Q: We are struggling with how to report the functional status codes that are required when a physical therapist provides therapy services post-operatively. We have a process for doing that for our “regular” therapy patients, but are struggling with how to implement this for the outpatient surgeries.
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.
Q: We recently received a request for a patient's records. The patient transferred to another provider several years ago and we subsequently transferred all the patient's records to the new provider. Should I direct the request to the provider the patient transferred to? I'm unsure that we should be responsible for retrieving and releasing information for this patient since we transferred the patient's entire record to the new provider.
A: If you sent a copy of the patient's records to the new provider and still have the original records, it would be appropriate for you to respond to the request. If you transferred all records to the new provider and no longer have the patient's information, refer the request to the new provider.
Editor's note: Mary Brandt, MBA, RHIA, CHE, CHPS, 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. Opinions expressed are those of the author and do not represent HCPro or ACDIS. Email your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com.
There are no federally recognized HIPAA certification standards for covered entities (CE) and business associates (BA) and it's unlikely one will be. However, that doesn't stop larger CEs from requiring some form of certification to demonstrate compliance with HIPAA and proof that BAs have implemented sound information security programs. The Health Information Trust Alliance (HITRUST) published its first common security framework (CSF) in March 2009 with the goal of focusing on information security as a core pillar of the broad adoption of health information systems and exchanges. Larger CEs, primarily large health plans, now require their BAs to become HITRUST certified.
