OCR's long-awaited Phase 2 HIPAA Audit Program is finally in full swing. On March 21, OCR announced that it will begin verifying the contact information of covered entities (CE) and business associates (BA) selected for audits (www.hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/phase2a...). This shouldn't surprise savvy healthcare organizations. The audits kicked off after a flurry of activity from OCR and HHS, including pricey HIPAA settlement fines and the publication of user-friendly HIPAA guidance for providers, developers, and patients.
"Don't click on that link" is a common warning from security officers. That hasn't stopped many staff from clicking on suspicious links that at first glance appear to be valid, and the result can be a significant loss of PHI and other sensitive data. This type of hack, phishing, represents one of the more significant risks when it comes to breaking into networks and stealing data.
The readmission rate is dropping, but are hospitals just doing a quick shuffle--shifting patients from inpatient status to observation services--to make that change happen?
The study "Readmissions, Observation, and the Hospital Readmissions Reduction Program" published in the February 24 issue of the New England Journal of Medicine says that is not the case. The decline in readmissions is real, says the study, and likely in response to the Hospital Readmissions Reduction Program (HRRP), which fines hospitals for excessive readmissions.
CMS implemented the HRRP in 2010 in an effort to save the government money on the $17 million in estimated avoidable costs incurred each year from unnecessary hospital readmissions and to spare patients the poor outcomes that send them back to the hospital after they are discharged home.
The readmission rate has declined since the implementation of HRRP. But at the same time, some pointed to the fact that use of observation services was increasing and wondered if the two were connected. Others questioned whether the HRRP was actually making a difference in readmission rates, which were already on the decline before the program went into place.
The findings of this study validate what some case managers say they knew all along.
"Personally, as a director of case management I have never seen observation status used to avoid the readmission penalty," says June Stark, RN, BSN, MEd, director of care coordination at St. Elizabeth's Medical Center, Steward Healthcare in Boston.
Documentation can be a headache for everyone, from the physicians who have to take precious time away from patients to document in the EHR to the case managers who have to track the physicians down to fill in gaps when information is missing from the medical record.
The case manager plays a crucial role in helping to make sure medical record documentation not only supports billing and coding to ensure accurate reimbursement, but also clearly communicates the patient's condition to the entire clinical team.
It needs to be complete, accurate, succinct, and effective, says Glenn Krauss, BBA, RHIA, CCS, CCS-P, PCS, FCS, CPUR, C-CDI, CCDS, director of enterprise solutions at Zirmed. However, it's often anything but. Krauss says he often comes across documentation that case managers could help clarify, and he recently offered some real-life examples (with details changed to protect patient privacy) to illustrate key points.
Case managers can help resolve common problems found in patient charts, including insufficient clinical information and missing basic information.
Few in the healthcare industry would argue that the way the government currently pays for drugs is the most cost-effective, efficient, and equitable method possible.
