Insights

Insights September 2022

Privacy Community of Practice Model Reduces Duplication, Eliminates Silos and Facilitates Collaboration among OHTs

Lauren Black

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It has been exciting to see Ontario Health Teams (OHTs) take shape in different ways – similar to startups – each with its own culture and approach. The open playing field has prompted an impressive degree of innovation.

As healthcare providers navigate the transformation of Ontario’s healthcare system and design ways to work together to better integrate care as OHTs, a recent cross-regional collaboration on the topic of privacy could provide a model for collaboration and sharing best practices. 

Among the many intricacies of setting up and operating an OHT, privacy stands out as a significant issue faced by every region. Every OHT must address the complex question of how to appropriately share personal health information to facilitate seamless, integrated care while properly protecting privacy and following legislative requirements. 

If each OHT acted independently, we could end up with a patchwork of processes and platforms that would prove difficult for clients, healthcare providers and other stakeholders to navigate – and would be even harder to reform down the road. 

As the privacy officer for VHA Home HealthCare (VHA) – a large not-for-profit home and community care provider in Ontario – and as a member of 18 different OHTs, I have the privilege of sitting on privacy committees/working groups of different OHTs in the Greater Toronto Area. While working with these various committees to develop procedures, craft policies, establish standards and frame documents, I saw similar issues emerging within different groups. 

With these cross-OHT connections, VHA became a node in a growing ad hoc network. Each OHT privacy group appreciated insights into what the others were doing and found value in learning from one another’s innovations. VHA saw an opportunity to formalize the network and took the lead in creating an OHT Privacy Community of Practice (CoP). 

The first meeting of the OHT Privacy CoP – hosted through East Toronto Health Partners (ETHP) OHT – was held in April 2021, with six OHTs represented. Today, our monthly meetings have a dozen OHTs at the table and include representation from primary care, as well as the patient and the caregiver. 

The group shares knowledge and resources, reviews proposed pilot projects/tests of change and discusses issues related to privacy, data sharing and secure digital platforms. We have put together a shared privacy toolkit to avoid individual OHTs having to create their own. Documents, such as privacy governance frameworks, data-sharing agreements, breach reports, information practices’ disclosure forms, terms of reference and OHT website privacy statements, reside on a SharePoint site so that all members of the CoP can view and use the work of their peers. We also created a privacy consultation referral form that other OHT working groups can use to connect with their privacy advisors.

Developing these tools has been an iterative process in which ideas and innovations made at one OHT have been improved at another. 

An example is a gap analysis conducted by the North York Toronto Health Partners (NYTHP) OHT. Ontario’s Personal Health Information Protection Act (PHIPA) is very clear about a “health information custodian’s” responsibility for client privacy. However, OHTs are not (yet) health information custodians and must rely on compliance by individual team member organizations across the continuum of care, each of which may have different degrees of privacy programs. Furthermore, while most team members are health service providers designated as health information custodians, some community agencies (such as food security or housing partners) are not designated the same and might not have the same robust privacy practices in place. NYTHP used an Excel spreadsheet to understand baseline privacy practices and determine how to bridge these differences before they could begin sharing any personal health information. 

NYTHP generously made the gap analysis available to all members of the CoP. In the spirit of iterative improvements, East York Region North Durham OHT came back with refinements, including converting the Excel spreadsheet to a survey format, which made it easier to complete, track and collate responses. North Toronto OHT (NT OHT) then developed a series of template documents, including privacy training modules and a sample privacy policy that made it easier for organizations with less robust practices to become compliant. 

That is the spirit of an effective CoP: learning what works and making collective progress to everyone’s benefit through shared action.

The OHT Privacy CoP has enabled access to tools and standards for OHTs that are compatible across the industry and tailored to their needs. Clients and community members have the reassurance and convenience of standardized processes. Stakeholders have a forum to discuss areas of shared concern and can pool resources to resolve them in a manner that can work across OHTs. 

Ontario Health (OH) has taken notice; their privacy officer has attended sessions and OH privacy team members are now regular participants and presenters. In addition, ministry of health representatives have attended, and a recent CoP session included a consultation with the ministry with respect to the proposed new regulations under PHIPA.   

What learnings can we apply to the problems and questions that still lie before us as Ontario’s healthcare landscape takes shape? 

Standardization is clearly beneficial in urban areas, where a client can move from one OHT to another just by crossing the street and the same healthcare providers may participant in multiple OHTs. But regardless of the specific region, CoPs can yield valuable insights and reduce duplication for healthcare leaders across the province. The CoP model can also provide a single, consolidated voice for advocacy, where needed.

With more than 50 different OHTs operating in the province, if we do not collaborate, we risk costly duplication of efforts, wasting of resources and the creation of silos that can undermine the client and provider experience, create confusion and frustration for clients and families and hinder system integration. The success of the OHT Privacy CoP is a model that can be replicated in other areas of shared concern. 

Organizations that partner with many OHTs, such as VHA, can play a crucial role in leveraging these network effects.

When we consider the advantages of the CoP approach – emergent standards, benefits to the client experience and access to a forum where stakeholders, including the government, can converge to communicate and share – it seems like a wheel worth setting in motion across the sector.

About the Author(s)

Lauren Black is the general counsel and privacy officer at VHA Home HealthCare. She is co-chair of the NT OHT and NYTHP privacy groups and an active member of the privacy working groups at ETHP, Downtown East, Downtown West and Scarborough OHTs.

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