Final Memo - File Maintenance Review

8/2/2019 Final Memo - File Maintenance Review

1/7

Page 1 of 7

Memorandum

DATE: October 25, 2011

TO: Barry Schumacher, Chief of Employer Services

Tim Wahlin, Chief of Injury Services

Jodi Bjornson, General CounselTim Schenfisch, Director of Information Technology

Kim Ehli, Director of ClaimsTom Solberg, Director of Medical Services

Darrel Enerson, Application Services Supervisor

Steve Vaughan, Technology Services SupervisorDenise Bachler, Director of Office Services

Cade Jorgenson, Decision Review Office

CC: Bryan Klipfel, DirectorClare Carlson, Deputy Director

John Halvorson, Chief Operating OfficerMichele Blumhagen, Quality Assurance Director

FROM: Krisi L. Kunz, Internal Auditor

Micole Kvas, Internal Audit Director

RE: File Maintenance Review

The Internal Audit Department at Workforce Safety & Insurance (WSI) recently completed a

review of the maintenance of files for injured workers and employers. The review was conductedat the request of Management.

PurposeThe purpose of this review was to determine the adequacy of internal controls and procedures

utilized in maintaining files for injured workers and employers.

ScopeThe scope of the review was from January 1, 2010 through October 14, 2011, and included the

following:

Notepad entries made within the Claims Management System (CMS), including medicalreviews completed by the WSI Medical Director that are documented within the CMS

notepad.

Notepad entries made within the Policyholder Information Computer System (PICS).Methodology

Verified the appropriate procedures are being followed at the time a CMS notepad entryis deleted, moved or updated in an injured workers claim file.

Verified medical opinion documentation from the WSI Medical Director is beingincluded, unaltered, in the injured workers claim file.

Verified the appropriate procedures are being followed at the time a PICS notepad entryis deleted, moved or updated in an employers account file.


2/7

Page 2 of 7

Define RecordsThe North Dakota Century Code (NDCC) 54-46-02(2) defines Record as follows:

Record means document, book, paper, photograph, sound recording or other material,regardless of physical form or characteristics, made or received pursuant to law or in

connection with the transaction of official business. Library and museum material made

or acquired and preserved solely for reference or exhibition purposes, extra copies of

documents preserved only for convenience of reference, and stocks of publications and of

processed documents are not included within the definition of records as used in thischapter.

The Assistant Attorney General primarily addressing open records issues and the Director of the

States Risk Management Division were contacted to obtain a general understanding of an agencys

authority relating to the contents of a record. These discussions were consistent with the

following basic principle:

Each individual state agency has the responsibility to determine the internal use of its

records and further has the authority to dictate the format and content to help ensure

records meet their intended purpose.

Injured workers claim files and employers account files are included within WSIs records

retention schedule:

#190101 Injured Worker Claim File

Description: This series contains information regarding injured work claims and theaction taken. This includes medical and legal documents and any other general

correspondence and documentation relating to the claim.

Confidential: NDCC 65-05-32

#800304 Employer Account FileActive

Description: This series contains original application, annual payroll report, annualbilling statements, 2nd, 3rd, 4th request for payment, optional employer contracts, andcorrespondence.


#800305 Employer Account FileCanceled

Description: This series contains the same type of information as active accounts

including original application.


Review Results

Internal Audit separated this review into three sections: CMS notepad entries, WSI MedicalDirectors medical reviews, and PICS notepad entries. Below you will find the review results foreach of these sections, along with recommendations/suggestions for improvements.

Section 1: CMS Notepad EntriesThe Claims Department currently has Claims Procedure #906 File Maintenance and

Documentation, which indicates the following relating to the function of the notepad, along

with moving, updating and deleting notepad entries:


3/7


4/7


5/7

Page 5 of 7

on the wrong claim; 1 was due to confidentiality reasons; and, 6 had no documentedreason for the deletion within the request.

RecommendationsInternal Audit recommends WSI determine whether or not they should allow notepad entries in

CMS to be deleted. During this determination they should consider the public perception of

items being deleted from the system without any record.

