Using an Index to Clarify an Access Request and Reduce the Cost
The goal in the Privacy Office of Sun Country Health Region is to assist applicants with their information requests in a timely manner, and to provide a positive experience. Occasionally, this can be very challenging and costly, especially when the request includes a large number of records, or records from several sources.
We now develop an index (see Table 3) of the requested records and provide a copy of this index to the applicant. This is very helpful when the applicant lives out of town and allows us to provide assistance over the phone. At a subsequent meeting with the applicant, we review the index and determine exactly what portions of the record are important to the applicant. We identify duplicate information and records the applicant may not need, ultimately reducing the cost of the package.
Although it takes time to develop the index and meet with the applicant, the rewards are great. The applicant is satisfied when the initial fee estimate has been reduced, sometimes by as much as one-half, or less.
If we know in advance that the applicant is requesting several records in the Region from various sites, we coordinate the request through our privacy office so we can respond in a timely and organized manner.
Table 3 refers to a simplified index showing an example of a request for personal health information from multiple health care sources. This example identifies duplication of documentation as the patient is moved through the different levels of care.
The initial fee estimate, based on 220 pages, was $245 (Table 1).
After a meeting, the applicant decided on a total of 58 pages at a cost of $42.50. When the applicant was given an opportunity to decide exactly what was needed, the cost was reduced by $202.50. In this example, the applicant decided to eliminate duplication from three sources and identified unneeded sections of the record, such as progress notes, etc.
This process can be applied to access to information requests for both personal health information under The Health Information Protection Act (HIPA) and personal or corporate information under The Local Authority Freedom of Information and Protection of Privacy Act (LA FOIP).
Table 1: Initial Fee Estimate – Applicant requested the entire record for all 3 sources
| Type of Fee | Calculation of Fee | Total Amount of Fees |
| Time required to prepare records for disclosure (redacted source documents) | 7.33 hrs x $15.00/half hr
220 pages x 2 min/page = 440 min |
$220.00 |
| Photocopies of records | 220 pages x $0.25/page | $55.00 |
| Data analysis and verification of inclusions and exclusions in the data (exporting if data) | 0 hrs x $15.00/half hr
not applicable |
$00.00 |
| LESS: | 1 hr free X $15.00/half hr | ($30.00) |
| Total amount of fees required to process access request: | $245.00 | |
Table 2: Revised Fee Estimate – After index reviewed with applicant
| Type of Fee | Calculation of Fee | Total Amount of Fees |
| Time required to prepare records for disclosure (redacted source documents) | 1.93 hrs x $15.00/half hr
58 pages x 2 min/page = 116 min |
$58.00 |
| Photocopies of records | 58 pages x $0.25/page | $14.50 |
| Data analysis and verification of inclusions and exclusions in the data (exporting if data) | 0 hrs x $15.00/half hr
not applicable |
$00.00 |
| LESS: | 1 hr free X $15.00/half hr | ($30.00) |
| Total amount of fees required to process access request: | $42.50 | |
Table 3: Index of 3 Source Documents
Acute Care – Site A (Admission May 1 – June 30, 2014)
| Source Section | Source document Name | # pages | Document Dates | Duplicate (Y) | Applicant does not want copy |
| A1 | Therapies progress notes | 18 | May 1 – June 30, 2014 | 18 | |
| A2 | Guardianship form | 6 | May 15, 2014 | 6 | |
| A3 | Cognitive assessment form | 25 | May 3, 2014 | 25 | |
| A4 | Therapies assessment | 15 | May 8, 2014 | ||
| A5 | History and physical | 2 | May 1, 2014 | ||
| A6 | Physician progress notes | 10 | May 1 – June 30, 2014 | ||
| A7 | Discharge summary | 2 | June 30, 2014 | ||
| A8 | Lab results | 20 | May 1 – June 30, 2014 | 20 | |
| A9 | Physician orders | 6 | May 1 – June 30, 2014 | ||
| A10 | Nursing progress notes | 20 | May 1 – June 30, 2014 | 20 | |
| Totals: | 124 | 89 |
Respite – Site R (Admission June 30 – July 15, 2014
| Source Section | Source document Name | # pages | Document Dates | Duplicate (Y) | Applicant does not want copy |
| R1 | Guardianship form | 6 | May 15, 2014 | Yes (see A2) | 6 |
| R2 | Therapies assessment | 15 | May 8, 2014 | Yes (see A4) | 15 |
| R3 | Admission agreement | 5 | June 30, 2014 | ||
| R4 | Discharge summary (Acute care) | 2 | June 30, 2014 | Yes (see A7) | 2 |
| R5 | Physician progress notes | 5 | June 30 – July 15, 2014 | ||
| R6 | Nursing progress notes | 10 | June 30 – July 15, 2014 | 10 | |
| R7 | Interagency transfer note | 2 | July 15, 2014 | ||
| Totals: | 45 | 33 |
LTC – Site L (Admission July 15 – July 30, 2014)
| Source Section | Source document Name | # pages | Document Dates | Duplicate (Y) | Applicant does not want copy |
| L1 | Guardianship form | 6 | May 15, 2014 | Yes (see A2) | 6 |
| L2 | Therapies assessment | 15 | May 8, 2014 | Yes (see A4) | 15 |
| L3 | Discharge summary (acute care) | 2 | June 30, 2014 | Yes (see A7) | 2 |
| L4 | Interagency transfer note (respite) | 2 | July 15, 2014 | Yes (see R7) | 2 |
| L5 | Admission agreement LTC | 5 | July 15, 2014 | ||
| L6 | Physician orders | 6 | July 15 – 30, 2014 | ||
| L7 | Nursing progress notes | 15 | July 15 – 30, 2014 | 15 | |
| Totals: | 51 | 40 |
| Total pages form all 3 sources: | 220 | Total pages to be eliminated from original request: | 162 |