Q: I work in a behavioral health hospital and am looking for guidance relating to disclosures as part of the Clozapine REMS Program. In order for a patient to fill a prescription for Clozapine at an outside pharmacy (not our on-site pharmacy), the pharmacy is required to have a copy of the patient's latest blood draw (absolute neutrophil count). Is the patient required to sign a release of information for us to be able to send the latest blood draw results, or is sharing the results with the outside pharmacy considered part of the process when the patient is registered in the Clozapine program?
In addition, if the latest lab results contain more information than what is required for the Clozapine prescription to be filled, should we edit the results to only include what is specifically needed by the pharmacy?
A: Releasing this information is considered treatment, so the patient's authorization is not needed. Editing the results report to release only the neutrophil count would be a good practice, if it is reasonable to do that. If not, it would be acceptable to release the complete results containing the neutrophil count, since the minimum necessary requirement does not apply to treatment disclosures.
Editor's note: This question was answered by Mary Brandt. Brandt 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. Email your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com.
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.
