Q: Rural health clinics have to start to bill all services on individual lines with HCPCS codes and charges. Is there a way to report these services on a separate line without the appearance of inflating our charges?
Do you recall the recent humorous television commercial for phone services that featured children who wanted more and tried to explain why? The core message was that more isn't always better. I believe there are many applications of this principle in healthcare. To understand why this is the case, since large evolves from small, you might have to engage your sense of recall to visualize the past compared to the present. We'll look at some examples below.
Big (bad?) data
For all the talk about population health and big data, there is less discussion about data integrity, a key principle in data usage. Anyone who has worked with the most basic of databases, the master patient index, knows how many errors occur in collecting up-front patient access data. Errors still abound in duplicate medical record and account data. How can any of the data associated with these accounts be considered valid and worthy of basing conclusions upon? How confident are we, really, in our interpretation of this data?
For example, comparative MedPAR data will not display ICD-10-CM/PCS data until at least 18 months after ICD-10 implementation. There is no way to measure if we are undercoding, overcoding, erroneously coding, or problematically grouping any cases until we have enough data to make some judgments. Even then, the only true audit is one that compares the collected data with the source documents (in this case, the medical record). Organizations must conduct multiple rounds of these audits before findings can even be discussed.
The best approach is to begin your own audit of small segments (e.g., most common, most at risk) of diagnoses and procedures rather than waiting until the MedPAR data arrives. Be aware that if you are looking at any comparison databases, there is likely a crudely mapped comparison going on between ICD-9 databases (and ICD-10). As we all know, comparisons are not possible in all cases, and the more cross-mapping we do, the less granularly correct the comparison outcome data is, which decreases the validity of the universe of data.
In HIM, there are other data quality issues that have an unknown impact on integrity comparisons. For example, are we comparing apples to apples for sites that are using computer-assisted coding applications versus those that are not? Is it fair to compare outsourced coding with in-house coding? In a recent study conducted for a client, I observed that the time for coding of outsourced cases was dropping in a direct ratio to the case mix. Are we gaining productivity but sacrificing quality and reimbursement potential?
The number of drug overdoses related to opioids has more than quadrupled in the U.S. since 1999, according to the National Institute on Drug Abuse (NIDA). As of 2014, some 2.5 million Americans were thought to have a substance abuse disorder related to prescription opioid painkillers or heroin?and they're coming into hospitals where case managers are increasingly being called on to manage their care.
"The substance abuse epidemic seems exactly like that, an epidemic, with the numbers of patients suffering from substance abuse growing, with many presenting to the hospitals with serious overdoses and/or medical complications of their drug habits," says June Stark, RN, BSN, MEd, director of care coordination at St. Elizabeth's Medical Center-Steward Healthcare in Boston.
Scarce resources and the complex needs of these patients make helping patients with opioid addictions a challenge. Not only do case managers need to manage the challenges and social issues that go along with addiction, such as homelessness and lack of family connections, but they may also struggle to find placements for patients?there just aren't enough beds out there, Stark says, a possible side effect of years of cutbacks and reductions in these types of care options.
While in the past, many patients came into St. Elizabeth's Comprehensive Addictions Program suffering from alcohol dependence, today there's been a huge increase in individuals abusing prescriptions and other opiates, says Mary Ellen Peters, RN, BSN, CARN, a substance abuse case manager at St. Elizabeth's Medical Center in Boston. The growing number of opioid users and the increased publicity surrounding this issue has prompted more people to come in and seek help, she says.
In Massachusetts, you can't pick up a newspaper without hearing stories of struggles with addiction and the community's effort to get ahead of the crisis, says Peters. Even police departments are changing their approach, arming police officers and first responders with a lifesaving opioid overdose-reversal treatment, Narcan. The Gloucester (MA) Police Department is not only using Narcan, but has publicly changed its focus to trying to get people treatment, not jail time, says Peters.
While some changes are in the works that may help future case management efforts, today's case managers still face major challenges. Peters says they manage these challenges by taking a multi-pronged approach to address patient needs, consisting of:
A thorough assessment
Community referrals for follow-up care
Reaching out to family members for support
A focus on reversing social issues, which provide barriers to recovery
Subpoenas are a sometimes-unwelcome fact of life for privacy officers. They can be complicated, requesting broad amounts of information that is time-consuming to gather. They can be written in dense legal language that takes time and finesse to decipher. If a subpoena requests PHI, it can also raise privacy concerns and questions about how to honor the subpoena while releasing only the necessary information. Some subpoenas may request information that an organization considers sensitive for other reasons. It can be all too easy to put off dealing with a subpoena until the last minute, then rushing to react without taking the time to really read and understand what it says.
Email encryption, file sharing, and mailbox security
by Chris Apgar, CISSP
Q: We are in the process of building a new office. Would it be HIPAA compliant to have an outside locked mailbox for our general postal mail and therapist paperwork that is dropped off at night? If not, would a mail slot on our front door work better?
A: An outside locked mailbox will suffice to secure incoming mail and therapist paperwork. Ensure that the mailbox is secure and not easily broken into. If the mailbox is secured with a key, it's a good idea to implement a solid key management program so it's known who has a key. Keys should be recovered when an employee resigns or is terminated. If an employee leaves without returning his or her key, it's wise to re-key the lock on the mailbox.
Editor's note
Apgar is president of Apgar & Associates, LLC, in Portland, Oregon. He is also a BOH editorial advisory board member. 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.
Research shows that ethnic and racial minorities may wind up back in the hospital after discharge more often than their white counterparts for certain conditions, such as pneumonia and heart failure. This increased rate of readmissions is due to many factors, including:
A higher incidence of some chronic diseases
Social, economic, cultural, and linguistic barriers to care
CMS is hoping to change that with a new publication, "Guide to Preventing Readmissions Among Racially and Ethnically Diverse Beneficiaries." Its authors said that the guide aims to accomplish three main goals:
Providing an overview of the issues that can lead to higher readmission rates among this group
Outlining actions hospital leaders can take to reduce these avoidable readmissions
Providing case studies and examples of initiatives that have worked to reduce readmissions among racial and ethnically diverse Medicare beneficiaries