If WSI decides to discontinue deleting inappropriate notepad entries and notices an inappropriatenotepad in the future, WSI could add an additional notepad entry explaining why the notepad is

inappropriate and that training will be given to the individual who added the inappropriatenotepad entry. In addition, Claims Procedure 906 should be updated to reflect this change, and

all appropriate staff should be notified of this new process.

If WSI decides to continue deleting inappropriate notepads, the following should be done:

Review and update Claims Procedure 906 to include more detail/examples of reasons fornotepad deletions. Once this is completed, all appropriate staff should be notified of this

update.

Documentation should be kept on notepad entries that were deleted. At a minimum, thedate of the deletion, claim number, owner of the notepad entry, reason for the deletion,and what type of training was provided to the owner of the deleted notepad should be

documented.

In addition, all appropriate staff should receive refresher training on what is/is not appropriate to

be entered into CMS notepads. This training should also include information on when notepad

entries can/cannot be moved, updated and possibly deleted. All staff should know who isauthorized to make changes, along with who has authority to make these requests to the Help

Desk. If at all possible, these requests should be handled by the individuals who have system

access to make these changes and not sent to the Help Desk.

The Help Desk should develop and implement a process/procedure to ensure that requests, ifreceived, have the appropriate approval before the notepad is moved, updated and possibly

deleted. All IS staff that works with changes to notepad entries should be trained on thisprocess/procedure.

Note: Appropriate staff referred to above includes all individuals that have the capability tocreate CMS notepad entries. This would include all staff outside of Injury Services who have this

capability, for example, the Legal Department and the Decision Review Office.

Section 2: WSI Medical Directors Medical ReviewsMedical reviews are completed by WSIs Medical Director when requested by the claims staff

(or legal staff via claims staff). Medical reviews are generally requested if there is a question oncompensability, there is legal action occurring or if it is a highly complex claim/injury.

WSIs Medical Directordeveloped his own standard format for his medical reviews in 2007,

which includes:

Identification of the injured worker and claim number Listing of all documentation reviewed during the medical review Clinical history Discussion Conclusion


6/7


7/7

Page 7 of 7

The PICS system has the following security roles:

Updating Notepads

Not everything on the note can be updated. The fields that can be updated are: the text,the view indicator, and a follow-up date. The fields that cant be updated are: the date thenote was entered, the category, the sub-category, and the policy period. The only person

who can update a note is the one who originally created it.

Moving NotepadsNotes can be moved from one account to another. The only person who can move

(transfer) a note is the one who originally created it.

Deleting Notepads

PICS notes cant be deleted, but the whole text could be changed or removed with theupdate function noted above.

RecommendationsInternal Audit recommends WSI determine whether or not they should allow the text of notepadentries in PICS to be updated, knowing that the text could be deleted in its entirety. During this

determination they should consider the public perception of items being changed within thesystem without any record.

If WSI decides to discontinue updating the text within notepad entries and notices an

inappropriate notepad in the future, WSI could add an additional notepad entry explaining why

the notepad is inappropriate and that training will be given to the individual who added theinappropriate notepad entry.

If WSI decides to continue allowing the text of notepad entries to be updated, documentation

should be kept on notepad entries that were updated. At a minimum, the date of the update,policy number, owner of the notepad entry, reason for the update, and what type of training was

provided to the owner of the updated notepad should be documented. WSI should also considernarrowing the number of individuals that have access to make text updates within notepads (forexample, only supervisors).

In addition, the PHS Operations Guide should include policies/procedures on the maintenance ofnotepad entries within the PICS system (updating and moving notes). Consideration should also

be made on narrowing the number of individuals with move capabilities. Once this is

documented, all appropriate staff should be trained on the new policies/procedures.

Note: Appropriate staff referred to above includes all individuals that have the capability to

create PICS notepad entries.

If you have any questions regarding this review, please contact Krisi L. Kunz at x8-3828 or

Micole Kvas at x8-3824.

Thanks.

Final Memo - File Maintenance Review

Documents

Transcript of Final Memo - File Maintenance Review