Q: I work in a behavioral health hospital and am looking for guidance relating to disclosures as part of the Clozapine REMS Program. In order for a patient to fill a prescription for Clozapine at an outside pharmacy (not our on-site pharmacy), the pharmacy is required to have a copy of the patient's latest blood draw (absolute neutrophil count). Is the patient required to sign a release of information for us to be able to send the latest blood draw results, or is sharing the results with the outside pharmacy considered part of the process when the patient is registered in the Clozapine program?
In addition, if the latest lab results contain more information than what is required for the Clozapine prescription to be filled, should we edit the results to only include what is specifically needed by the pharmacy?
A: Releasing this information is considered treatment, so the patient's authorization is not needed. Editing the results report to release only the neutrophil count would be a good practice, if it is reasonable to do that. If not, it would be acceptable to release the complete results containing the neutrophil count, since the minimum necessary requirement does not apply to treatment disclosures.
Editor's note: This question was answered by Mary Brandt. Brandt is a healthcare consultant specializing in healthcare regulatory compliance and operations improvement. She is also an advisory board member for BOH. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Email your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com.
Is your hospital in one of the 67 geographic areas defined by CMS as a metropolitan statistical area (MSA) and one that CMS has identified to participate in the Comprehensive Care for Joint Replacement (CJR) Model? If so, is your case management department ready? Does your department have the processes and procedures in place for how it will participate in this retrospective bundled payment innovative project for Medicare fee-for-service beneficiaries?
Now that you've had time to recover from the first hectic months of the new year, it's time to focus on what the remainder of the year will bring for case management and some of the biggest challenges that may lie ahead in 2016.
Discharge planning Conditions of Participation changes.Ronald Hirsch, MD, FACP, CHCQM,vice president of the Regulations and Education Group at Accretive Health in Chicago, called CMS' proposed changes to the discharge planning Conditions of Participation (CoPs), which would revamp the discharge planning process, "the bombshell for 2016."
BFFC-QIO audits. In October 2015, Quality Improvement Organizations (QIO) took over the role of education and enforcement for the 2-midnight rule from the Recovery Audit Contractors. In 2016, these Beneficiary and Family Centered Care QIO (BFCC-QIO) audits of short stays will be in full force, says Hirsch.
The new Comprehensive APC for observation patients. CMS approved a new comprehensive APC (C-APC) payment for observation patients for 2016, which provides payment for nonsurgical services provided to patients with an eight-hour or longer observation stay. Any ED-visit level code will qualify for the comprehensive APC code. "The new Comprehensive APC for observation patients means that hospitals need to be more efficient and avoid incidental testing which will no longer be paid," says Hirsch.
One of the last major shifts in coding before the transition to ICD-10 was the introduction of diagnosis-related groups (DRG) in 1982. Now that the struggle to implement ICD-10 has passed, how do the two transitions measure up? Both Wendy Coplan-Gould, RHIA, president of HRS Coding in Baltimore, and Sallee Silverman, RHIA, an AHIMA-approved ICD-10 trainer and a manager with HRS Coding, were actively working in healthcare through both shifts and shared their thoughts with HIM Briefings shortly after ICD-10 went live in October 2015. When DRGs were introduced, Coplan-Gould was working as the associate director of the Maryland Resource Center in Maryland.
by Shannon Newell, RHIA, CCS, AHIMA-approved ICD-10-CM/PCS trainer
Approximately 800 hospitals across the country that perform inpatient total hip and knee joint replacements will be required to participate in the latest value-based payment initiative launched by CMS, the Comprehensive Care for Joint Replacement (CJR) model, which becomes effective April 1.
A recent Healthcare Financial Management Association webinar on the CJR noted it as one of the biggest Medicare changes since the implementation of diagnosis-related groups (DRG). Not surprisingly, various impacted parties continue to push for delays in implementation of the model. The CJR model holds participant hospitals financially accountable for the cost and quality of an episode of care and incentivizes increased coordination of care among hospitals, physicians, and postacute care providers.
The assignment of ICD-10 codes on both inpatient and outpatient claims impacts these outcomes by triggering which discharges are included in the program, the actual (or observed) complication rates for these patients, and?equally important but often overlooked?their risk-adjusted expected complication rates. If ever there was an opportunity for clinical documentation improvement (CDI) programs to step up to support their organizations with documentation that impacts both quality and financial outcomes, this is it!
When the Quality Improvement Organizations (QIO) took over the role of education and enforcement for the 2-midnight rule on October 1, 2015, many anticipated that their reviews would only look at records from that date forward. But in an unpleasant turn of events, some hospitals have reported QIO record requests zeroing in on cases as far back as May 2015, says Ronald Hirsch, MD, FACP, CHCQM, vice president of the Regulations and Education Group for AccretivePAS in Chicago.
"It caught everybody off guard. No one expected them to audit any earlier than October 1," he says. "But audits are starting hot and heavy, and it's important for organizations to understand that it's permitted and that the QIOs can request charts going back six months."
According to a fact sheet, CMS is specifically using "Beneficiary and Family Centered Care (BFCC) QIOs, rather than MACs or Recovery Auditors, to conduct the initial medical reviews of providers who submit claims for short-stay inpatient admissions on October 1, 2015. Beginning in 2016, BFCC-QIOs will begin reviewing inpatient cases under the revised Two Midnight Rule being announced today." (For more information, visit www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-10-30-4.html.)
Another surprise? BFCC-QIOs are requesting charts for inpatient-only surgeries, something they weren't supposed to do, says Hirsch.
