optimizing and maintaining operations and workflows: him ... · housekeeping •all attendees are...
TRANSCRIPT
Optimizing and Maintaining Operations and Workflows:HIM Life in a COVID World
Angela Rose, MHA, RHIA, CHPS, FAHIMA
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
8/25/2020 © 2020 MRO. All rights reserved. 1
Listen to the recording of this webinar by clicking the link below
https://info.mrocorp.com/webinar/2020/pt1-recording
8/25/2020 © 2020 MRO. All rights reserved. 2
Today’s Panelists
Angela Rose
VP of Implementation Services and Corporate Policy
8/25/2020 © 2020 MRO. All rights reserved. 3
Rita Bowen
VP of Privacy, Compliance and HIM Policy
Stephanie Kindlick
Sr. Director of Marketing& Host
Housekeeping
8/25/2020 © 2020 MRO. All rights reserved. 4
Housekeeping
• All attendees are on mute
• Please use the chat box feature during the presentation • We will be addressing these questions at the end of today’s presentation
• We are recording this webinar and will send the playback along with a survey
• We appreciate your feedback
• Webinar pre-approved by AHIMA for 1 CEU • Participants who were unable to attend the live presentation will still receive 1 CEU
• Certificates of completion are not required – the presentation will be an option in your AHIMA CEU portal
• Register for the rest of MRO’s 2020 webinar series • Register at: https://info.mrocorp.com/webinar/2020
8/25/2020 © 2020 MRO. All rights reserved. 5
About MRO
8/25/2020 © 2020 MRO. All rights reserved. 6
MRO Overview
8/25/2020 © 2020 MRO. All rights reserved. 7
2ndLargest Disclosure
Management Provider
#1KLAS Category Leader
for 7 Years in a Row
Company Established in 2002
Meet Today’s Speakers
8/25/2020 © 2020 MRO. All rights reserved. 8
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
VP, Privacy, Compliance and HIM Policy, MRO
In her role as Vice President of Privacy, Compliance and HIM Policy, Bowen ensures new
and existing client HIM policies and procedures are to code. Bowen also serves as the
company’s Privacy and Compliance Officer (PCO), assuring timely reporting of any
disclosure incident. She is also responsible for reviewing legislation to assure industry
response and compliance within MRO. Bowen has more than 40 years of experience in
Health Information Management (HIM), holding a variety of HIM director and consulting
roles. Bowen currently sits on The Sequoia Project Board of Directors and is an active
member of the American Health Information Management Association (AHIMA). She
served as AHIMA President and Board Chair, as a member of the Board of Directors for
six years, and of the Council on Certification for three years. Bowen has also served on
the AHIMA Foundation Board of Directors, serving as its Board Chair. She has been
honored with AHIMA’s Triumph Award in the mentor category; she is also the recipient of
the Distinguished Member Award from the Tennessee Health Information Management
Association (THIMA). Bowen is an established author and speaker on HIM topics and has
taught HIM studies at Chattanooga State and the University of Tennessee Memphis.
Bowen holds a Bachelor of Medical Science degree from Emory University in Atlanta, GA
with a focus in medical record administration and a Master’s degree in Health Information/
Informatics Management Technology from the College of Saint Scholastic in Duluth, MN.
8/25/2020 © 2020 MRO. All rights reserved. 9
Angela Rose, MHA, RHIA, CHPS, FAHIMA
VP, Implementation Services and Corporate Policy
As Vice President of Implementation Services for MRO, Rose oversees, and coordinates activities
related to successfully onboarding new clients to MRO’s Release of Information (ROI) platform.
She has more than 25 years of experience in Health Information Management (HIM), with
focused expertise in privacy and security. Prior to joining MRO, she served as Director of HIM
Practice Excellence for the American Health Information Management Association (AHIMA). Rose
is an active member of the American Health Information Management Association (AHIMA) and
currently serves as the Education Co-Chair of the Pennsylvania Health Information Management
Association (PHIMA). Rose is an established author and speaker on various HIM topics. She has
served as adjunct faculty and various HIM Advisory Boards. She currently serves on the
University of Pittsburgh’s and Temple University’s HIM Advisory Boards. She received her
Bachelor of Science in HIM from the University of Pittsburgh and Master’s in Health
Administration from the University of South Florida.
