Category Archives: Policy

HIPAA Omnibus Final Rule

bbbWhat physician practices must comply before deadline?

HIPAA Omnibus Final Rule has made several modifications to the privacy, security and enforcement rule which is ensuring confidentiality and security of the health data of patients across the United States since its enactment almost fifteen years ago. Since then, a number of changes and amendments have been made to the rule and the modifications made earlier this year have been termed ‘omnibus’ which is an indication of combining all the amendments and finalizing the rule. The rule obligates physicians and healthcare providers to vehemently safeguard the privacy of their patients health information and has recently extended this obligation to ‘Business Associates’ as well.

The United States Department of Health and Human Services (HHS) summarizes the 500 pages that encompass the Omnibus rule and highlights the modifications that physician practices are obligated to,

  1. Make Business Associates of Covered Entities directly liable for compliance with certain HIPAA Privacy and Security Rules’ requirements.
  2. Strengthen the limitations on the use and disclosure of protected health information for marketing and fundraising purposes, and prohibit the sale of protected health information without individual authorization.
  3. Expand individuals’ rights to receive electronic copies of their health information and to restrict disclosures to a health plan concerning treatment for which the individual has paid out of pocket in full.
  4. Require modifications to, and redistribution of, a covered entity’s notice of privacy practices.
  5. Modify the individual authorization and other requirements to facilitate research and disclosure of child immunization proof to schools, and to enable access to decedent information by family members or others.
  6. Adopt the additional HITECH Act enhancements to the Enforcement Rule not previously adopted in the October 30, 2009, interim final rule, such as the provisions addressing enforcement of noncompliance with the HIPAA Rules due to willful neglect.

Physician practices need to implement and comply with the HIPAA Omnibus Final Rule requirements before the September 23, 2013 deadline and according to The American Medical Association (AMA), there are three areas that they need to focus on:

1. Privacy, Security, and Breach Notification policies and procedures

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If there is a breach of Protected Health Information (PHI), physicians first have to perform a risk analysis that denotes how sensitive the health data was and the extent of damage incurred from a financial or clinical perspective. Then, they must notify the patients that the security of their PHIs have been compromised.

Moreover, physicians cannot disclose details of their patients health plan to third parties containing details about the services that the patient paid out-of-pocket.

Although physicians can give their patients gifts of nominal value, they may not promote a specific brand or product as if marketing it.

Physicians are not permitted to sell PHIs to a third party for any type of financial gains in the absence of the patient’s written authorization.

If a patient requests a copy of their health records, physicians have to respond to the request within 30 days and must provide it in mutually agreeable formats.

2. Notice of Privacy Practices (NPP)

Physicians are required to revise Notice of Privacy Practices (NPP) and provide them to patients through their website or distribute in print form, making necessary changes in the light of the Omnibus rule (breach notification, disclosures of PHI or health plans etc.)

3. Business Associate (BA) Agreements

If physician practices are utilizing services performed by third parties for the handling of PHIs, such as for health information exchange, data storage or e-Prescribing, they are termed as ‘Business Associates’ in the Omnibus rule. Physicians are responsible for the actions of their Business Associates as well as Subcontractors and require them to meet the HIPAA security standards.  Physicians should review and renew their agreements with BAs, in the light of the HIPAA Omnibus final rule.

A copy of HIPAA Omnibus Final Rule is available here.

5 Best Practices for Meaningful Use of EHR

Trainings and tutorials are okay to start with when attempting to learn something new, especially when it comes to learning a software application. However, some prefer the learning approach of learning by doing. Take for instance, learning to drive a car, one can read a hundred web pages explaining the process of driving a car that is loaded with tips & tricks, but one cannot get the true gist of driving a car by watching thousands of videos. Learning to drive is a physical learning process that starts by putting your hands on the steering wheel. Only then can a set of standard practices be put to the test and give hands on experience of feeling the road and how the car handles.

Learning the meaningful use of EHRs is complicated when a majority of providers have switched from a paper based practice to an EHR system and are first time users of this type of software application. Although, basic functionalities and flow of an EHR system can be learnt in a few days, however the complete adoption and competent use can take up to a few months.

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To expedite this learning process, I have narrowed down a list of best practices that are important to perfect not only for a successful EHR adoption but would help to qualify for the Meaningful Use incentive program.

