10 Release of Information Pitfalls to Avoid in an EMR Environment
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Transcript of 10 Release of Information Pitfalls to Avoid in an EMR Environment
Agenda
Introduction - ROI has Changed 10 ROI Pitfalls to Avoid in Relation to:
1. Electronic is not Always Effortless2. Preserving Security 3. Providing Reporting Capabilities4. Maintaining Data Integrity 5. Following Labor Cost Guidelines6. Updating HIPAA Compliance Policies7. Data Breaches8. Responding to Meaningful Use Requests9. Managing the Business of ROI10. Overcoming Common Misconceptions
Summary Q&A
Release of Information has Changed
HITECH Act promoted the adoption of Electronic Medical Record (“EMR”) systems
EMR systems boast benefits but ROI is not their focus
Evaluate how your new EMR, Meaningful Use, Labor Costs and compliance updates could affect your organization’s ROI practices
Take the proper steps to ensure compliance
Are you ready?
1. Electronic is not Always Effortless
Challenge: Hybrid charts
Automatic file retrieval
Loss of tangibility
Increased turnaround time
Employee capabilities
Solution: Implement a well defined process that guarantees that all elements of the requested chart are
included in duplication
Store electronic and paper PHI in a single central location
Train users to identify parts of charts based on naming conventions and image previews
2. Preserving Security
Challenge: Open access
Vulnerability
Access to unnecessary information
Solution: Restrict unlimited access to patient’s records
Create and implement user roles
Implement a Disaster Recovery Plan
Create procedural safeguards
3. Providing Reporting Capabilities
Challenge: Some providers who have implemented EMR’s are struggling to track:
Meaningful Use requests Accounting of Disclosures Turnaround time Cash/self pay Charts of patients who are involved with litigation Verbal authorization to release proof of immunization Incomplete/deficient charts Payments for records (if applicable)
Solution: Develop a plan that allows you to track these types of requests
Work with your EMR system provider to tailor the system to your needs
4. Maintaining Data Integrity
Challenge: Minimum Necessary Standard
Some EMR charts contain information that should not be released: Medical records, release forms and correspondence documents from other facilities Internal hospital records Records of different patients with duplicate medical record numbers
Human error
Lost records
Solution: Institute strict guidelines for uploading data and processing requests
Work with your EMR vendor to organize how your data is stored
Implement quality review measures
Follow a detailed plan when converting paper charts to digital format
5. Following Labor Cost Guidelines
Challenge: Labor Costs- Reasonable fee that covers the cost of skilled technical staff time
spent creating and copying electronic files Compiling, extracting, scanning, burning discs, distributing media Cost of supplies and postage or courier Can not charge retrieval fee
Eligibility Eligible: patients, qualified representatives and claimant’s attorneys (with
healthcare POA) Ineligible: defense attorneys, claimant’s attorneys/third parties lacking
healthcare POA and insurance companies
Must charge the lower of Labor Costs and State mandated pricing
Solution: Perform a cost analysis to determine your organization's Labor Costs
Inform your staff of eligibility and guidelines for charging different requestors
6. Updating HIPAA Compliance Policies
Challenge: Compliance Policy
Documented policy that outlines the steps taken by an organization to ensure a diligent attempt to protect the privacy and security of patient records
Must dictate how the organization will react to a breach
Risk Analysis
Designate officers
Encryption
New BA Agreement- Equally as liable as Covered Entities
Solution: Consult with experts to build a program that complies with the standards set forth by
HITECH
Distribute policy to employees
Follow policy
7. Data Breaches
Challenge: Breach - “Generally, an impermissible use or disclosure under the Privacy Rule that
compromises the security or privacy of the protected health information.”
Breach response process Investigate and document incident Risk Assessment - Determine threat, if any, to patients Breach notification requirements Review and update protocols, procedures and policies to mitigate future risk
Solution: Implement detailed Breach Policy
Designate an Incident Response team/lead
8. Responding to Meaningful Use Requests
Challenge: Meaningful Use - When the requested records exist on an EMR system and the records are
requested to be delivered in electronic format, you must respond to the request within 3 days
Solution: Qualifications - Familiarize yourself and your staff
Patient or qualified requestor submit written or oral request Fully electronic records (not paper or hybrid) Records delivered in electronic format
Outlined process - Develop and follow a plan Screen mail Determine if request meets Meaningful Use criteria Document in EMR system Process request Burn to encrypted disc or use other encrypted transfer Mail encrypted disc or arrange pick up
If records are unavailable, the patient must be notified within 3 days
9. Managing the Business of ROI
Challenge: Staffing
Billing
Status request calls and correspondence
Release of records
Track completed requestsSolution: Implement a comprehensive ROI practice that encompasses the issues mentioned throughout this presentation
Highly skilled and knowledgeable of industry guidelines Appropriate for volume Allows your facility to meet the restrictive guidelines established by HITECH and
Meaningful Use Implement a system to generate invoices at proper rates, monitor payments
Quality assurance - check files & authorizations Encryption Tracking
10.Overcoming Common Misconceptions
Challenge: HIM staff can be reduced because of EMR systems
All other systems are up to speed with EMR system
Once the EMR system is rolled out, the job is done
Solution: Prepare for EMR system transition:
An implemented EMR system requires: Upgrades Training User management Physician Adoption
Staff your department appropriately Consider temporary staff or outsourcing
Improve imaging systems, billing systems, administrative scheduling systems etc…
Summary
HITECH and Meaningful Use aim to maximize patient care
Implementing an EMR system is a tool to realize that goal, not the goal itself
Providers must consider the unintended downstream effects when choosing their EMR system and make the necessary changes to their procedures and policies to comply with recent rulings
www.onesourcedoc.com/hitech