Security officers may sometimes feel that they're asked to do too much with too little. Limitations surrounding staffing, budgets, or resources, or an administration that simply doesn't understand the importance of information security, can make a difficult task even more complicated. In some organizations, information security is a relatively new department and might lack the connections and relationships that more well-established departments rely on for support. Security needs allies. Fortunately, there's one they may already work closely with who is ideally suited: internal auditors.
Submit your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com and we will work with our experts to provide you with the information you need.
Q: Our front desk receptionist has asked the following question regarding residents who are admitted to our long-term care facility. If someone calls the front desk asking for information on a resident, such as "Is (resident) in your facility?" or "What is their room number?", would this information be considered PHI?
A: The answer is not straightforward when it comes to long-term care. It all depends on the care setting. If care is provided in an assisted living facility and the assisted living facility does not provide healthcare services, such as nursing care related to treatment or a clinic on-site, the information is not PHI. On the other hand, if the facility is a skilled nursing facility (SNF) and is providing what HIPAA defines as healthcare, it would be considered PHI. That doesn't mean the receptionist cannot share the information about whether a resident is at the facility or the resident's room number. Similar to a hospital, a long-term care facility could maintain a facilities directory. Unless the resident has specifically requested he or she not be included in the facility directory, you can share whether a resident is at the facility and where the resident is located in the facility. Providing more information would be prohibited. Review the long-term care regulations in the state in your state.
Editor’s note: Chris Apgar, CISSP, president of Apgar and Associates in Portland, Oregon, answered this question. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions.
The Hospital Readmissions Reduction Program is a CMS pay-for-performance program that links the amount hospitals are paid to risk-adjusted readmission rates. Measures included in the program are claims based, which simply means that the ICD-10 codes we submit on our claims for payment are also used to assess our performance; our performance then impacts our payment.
Clinical documentation improvement (CDI) programs are prevalent in many hospitals and have evolved over the years. In 2014, 66% of 318 hospitals surveyed by AHIMA had a CDI program in place. If all surveyed facilities that planned to implement a CDI program did so, 80% of responding hospitals would have one. These numbers are likely even higher today as CDI programs become ever more relevant.
CDI programs can be a valuable bridge between clinical care and coding at hospitals. By concurrently reviewing clinical documentation in medical records and conferring with and educating providers, CDI teams continually support accurate documentation. When CDI program staff collaborate with providers and coders around improved documentation, the result is more accurate coding, reporting, quality metrics, and reimbursement.
Greater detail in clinical documentation is required since the introduction of ICD-10, making CDI efforts even more relevant. In addition, healthcare is steadily moving toward value-based purchasing and greater scrutiny from regulators and the public. With all of this in mind, it is more important than ever to get documentation and coding right. The daily activities surrounding CDI are crucial to successful outcomes and sustainability of facilities and healthcare systems.
The 2016 OPPS final rule includes the first negative payment update for the system. CMS finalized its proposal to reduce the conversion factor by 2% to account for its overestimation of dollars for packaged labs built into the 2014 APC rates, despite congressional and provider pressure to not proceed with this payment reduction.
As we celebrate our 30th year of delivering you the latest in HIM, we would like to invite you to celebrate the HIM profession with us. Each month this year, HIM Briefings (formerly Medical Records Briefing) will include a special feature that highlights the changes to our publication and the HIM profession over the years.
