10 Release of Information Pitfalls to Avoid in an EMR

Environment

Presented byFig GungorCEO

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 RequestsChallenge: 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 ROIChallenge: 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

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