Faxing, like many other efforts to protect health information, comes down to basics. Call the recipient to ensure they are near the fax machine. Double- and triple-check fax numbers. Send a cover sheet that clearly addresses to whom the fax is intended. Follow up with a call.
"We try to call the recipient and tell them, 'Hey we're going to fax something to you. If you're at a public fax machine go stand by that machine,' " Wallach says.
Basic stuff, right? But for busy healthcare systems who can send a massive amount of faxes each day, the human error rate is high, says Frank Ruelas, MBA, who serves as principal at HIPAA College in Casa Grande, Arizona, and facility compliance professional at Dignity Health's St. Joseph's Hospital and Medical Center in Phoenix. Ruelas is also a BOH editorial advisory board member.
"Just because you're in a hurry doesn't make it right," says Ruelas. "Do we need something this sophisticated and scientific here? This is a process that should have a really low error rate. Or it should be much lower than it is."
Break down faxing policies into rudimentary steps where employees are comfortable and deploy them, he says.
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.
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?