  1. Make sure that you are using a certified EHR system
    1. Keep the EHR system updated
    2. Complete patient visit documentation and sign off the clinical note
    3. Do not skip required fields
    4. Do not override medication/allergy alerts casually
    5. Do not leave the tasks half finished otherwise you would lose the thread and forget.
    6. Do not copy paste patient notes
  2. Know your Meaningful Use stage timeline and its requirements
    1. Stay informed about Meaningful Use program timeline, updates and developments
    2. Measure your meaningful use progress on a weekly, bi-weekly, monthly basis
    3. Before attestation, 80% of your patients must have records in the EHR
  3. Ensure security of patients’ health records
    1. Make data backups for emergencies and have a disaster recovery plan
    2. Make sure that your practice is following HIPAA compliant security protocols
    3. EHR logins should be protected with strong passwords
    4. Encrypt EHR data before sharing
    5. Do not share EHR login passwords, every user should have a unique login ID
    6. Avoid copying EHR data on flash drives and other portable devices
    7. Disallow a remote access to your network
    8. Do not forget to forbid a former employee’s access
    9. Do not share patients’ health information on social networks
    10. PHI if printed should be properly disposed of when not required
  4. Train entire staff for a meaningful EHR use
    1. Don’t try to handle everything alone
    2. Involve everyone from the front desk staff to the IT department in the EHR implementation
    3. Provide extensive training on how to fulfill the MU measures and objectives
    4. Involve professionals for billing and managing accounts receivable
  5. Run an internal EHR audit
    1. Compile an internal EHR audit checklist
    2. Be prepared for a CMS audit of the EHR incentive program
    3. When you successfully attest, ensure that the Confirmation Page, Summary Attestation Report, and the providers MU Tracking Information is saved and printed out to show proof.

Read also : Top 10 Tips to Make EMR / EHR Implementation Process a Success and EHR implementation process: Key variables.

Meaningful Use Stage 3 and its cherished outcomes

Meaningful Use Stage 3 dubbed as “Improved Outcomes” is set to bring tangible results by improving quality, safety, efficiency and reducing health disparities. In addition to those results, the healthcare community will be more engaged in improving population and public health, privacy and security protections for personal health information, and better care coordination by engaging patients and their families in the care process.

The MU Stage 3 proposed measures and objectives have been recently extended to all the stakeholders in healthcare for comments and suggestions. As scheduled, the Health Information Technology Policy Committee (HITPC) will review the suggestions and comments at its public meetings in the first quarter of 2013.

According to the Meaningful Use Stage 3 proposed draft released by the Office of the National Coordinator for Health Information (ONC), the Stage 3 vision includes a collaborative model of care with shared responsibility and accountability, building upon the Stage 1 and Stage 2 rules.

[SequelMed blog has kept its readers informed through webinars and insightful reviews of Stage 1 and Stage 2 of the Meaningful Use program.]

The Meaningful Use Stage 3 proposed objectives and measures have been conceived over the foundational objectives of the meaningful use program. To improve the outcomes, HITPC suggests that HHS add to the EHR certification criteria the ability to consume an externally supplied list of “never” DDIs, track CDS triggers and functionality to help maintain an up-to-date problem list. Similarly, suggestions on how to implement drug formulary checks in EHRs and incorporate clinical lab-test results into EHR as structured data and create patient-oriented dashboards. The Workgroup has also recommended that certified EHRs should be capable of receiving imaging results consisting of the image itself and other accompanying information. Moreover, comments and suggestions are required over standardization of patient-generated health information.

For the betterment of the population and public health, HITPC proposes that EHR should be capable of keeping track of a patient’s immunization history and electronically sending standardized Healthcare Associated Infection (HAI) reports to the National Healthcare Safety Network (NHSN). Similarly, the ability to shift patients’ records from one EHR to another vendor’s EHR.

SequelMed’s EHR system is already demonstrating quality outcomes through its ever-evolving interfaces. The system meets all the requirements of Meaningful Use criteria and is fully compliant with the HIPAA privacy rule. It seamlessly works with patient portal and all other practice management programs that involved the sharing of data, files and patient health records with labs, pharmacies and referring physicians. Read testimonials from real users here.

