Observation hours start accruing not when the patient comes into the hospital, but when the physician writes the order for observation. Observation hours end when all medically neces¬sary services related to observation are complete.
Q: What recommendations do you have for handling medical records for staff members who are also patients at the organization where they work? Should we provide extra protection for these patients? What can we do to ensure that staff members are not accessing their coworkers' records without permission or need?
A: I am a firm believer in not adding special protection to any record, because it implies that some records are more confidential than others. In fact, all records are confidential and staff should not access any record unless it is necessary to do so to do their jobs. And, if it is necessary, they should only access the minimum necessary to do the job. HIPAA requires access monitoring, so your organization should conduct routine audits to determine whether staff are accessing records without a work-related reason. There is now software available that can conduct routine audits by staff member and department. This software can be used to reassure staff that their information is not being accessed by coworkers and to hold accountable those who are not following the policy/law. When a staff member raises a concern, an audit should be run to determine whether inappropriate access has occurred, and if it has, sanctions should be applied. Organizations should also consider having a policy that staff should not handle coworkers' (or family members') records (except in an emergency) without the permission of their supervisor.
All of these points should be reviewed at orientation and during (at minimum) annual training to ensure all staff understand that the organization takes such transgressions seriously and will take action as needed to protect the privacy of every patient's information.
While the 2017 OPPS proposed rule includes a variety of tweaks and augmentations to existing regulations, its biggest impact is likely to come from its proposal to implement Section 603 provisions of the Bipartisan Budget Act of 2015 regarding off-campus, provider-based departments (PBD) and move toward more site-neutral payment policies.
CMS wants your thoughts on its 2017 OPPS proposed changes. In various places in the proposed rule, CMS specifically asks providers to comment on the proposals. You may submit comments to the agency until September 6, 2016.
CMS released the 2017 OPPS proposed rule on July 5 without much fanfare. On July 14, the Federal Register version was posted, and upon initial review, it seems rather short at 186 pages.
CMS’ proposed changes to implement Section 603 of the Bipartisan Budget Act of 2015 would reshape payments for off-campus, provider-based departments (PBD) if finalized and represent the most significant changes in the calendar year (CY) 2017 OPPS proposed rule.
