Over-querying is a common concern in CDI. It can influence productivity and workflow. It can cause delays in documentation and coding processes. It can also overwhelm and frustrate physicians, who in turn may be less likely to support or engage with CDI program efforts.
Q: The chief executive officer of the hospital where I work is talking about having our hospital coding done in India. What are the potential ramifications of this plan for our hospital? I know a prominent hospital in Palo Alto, California, was going to do this in 2011.
Have any U.S. hospitals actually outsourced their medical record coding to foreign countries? What are the liability risks? What do we need to be aware of in terms of HIPAA compliance?
A: Yes, many organizations send coding and transcription work overseas. Despite business associate agreements (which you must get with any such vendor, offshore or not), it may be difficult to ensure that these vendors are HIPAA compliant, although one could make the same argument about U.S. vendors as well. Be sure to do your due diligence by carefully checking your vendor's references (and documenting the results) should you choose to go this route. You might also discuss this with your organization's insurance carrier and/or attorney for an assessment of the risks.
Editor's note: Chris Simons, MS, RHIA, the director of health information and privacy officer at Maine General Medical Center in Augusta, answered these questions. Simons is also an HIMB advisory board member. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Send your questions related to HIPAA compliance to Editor Jaclyn Fitzgerald atjfitzgerald@hcpro.com.
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.
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.
The American Hospital Association asked CMS to clarify some aspects of its new outpatient notification requirement, Notice of Observation Treatment and Implication for Care Eligibility Act, which is supposed to go into effect in the summer of 2016.