2014 brings the transition of ICD-10 and Stage 2 Meaningful Use. What’s a provider to do?

Perhaps a saving grace is the fact that for 2014 only, all providers regardless of their stage of Meaningful Use are only required to demonstrate meaningful use for a three-month EHR reporting period during a fixed quarter. Meanwhile, for ICD-10, providers have to jump in wholeheartedly from day one and adopt the revamped 25-year-old code set. Since both transitions were delayed by a year to 2014, it would be advisable for providers to stay on the course as if there were no delay. By continuing as if nothing happened, providers can allow themselves more time to best determine the effort required to implement and be compliant for both transitions.

ICD-10 has five times as many codes as ICD-9, so the implementation will affect a great deal of stakeholders and processes throughout medical practices. To make the transition more pressing, if a provider is not ready when the ICD-10 transition hits, there will be financial repercussions as submitted services are delayed or even denied for payment.

For providers who have been working on their Meaningful Use compliancy come 2014 will have new measures, objectives, and thresholds to meet for Stage 2. Any provider who is starting later does not have to jump right in to Stage 2 since Eligible Professionals who are new to Meaningful Use are allotted two years for each Stage, therefore starting with Stage 1. However, after they attest, they will find in the mail an incentive check that is $6,000 less than what they could have received should they have started in either 2011 or 2012. Along with a lower reimbursement value, the practice will realize that they have been missing out on certain practice efficiencies. Due to their delayed adoption, they have compromised prescribing, registry reporting, transitions in care, medical records management, transcriptions and the sharing of data. In addition to the lower reimbursement, penalties and hardship exemptions are defined. CMS established October 1, 2014 as the latest date by which an EP can attest for the first time and avoid a 1% payment adjustment in 2015.

Needless to say, providers must prepare for the double whammy of transitions that are ICD-10 and Stage 2 Meaningful Use.

MU Stage 2 Final Rule | Nutshell Review

Meaningful Use Stage 2 Final Rule came to limelight with a focus on patient safety, population health, efficient use of medical resources, patient and family engagement and coordination in the care process.

The final rule is a sequel to proposed recommendations on Stage 2 of Meaningful Use released earlier. A 60-days period was dedicated for comments on Meaningful Use Stage 2 recommendations and then CMS sent it to the Office of Management and Budget (OMB) for the final approval.

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In the finalized version nearly all of the Stage 1 core and menu objectives that were proposed are being finalized for Stage 2. A couple of objectives are replaced, such as; “exchange of key clinical information” core objective from Stage 1 is replaced by “transitions of care” core objective in Stage 2. Similarly, “Provide patients with an electronic copy of their health information” objective is also eliminated because it was replaced by the “electronic/online access” core objective.

There will be 20 measures for EPs (17 core and 3 of 6 menu) and 19 measures for eligible hospitals and CAHs (16 core and 3 of 6 menu).

CMS finalized two new core adjectives (1) Provide patients online access to view, download and transmit health information. (2) Use secure electronic messaging to communicate with patients on relevant health information.

To encourage health information exchange between providers, CMS has included 2 measures for this objective. (1) Providers must send a summary of care record for more than 50 percent of transitions of care and referrals. (2) Providers must electronically transmit a summary of care for more than 10 percent of transitions of care and referrals and at least one instance of exchange with a provider using EHR technology designed by a different EHR vendor or with a CMS-designated EHR.

On Clinical Quality Measures (CQMs), CMS finalized that EPs must report on 9 out of 64 total clinical quality measures (CQMs) and eligible hospitals and CAHs must report on 16 out of 29 CQMs. Moreover, these CQMs must be selected from at least 3 of the 6 key health care policy domains namely: patient and family engagement, patient safety, care coordination, population and public health, efficient use of healthcare resources, clinical processes/effectiveness.

The approved version of the MU Stage 2 final rule comprises 672 pages (which will begin as early as 2014) is focused on “increasing health information exchange between providers” and “promoting patient engagement by giving patients secure online access to their health information”.

In the wake of Meaningful Use stage 2 final rule release, we are receiving mixed reactions via email and through direct messages. To some providers the requirements for stage 2 are “more demanding” in terms of health information exchange and patient engagement but the extended time-frame is quite a relief for many.purchase viagra new zealand