8/25/2020 © 2020 MRO. All rights reserved. 10
Agenda
8/25/2020 © 2020 MRO. All rights reserved. 11
Agenda
• Environmental Scan
• Legal Requirements • HIPAA Compliance
• Other Federal Laws
• Telehealth
• Coding and CDI
• Release of Information
• Telecommuting Checklist
• Management and Thought Leadership
• Questions and Discussion
8/25/2020 © 2020 MRO. All rights reserved. 12
Current Environment
8/25/2020 © 2020 MRO. All rights reserved. 13
Current Environment
• Healthcare Right Now• Healthcare environment becoming overwhelmed (again)• Quarantine/Stay-at-Home/Roll back orders • Social distancing/Mask requirement• Remote workforce• Increased use of telehealth • Patients afraid to seek medical help
• Challenges • Increased demand (varies by state)• Shortage in supplies (again)• Shortage in resources (again)• Exhausted and limited workforce • Continuously changing environment (laws, restrictions, etc.)
• Risks • Compliance • Customer Service
8/25/2020 © 2020 MRO. All rights reserved. 14
Legal Requirements in a DisasterCivil Rights Laws and HIPAA Flexibilities
During the COVID-19 Emergency
8/25/2020 © 2020 MRO. All rights reserved. 15
HIPAA Compliance
• Treatment
• Public Health Activities • To a Public Health Authorities (45 CFR §§ 164.501 and 164.512(b)(1)(i))
• At the Direction of a Public Health Authority or Foreign Government Agency (45 CFR 164.512(b)(1)(i))
• To Persons at Risk (45 CFR 164.512(b)(1)(iv))
• Disclosures to Prevent a Serious or Imminent Threat (45 CFR 164.512(j))
• Disclosures to Family, Friends, and Others Involved in an Individual’s Care and for Notification (45 CFR 164.510(b))
• Disclosures to the Media or Others Not Involved in the Care of the Patient (45 CFR 164.510(b))
• Minimum Necessary (45 CFR 164.502(b))
8/25/2020 © 2020 MRO. All rights reserved. 16
General Requirements
HIPAA Compliance
• Media Access to Individual PHI in Facilities (5/5/2020)• NO CHANGE - Disclosures of PHI to media is not permitted
• Media and film crews are not permitted without patient authorization even if faces are blurred or masked; must obtain a valid signed HIPAA authorization
• Contacting Former COVID-19 Patients about Blood and Plasma Donations (6/12/2020)
• Contacting a patient about blood and plasma donations is permitted under HIPAA as a population-based health care operations activity
• May not constitute marketing
8/25/2020 © 2020 MRO. All rights reserved. 17
General Requirements
HIPAA Compliance
• Permitted disclosures • To provide treatment
• Required by law
• To notify a public health authority to prevent or control spread of disease.
• First responders at risk of infection
• Necessary to prevent/lessen threat to the health and safety of a person/public
• Correctional institution
• Law enforcement official with lawful custody of an inmate/other individual
8/25/2020 © 2020 MRO. All rights reserved. 18
Disclosures to Law Enforcement, Paramedics, First Responders, and Public Health
HIPAA Compliance
• Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency
• Enforcement Discretions • Business Associates - OCR will not impose potential penalties against providers or their
BAs under HIPAA provided:
• BA makes good faith disclosure for public health
• BA informs CE within 10 calendar days of the disclosure
• Community-Based Testing Sites During COVID-19 - Retroactive to 3/13/2020
• OCR will not impose penalties or violations in connection with good faith participation in the operations of testing sites
8/25/2020 © 2020 MRO. All rights reserved. 19
Enforcement Discretions and Waivers
HIPAA Compliance
• Applies to the following provisions of the HIPAA Privacy Rule: • Requirements to obtain a patient's agreement to speak with family members or friends
involved in the patient’s care (45 CFR 164.510(b). )
• Requirements to honor a request to opt out of the facility directory (45 CFR 164.510(a))
• Requirements to distribute a notice of privacy practices (45 CFR 164.520)
• Patient's right to request privacy restrictions (45 CFR 164.522(a))
• Patient's right to request confidential communications (45 CFR 164.522(b))
8/25/2020 © 2020 MRO. All rights reserved. 20
Limited Waiver of Sanctions and Penalties
Other Legal Requirements
• 21st Century Cures Act • Information Blocking Rule and Interoperability
• SAMHSA 42 CFR Part 2 Revised Rule – effective 8/14/2020• Treatment records created by a non-part 2 provider not covered
• Records from a Part 2 provider to a non-provider and incorporated into non-provider’s records are covered
• Disclosure consent no longer requires specific individual name
• New list of activities considered payment and healthcare operations permissible with written consent
