
Posted: Friday, August 9, 2013
Joined: 8/31/2011
Posts: 231


Dear Section,

 


For those of you who use Qpath (or another WorkFlow solution) and do not upload the studies onto PACS/Syngo... how did you convince your Compliance/IT department that having ED's own WorkFlow solution is sufficient as a stand-alone archiver?  My institution's Compliance group's concern is in regard to those u/s studies that the clinician will use to base his/her clinical decision on; they are asking for all those to end up on a "central hospital" archiver like PACS (the educational studies being stored solely on Qpath are "ok" for them.)  
I have communicated to our compliance group that the Qpath studies are to be stored legally & safely for 10 years and are easily retrievable at any time upon request, but this availability is not deemed enough for them if the u/s result/interpretation has become "part of the chart."  
I understand it's possible to upload studies from Qpath to PACS, but this would not be our division's preference.  

If you've dealt with this at your home institution, your input would be greatly appreciated.

 


Many Thanks,
Svetlana
pererap
Posted: Friday, August 9, 2013
Joined: 8/31/2011
Posts: 231


Interesting question.

Out of curiosity, why is QPath not considered a PACS?

It is a "picture archival and communication service".

Typically it can be made available on a hospital network, with passwords provided to those who want access.

There are many cardiology/ OB/Gyn services in the community that are still archiving on VHS or thermal prints.

Chris Moore

pererap
Posted: Friday, August 9, 2013
Joined: 8/31/2011
Posts: 231


I think it is best to think of QPath as a software solution that lives on a server. It functions as a type of PACS system. However, unlike the PACS system that your Radiology Department uses (such as Centricity, AGFA, etc.), it doesn't come with a robust set of servers with multiple redundant layers of back up. So, when you suggest to your IT department that "we want to begin using QPath" you are probably assuming that all you need is the QPath software loaded on a simple server and that's enough. But, to your hospital IT department, this assumption is naive at best and likely viewed by them as dangerous and potentially disastrous for the institution.

Your hospital IT department is going to have several internal requirements (based on what is required by CMS and other federal requirements) about how a server that houses protected health information functions, who has access to it and how it is backed up. This is really important for the protection of you, as a physician who is billing a professional fee for ultrasound exams, and your hospital, who is probably billing and collecting the technical component of the exam.

Say for instance that you decide to install the Software on a PC that lives in your department or even purchase a server from QPath with the software on it. What happens if that PC / server crashes and some of the information is lost?  Or what if the whole thing completely dies and everything that it was storing was lost? While this is highly unlikely, this whole scenario is what keeps your hospital IT people up at night and gives them bad dreams. Imagine that you lost 6 months worth of data in one of those crashes. If that server is where you stored and archived those images, you can no longer prove that you completed those exams. If you were audited, you would not be able to produce those images and you would be accused of fraud. If the audit was done by CMS on a CMS patient, your entire institution would now be at risk of not just having to pay back CMS for those exams but also risks being denied future CMS reimbursement, which would in essence shut down most hospital systems who receive a huge portion of their revenue from Medicare and Medicaid patients. This is why our idea to "just bring in QPath that can archive all of our studies" is greeted with great trepidation from both compliance and the IT folks.

To get around this problem, it is best to have your hospital IT department either host the server and apply their standard back-up system for the server OR just install the software on one of their servers, where they also ensure proper back-up. While this may require some work on the front end, it is well worth the risk and headache that would ensue should you decide to host the server yourself, independent of the hospital IT department.

The real problem isn't with the QPath software, but with the way it is hosted. And that problem is easily solved by convincing them to host and maintain the server. We have done just that at our institution where QPath is the PACS system for all point of care studies that are done institution wide. However, it took time and effort to convince them why the traditional AGFA PACS system didn't meet our needs. And it took me time to understand all of their requirements and their reasoning behind them.

Rob Ferre
 
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