A business case for resourcing a compliance assurance program for privacy and security should be possible solely on the basis of the need to respond to complaints made directly to a covered entity (CE) (or business associate (BA) acting as an agent of a CE). However, despite stepped-up enforcement and periodic audits required by HITECH, industry experts still anticipate that a more proactive process for compliance may not be taken until an untoward event occurs. Consequently, other avenues for substantiating the importance of privacy and security measures are necessary and readily available. Information privacy and security officials may find it necessary to go beyond information about HIPAA Privacy and Security Rule enforcement in making the business case. Monitoring the general security industry and relating those risks to healthcare privacy and security are important when doing so. Consider the following:
While organizations should focus on performing regular risk assessments and analyses, there are also other ways in which they must review their systems for compliance. Often, these other evaluations are overlooked despite their value, says Kevin Beaver, CISSP, an information security consultant in Atlanta. In particular, organizations should be careful not to forget about performing vulnerability assessments and penetration tests, which are components of an overall risk assessment or analysis, says Beaver, who is an editorial advisory board member for SHCC's sister publication Briefings on HIPAA.
Q: My facility no longer registers patients under aliases, but will allow them to opt out of the patient directory. However, opting out of the registry will not exclude our patients from the operating room (OR) list. At one time, the facility's CEO received the daily OR list with full patient names so he could visit board members, donors, or others whom he knows at our facility. HIM changed this practice so that patients' names would not be on the OR schedule provided to the CEO. The CEO took this matter to the hospital attorney, who said the names could be included because the use of PHI by the CEO to determine whether and when a patient visit is appropriate is permitted by HIPAA as it is part of healthcare operations. Is it a violation of HIPAA for the CEO to use PHI to track patients in this manner?
Coronary artery bypass graft (CABG) procedures are not the only ones coders will report using the root operation bypass in ICD-10-PCS. Surgeons can create bypasses in other vessels of the body.
Inpatient coding professionals are used to DRG systems where all of the diagnoses and procedures map to a single DRG. So they may not look for additional procedures and services to report outside of that DRG.
RC.01.01.01, Content of the Medical Record, did not top the list of survey findings for hospitals in the first half of 2014, according to the September 2014 issue of Joint Commission Perspectives. Nor was it on the list for critical access hospitals at all! However, 49% of hospitals surveyed received a requirement for improvement for this standard, primarily in the EPs related to timing and dating entries. This indicates hospitals are still using a lot of paper records. That said, the downward swing is encouraging as more and more hospitals fully implement the EMR.
