You're reviewing a case file and discover that a patient's recent readmission is due to a medication prescribing error made by a physician. Do you report it?
One thing is certain: You don't want to wait until you receive a notification letter from OCR before you begin preparing for a HIPAA audit, says Dena Boggan, CPC, CMC, CCP, HIPAA privacy/security officer at St. Dominic Jackson (Miss.) Memorial Hospital.
There are six generic approaches to managing risk, and the approach an organization chooses to use will depend on many factors. For example, how real is this risk? Can it actually become a problem, or is it merely theoretical? Management will want to decide whether the risk is likely to happen and whether it is possible to determine when it may happen. This will also assist in appropriate allocation of resources to focus on material risk areas.
CMS has proposed to rescind the requirement for signatures on all lab requisitions, according to the "Medicare Program; Clinical Laboratory Fee Schedule: Signature on Requisition" proposed rule published in the Federal Register June 30. The 2011 Medicare Physician Fee Schedule, published last November, requires a physician's or nonphysician practitioner's (NPP) signature on lab requisitions for tests paid under the clinical lab fee schedule, regardless of whether there is a signed order. This is the opposite of prior CMS rulings that indicated signatures were not required on requisitions, although written and signed orders were required.
If patients were already concerned about healthcare organizations' ability to protect their information, a report released in May did nothing to alleviate their fears.
