Anti-Cloning Campaign: One Individual at a Time
Transcript of Anti-Cloning Campaign: One Individual at a Time
NHS Human Services and Magellan Behavioral Health of Pennsylvania present:
Anti-Cloning Campaign: One Individual at a Time
RCPA Conference October 6, 2015
Presented By:
Magellan Karli Schilling, MA, Compliance Auditor
Patty Marth, Compliance Auditor
NHS Human Services Debra Luther, Ph.D., CCE, Senior Director
John Ciavardone, CCE, Senior Vice President
Learning Objectives PART I (Magellan)
• Review the purposes of documentation
• Review Regulatory references
• Review the definition and history of Electronic Health Records
• Discuss the pros and cons of Electronic Health Records
PART II (NHS) • Implementation of an Electronic Health Record
• Identify and discuss barriers and solutions
• Identify and discuss staff training
• Identify and discuss auditing practices
• Identify and discuss policies & procedures agencies can implement to protect against cloning
• Discuss the use of algorithms
Learning Objectives PART III (Magellan) • Learn about the Managed Care Organization’s role
• Discuss the nuances of auditing Electronic Medical Records
• Review Audit Trends and Risk/ Consequences
• Recommendations for Program Compliance
PART IV (NHS & Magellan) • Open Discussion
o Barriers and Challenges
o Other Best Practices related to Compliance and EMR
o Lessons Learned
Purposes of Documentation
Legal record
Continuity of Care
Plan the course of treatment
Monitor healthcare over time
Quality Assurance
Research and education
Ensures compliance with regulatory requirements
Supports claims
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Important Regulatory References
Chapter 55 PA Code § 1101.51
Medical Assistance Bulletins and Policy Clarifications
MCO specific guidelines and requirements
42 CFR Part 455: Program Integrity Requirements for Medicaid
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Electronic Health Records (EHR)
An electronic health record (EHR), or electronic medical record (EMR), refers
to the systematized collection of electronically-stored health information,
in a digital format, about an individual patient or a population.
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History Lesson
Electronic Health Records (EHR) first appeared in the 1960’s
Same goals as today
Emergence of Ambulatory Care
IOM Report “To Err is Human: Building a Safer Health System”
2009 passage of Health Information Technology for Economic and Clinical Health Act (HITECH)
Incentive Program
2013 Statistics:
o 941 manufacturers
o 1,700 unique products
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Electronic Health Records (EHR)
EHRs replace traditional paper medical records with computerized recordkeeping to document and store patient health information.
EHRs may include patient demographics, progress notes, medication logs, medical history, and clinical test results from any health care encounter.
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PROs and CONs of EHR
Advantages Quality of Care
Legibility
Efficiency
Accuracy
Standardization
More Timely Information
Reduced Loss of Paperwork
Research
Continuously Updated
Other Capabilities
Disadvantages Quality of Care
Cost
Privacy Issues
Workflow changes
Temporary loss of productivity
Other Technological Issues
Software quality and usability deficiencies
Cut-and-paste/ cloning techniques
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EHR Implementation
Barriers: • Multiple States and Payers
• Large Volume of staff
• Connectivity
Solutions: • Document modification
• Tiered roll out
• IT Support – Site based assessments
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The NHS Anti-Cloning Campaign
Multifaceted Approach
• Etiology - identification of risk
• Training
• Policy & Print Media
• EHR modifications
• Audits & Algorithms
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Risk Identification
• QI Audit Process
• Investigation process to identify scope
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The NHS Anti-Cloning Campaign
The NHS Anti-Cloning Campaign
Training
• Anti-Cloning 101
• Anti-Cloning 102
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Anti-Cloning Policy and Print Media
• Defining the issue
• Concretizing consequences
• Print Media
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Observations
• Mood
• Communication: Verbal/Non-Verbal
• Insight
• Interactions
• Affect
• Appearance: Physical, Hygiene, Dress
• Mental Status Exam
• Engagement
• Strengths
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EHR Modifications
• Anti-Cloning Acknowledgement
• Disabled ‘Cut and Paste’ Functionality (Jquery)
• Limited use of ‘Pull Forward’ functionality
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Audits & Algorithms
Audit Process Enhancements
• Side by Side comparison of notes across days and within days of service
• Review of several weeks/months of notes simultaneously
• Group Services Audits
Algorithm Development
• Working towards a program to review strings of texts for duplicate content
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95.88%
91.13% 92.75%
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100.00% 100.00% 97.00%
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Impact of Anti-Cloning Campaign - EHR
Variance due to auditor
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41%
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Documents
Variance due to auditor
Managed Care Organization Oversight/ Auditing
• Why do we Audit?
i. To ensure a consistent approach to treatment between providers, Magellan and our County partners
ii. Proactive Patient Safety activity
iii. To measure adherence to standards set by CMS, Pennsylvania DHS and Magellan’s national and local teams
• How do we Audit?
i. On-site Review
ii. Treatment Record Reviews
iii. Integrated Audits
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Auditing The Differences between Paper Files and EHR
Clues identified when reviewing paper files
Differences in Handwriting
Missing Signatures
Altered Documentation
Changes in Date of Service
Clues identified when reviewing EHRs
Copy and Paste
Electronic Signatures
Over-Documentation
No proof of authorship
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Audit Trends- EHR Records
Cut-and-Paste/ Cloning
Signatures Stamps pre-date end time of the session
Signature Stamps conflict with another session or activity
Empty Data Fields
Missing Notes
Pre-populated Code Definitions that don’t correlate to provider’s contract or applicable regulations
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Risk/ Consequences
Increased Exposure
Corrective Action
Identified Overpayment/ Retractions
Extrapolation
Referrals to Oversight Agencies- BPI, OMHSAS, etc.
Referrals to Law Enforcement
Exclusion from future participation in federal health care programs (Medicaid, Medicare)
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Recommendations for Monitoring Program Compliance
1. Accessibility to the Requirements
2. Documentation of the Requirements
3. Policies and Procedures
4. Tools to monitor Compliance
5. Audit Plan
6. Measurements of Effectiveness
7. Mechanisms to Correct and Report Non-Compliance
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Key Points/ Takeaways
Provider’s Presentation
• Don’t over-customize your EHR
• Ensure timely roll out
• ID risks prior to roll out and train staff to avoid them
• Give staff the tools to be successful
• Harness the capacity of your EHR to capture risks
MCO’s Presentation
• Know and understand the regulations and other requirements for documentation
• Recognize both the strengths and limitations of implementing an EHR
• Acknowledge and address how your EHR system may affect Quality of Care
• Impact of EHR on Compliance
• EHR Essential items
• Know the risks and operate an effective Compliance Program
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