• Permits disclosures for care coordination and case management with written consent
• New opioid treatment program provisions
8/25/2020 © 2020 MRO. All rights reserved. 21
Other Federal Laws
Telehealth
8/25/2020 © 2020 MRO. All rights reserved. 22
Telehealth Today
• 0.1% to 43.5%
• 9% to 51%
• 50 states
• 9 million
• $27 billion
• https://aspe.hhs.gov/system/files/pdf/263866/HP_IssueBrief_MedicareTelehealth_final7.29.20.pdf
8/25/2020 © 2020 MRO. All rights reserved. 23
Telehealth
• Centers for Medicare and Medicaid (CMS) • Licensing requirements
• Telehealth and audio-only visits
• Expanded services for beneficiaries
• Billing
• Drug Enforcement Agency (DEA )• Remote prescribing
• Department of Health and Human Services/Office for Civil Rights (HHS/OCR)
• Video technologies use
• Breach penalties due to telehealth not pursued
8/25/2020 © 2020 MRO. All rights reserved. 24
Relaxed Rules and Requirements
Telehealth Tomorrow
• Continued growth
• Permanent place in healthcare
• Policy and procedure needs
• Business Associate Agreements
• Documentation requirements
• Legislation changes • Protecting Access to Post COVID-19 Telehealth Act
• KEEP Telehealth Options Act
8/25/2020 © 2020 MRO. All rights reserved. 25
Coding and CDI
8/25/2020 © 2020 MRO. All rights reserved. 26
Coding and CDI
• Staffing
• Morale
• Communication with providers
• Many changes with coding guidelines related to COVID-19• A lot of questions and new processes for second-level reviews, etc.
• Focus of providers on treatment not documentation
8/25/2020 © 2020 MRO. All rights reserved. 27
Challenges and Tips
Release of Information
8/25/2020 © 2020 MRO. All rights reserved. 28
Release of Information
• About 50% walk-in windows closed
• Alternative workflows in place
• Workforce • Remote
• Skeleton crews
• Volumes went down, but provider and patient volumes coming back strong
8/25/2020 © 2020 MRO. All rights reserved. 29
Today’s Environment
Release of Information
• Audits and Reviews• Medicare Risk Adjustment (MRA) reviews – not suspended
• Medicare Risk Adjustment Data Validation (RADV) audits – suspended
• CMS Audits (Gov’t Audits) – Restarted August 3rd
• HEDIS (Medicare plans) - Suspended
• HEDIS (Commercial & Medicaid plans) – no new requests
• Commercial Risk Adjustment (CRA) reviews – not suspended
8/25/2020 © 2020 MRO. All rights reserved. 30
Today’s Environment
Receiving Requests
• Secure Drop Box
Onsite Options
• Fax
• Portals
Virtual/Electronic Options
8/25/2020 © 2020 MRO. All rights reserved. 31
Receiving
Requests
Delivering Requests
• Fax
• Portals
• Electronic submission (i.e. esMD, SFTP, ERE)
Virtual/Electronic Options
• Scheduled appointments
• Minimal contact
Onsite Options
8/25/2020 © 2020 MRO. All rights reserved. 32
Delivering
Requests
Education and Training
• Instruction Sheet
• Contact information for immediate assistance
Patients/Requesters
• Policy and Procedure• Quick Tips
• Short Trainings
• Contact information for immediate assistance
Employees
8/25/2020 © 2020 MRO. All rights reserved. 33
Telecommuting Checklist
8/25/2020 © 2020 MRO. All rights reserved. 34
Transitioning to a Remote Workforce
• Policy and Procedure • Home Workspace Requirements
• Devices and Connectivity
• Use and Disclosure of PHI
• Reporting Incidents
• Work Days/Hours
• Expenses
• Help
• Sanctions
• Remote Access and Confidentiality Agreement
• Risk Assessment
• Education and Training
8/25/2020 © 2020 MRO. All rights reserved. 35
Remote Workforce Checklist
❑ Private workspace❑ Smart homes (i.e. Alexa, Google Home, Nest, Ring, nanny cams)
❑ Devices (Personal vs. Organization Owned)❑ Inventory and audit
❑ Secured (i.e. anti-virus protection, firewall, encryption)
❑ Updates and maintenance
❑ Functional secure connectivity ❑ Network access (i.e. VPN, VDI-Virtual Desktop Infrastructure)
❑ Internet Connection (i.e. WiFi, Ethernet)
❑ Proper authentication
❑ Effective communication solutions
8/25/2020 © 2020 MRO. All rights reserved. 36
Management and Thought Leadership
8/25/2020 © 2020 MRO. All rights reserved. 37
Pandemic Response Management
• Know your environment
• Monitor and track cases including exposures and potential exposures
• Understand organization policy and protocols • Response times
• Action items
• Workforce exposure protocol
• Reporting (to whom)
• Communication (internal and external)
• Sanitization schedules
• Contamination control
• Education and Training• https://www.cdc.gov/coronavirus/2019-ncov/downloads/Essential-Critical-Workers_Dos-
and-Donts.pdf
8/25/2020 © 2020 MRO. All rights reserved. 38
Think Outside the Box
• Benchmarks/Key Performance Indicators (KPIs)
