The following is an excerpt from Inpatient-Only Procedures Training Handbook, written by Debbie Mackaman, RHIA, CPCO, CCDS. For more information and to purchase, visit the HCPro Marketplace.
Q: I am a certified case manager working in an acute care hospital. As part of our job requirements, when working in the emergency room (ER), we are asked to problem solve throughout the day. We often get requests for information on patients seen in the ER who have since been discharged.
My HIM career began like many others?in frank conversation with a high school guidance counselor regarding career direction. I wanted to pursue a career in healthcare, but wasn't interested in direct patient care. Focused exploration led me to discover a degree in health information technology at my local college. Now, 30 years later, I'm celebrating a long and successful HIM career.
This column is devoted to restraint and seclusion documentation; it provides support for, and a tool for, 100% review of patients in restraints and/or seclusion.
The Joint Commission and CMS have a common goal of reducing the use of restraints and seclusion in hospitals. Hospitals have come a long way in meeting this goal, and requirements for improvement (RFI) usually are received because of poor documentation in the medical record. Generally, recommendations result from lack of physician orders, physicians not seeing patients on-site, incomplete orders as to the reason for restraints and/or seclusion, and care plans not including the goal to remove patients from restraints and/or seclusion.
Often during surveys, there will be no patients in restraints or seclusion and the surveyors will ask for closed records to review. Once the medical record is closed, little can be done to correct documentation. Therefore, a solid open record review is essential to avoid recommendations.
A process for reviews
Review of open records of patients in restraints and/or seclusion can be performed in several ways. Of utmost importance is the development of a method to identify patients in restraints and seclusion on a daily basis, and to review new and recurring patients until they are discharged. For example:
1.Nurses, clinical documentation specialists, and tracer teams (plus others?) can review medical records each day to ensure documentation compliance
2.If the hospital has an EMR, HIM staff can review open records online to identify discrepancies in documentation and report back to each unit
3.HIM and IT staff can collaborate to develop a method of importing information directly from the EMR to identify documentation errors
Any of these methods should eliminate errors as long as they are corrected as soon as possible before patients are discharged.
Certain phrases just stick with you. The longer you reflect on an idea, the more inspired you are by the ways in which the concept can become relevant to your needs.
As Phase 2 of the HIPAA audit program begins, covered entities (CE) and business associates (BA) will be watching their email for an audit letter from OCR. Of those chosen for audit, most will be selected for a desk audit. They'll have 10 days after receipt of the email to gather requested documents for OCR's auditors.
But how will CEs and BAs know they are collecting the right information? A careful reading of the updated Phase 2 audit protocol (www.hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/protocol/index.html) will help guide CEs and BAs. But if the protocol isn't read carefully, and in full, important documents could easily be left out, leading to inaccurate audit reports and even a visit from OCR's investigators.
The Phase 2 audit protocol expands the Phase 1 compliance areas to reflect changes made by the 2013 HIPAA omnibus final rule. The updated audit protocol also includes information for BAs, which were not audited during Phase 1 but will be in the current round of audits. The protocol contains a description of the audit areas, general instructions and definitions, and a keyword-searchable table.
Phase 2 audits will be conducted in three rounds. The first two rounds will consist of desk audits of specific audit targets, while the third round will be comprehensive audits. Round one audits will target CEs and round two audits will target BAs.