• Productivity
• Expectation/Accountability
• Policies and Procedures
• Onsite schedules
• Regular Meetings/Touchbases• Virtual meetings with video
8/25/2020 © 2020 MRO. All rights reserved. 39
Tips and Takeaways
8/25/2020 © 2020 MRO. All rights reserved. 40
7 Things to Remember
1. HIPAA STILL APPLIES! It’s relaxed, not gone.
2. Review/analyze current workflows/benchmarks and adjust as needed
3. Create/review/update new policies and procedures as needed.
4. Educate and train (staff and patients).
5. Implement CDC recommended hygiene guidelines into new workflows and the workforce environment.
6. Communicate!
7. Stay current!
8/25/2020 © 2020 MRO. All rights reserved. 41
Thank You!
Angela Rose, MHA, RHIA, CHPS, FAHIMAVice President, Implementation Services and Corporate Policy
MRO Corporation [email protected]
Office: 610-994-7500 x324Twitter: @adrose1014
LinkedIn: https://www.linkedin.com/in/angeladrose7/
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGBVice President, Privacy, Compliance, HIM Policy
MRO Corporation [email protected]
Office: 610-994-7500 x526LinkedIn: https://www.linkedin.com/in/rita-bowen-
74206012/
8/25/2020 © 2020 MRO. All rights reserved. 42
Questions?
8/25/2020 © 2020 MRO. All rights reserved. 43
MRO 2020 Webinar Series• HIM Workforce Training: Developing an Engaged Team
• Mariela Twiggs, Senior Director of Motivation and Development
• Wednesday, September 16, 2020 at 2pm EST
• https://info.mrocorp.com/webinar/2020/pt2
• Security in a Virtual Environment: Protecting Your Workforce at Home • Anthony Murray, Chief Information Officer and Angela Rose, Vice President of
Implementation Services and Corporate Policy
• Wednesday, October 21, 2020 at 2pm EST
• https://info.mrocorp.com/webinar/2020/pt3
• Information Blocking Rule: The Impact to HIM • Rita Bowen, Vice President of Privacy, Compliance and HIM Policy
• Wednesday, November 18, 2020 at 2pm EST
• https://info.mrocorp.com/webinar/2020/pt4
8/25/2020 © 2020 MRO. All rights reserved. 44
Resources
8/25/2020 © 2020 MRO. All rights reserved. 45
COVID-19 Resources
• Office for Civil Rights Coronavirus Homepage https://www.hhs.gov/hipaa/for-professionals/special-topics/hipaa-covid19/index.html
• HHS/OCR Bulletin: HIPAA Privacy and Novel Coronavirus
https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf
• COVID-19 & HIPAA Bulletin: Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency
https://www.hhs.gov/sites/default/files/hipaa-and-covid-19-limited-hipaa-waiver-bulletin-508.pdf
• HHS/OCR Bulletin: Civil Rights, HIPAA< and the Coronavirus Disease 2019 (COVID-19)
https://www.hhs.gov/sites/default/files/ocr-bulletin-3-28-20.pdf?language=es
8/25/2020 © 2020 MRO. All rights reserved. 46
HHS/OCR and HIPAA
COVID-19 Resources
• COVID-19 and HIPAA: Disclosures to law enforcement, paramedics, other first responders and public health authorities https://www.hhs.gov/sites/default/files/covid-19-hipaa-and-first-responders-508.pdf
• Notification of Enforcement Discretion to Allow Uses and Disclosures of PHI by Business Associates for Public Health and Health Oversight Activities During COVID-19 Nationwide Public Health Emergencyhttps://www.hhs.gov/sites/default/files/notification-enforcement-discretion-hipaa.pdf
• OCR Guidance on Media Access to PHI about Individuals in their Facilities https://www.hhs.gov/sites/default/files/guidance-on-media-and-film-crews-access-to-phi.pdf
• OCR Guidance on Providers Contacting Former COVID-19 Patients about Blood and Plasma
Donations
https://www.hhs.gov/sites/default/files/guidance-on-hipaa-and-contacting-former-covid-19-patients-
about-blood-and-plasma-donation.pdf
8/25/2020 © 2020 MRO. All rights reserved. 47
HHS/OCR
COVID-19 Resources
• COVID-19 and HIPAA: Disclosures to law enforcement, paramedics, other first responders and public health authorities
https://www.hhs.gov/sites/default/files/covid-19-hipaa-and-first-responders-508.pdf
• Notification of Enforcement Discretion to Allow Uses and Disclosures of PHI by Business Associates for
Public Health and Health Oversight Activities During COVID-19 Nationwide Public Health Emergency
https://www.hhs.gov/sites/default/files/notification-enforcement-discretion-hipaa.pdf
• CMS Flexibilities to Fight COVID-19 – What Providers Need to Know About Medical Record Requests
https://www.cms.gov/files/document/covid-ma-and-part-d.pdf
• CMS to Resume Medicare Audits August 3
https://www.vgm.com/webres/File/usrehab/FINAL%20Provider%20Burden%20FAQs%2007_06_20(1).pdf
8/25/2020 © 2020 MRO. All rights reserved. 48
HHS/OCR and CMS
COVID-19 Resources
• FAQs on Telehealth and HIPAA During the COVID-19 Nationwide Public Health Emergency: https://www.hhs.gov/sites/default/files/telehealth-faqs-508.pdf
• Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergencyhttps://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html
• New! HHS Telehealth Online Resource Center: http://www.telehealth.hhs.gov/
• HealthIT.gov has technical assistance on telehealth: https://www.healthit.gov/telehealth
• House Telehealth Leaders Move to Cement Regulatory Changes for Virtual Care
https://www.fiercehealthcare.com/tech/house-telehealth-leaders-move-to-cement-regulatory-changes-for-virtual-care
• CMS Telemedicine Billing Decision Tree: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf
• Telehealth and the HIM Professional’s Rolehttps://www.healthcareittoday.com/2020/07/30/telehealth-and-the-him-professionals-role-relaxing-of-rules-for-telehealth-services-due-to-covid-19-requires-strong-leadership/
8/25/2020 © 2020 MRO. All rights reserved. 49
Telehealth Resources
COVID-19 Resources
• CDC Coronavirus Homepagehttps://www.cdc.gov/coronavirus/2019-ncov/index.html
• COVID-19 Policy Tracker (information broken out by state)https://www.multistate.us/pages/covid-19-policy-tracker
• Cybersecurity & Infrastructure Security Agency (CISA)
https://www.cisa.gov/coronavirus
• FBI Coronavirus Homepage - Urges Vigilance During COVID-19 Pandemic https://www.fbi.gov/coronavirus
• HealthIT.gov has technical assistance on telehealth https://www.healthit.gov/telehealth
8/25/2020 © 2020 MRO. All rights reserved. 50
General Resources
OCR HIPAA Resources
• HIPAA and Public Health https://www.hhs.gov/hipaa/for-professionals/special-topics/public-health/index.html
• HIPAA Privacy Rule
https://www.hhs.gov/hipaa/for-professionals/privacy/index.html
• Guidance on BAAs, including sample BAA provisions
https://www.hhs.gov/hipaa/for-professionals/covered-entities/sample-
business-associate-agreement-provisions/index.html.
• HIPAA Security Rule safeguards https://www.hhs.gov/hipaa/for-professionals/security/guidance/index.html
• HIPAA for Professionals
https://www.hhs.gov/hipaa/for-professionals/
8/25/2020 © 2020 MRO. All rights reserved. 51
Other Resources
• SAMHSA Title 42 CFR Part 2
https://www.govinfo.gov/content/pkg/FR-2020-07-15/pdf/2020-14675.pdf
• MRO Information Blocking Webinar Series
https://info.mrocorp.com/webinar/info-blocking
• Business Continuity of PHI Disclosure Management During COVID-19
https://mrocorp.com/business-continuity-of-phi-disclosure-management-during-covid-19/
8/25/2020 © 2020 MRO. All rights reserved. 52