10 Release of Information Pitfalls to Avoid in an EMR Environment

1. 10 Release of Information Pitfalls to Avoid in an EMR Environment Presented by Fig GungorCEO

2. Agenda • Introduction - ROI has Changed • 10 ROI Pitfalls to Avoid in Relation to: • Electronic is not Always Effortless • Preserving Security • Providing Reporting Capabilities • Maintaining Data Integrity • Following Labor Cost Guidelines • Updating HIPAA Compliance Policies • Data Breaches • Responding to Meaningful Use Requests • Managing the Business of ROI • Overcoming Common Misconceptions • Summary • Q&A

3. Release of Information has Changed • HITECH Act promoted the adoption of Electronic Medical Record (“EMR”) systems • EMR systems boast benefits but ROI is not their focus • Evaluate how your new EMR, Meaningful Use, Labor Costs and compliance updates could affect your organization’s ROI practices • Take the proper steps to ensure compliance Are you ready?

4. 1. Electronic is not Always Effortless • Challenge: • Hybrid charts • Automatic file retrieval • Loss of tangibility • Increased turnaround time • Employee capabilities • Solution: • Implement a well defined process that guarantees that all elements of the requested chart are included in duplication • Store electronic and paper PHI in a single central location • Train users to identify parts of charts based on naming conventions and image previews

5. 2. Preserving Security • Challenge: • Open access • Vulnerability • Access to unnecessary information • Solution: • Restrict unlimited access to patient’s records • Create and implement user roles • Implement a Disaster Recovery Plan • Create procedural safeguards

6. 3. Providing Reporting Capabilities • Challenge: • Some providers who have implemented EMR’s are struggling to track: • Meaningful Use requests • Accounting of Disclosures • Turnaround time • Cash/self pay • Charts of patients who are involved with litigation • Verbal authorization to release proof of immunization • Incomplete/deficient charts • Payments for records (if applicable) • Solution: • Develop a plan that allows you to track these types of requests • Work with your EMR system provider to tailor the system to your needs

7. 4. Maintaining Data Integrity • Challenge: • Minimum Necessary Standard • Some EMR charts contain information that should not be released: • Medical records, release forms and correspondence documents from other facilities • Internal hospital records • Records of different patients with duplicate medical record numbers • Human error • Lost records • Solution: • Institute strict guidelines for uploading data and processing requests • Work with your EMR vendor to organize how your data is stored • Implement quality review measures • Follow a detailed plan when converting paper charts to digital format

8. 5. Following Labor Cost Guidelines • Challenge: • Labor Costs- Reasonable fee that covers the cost of skilled technical staff time spent creating and copying electronic files • Compiling, extracting, scanning, burning discs, distributing media • Cost of supplies and postage or courier • Can not charge retrieval fee • Eligibility • Eligible: patients, qualified representatives and claimant’s attorneys (with healthcare POA) • Ineligible: defense attorneys, claimant’s attorneys/third parties lacking healthcare POA and insurance companies • Must charge the lower of Labor Costs and State mandated pricing • Solution: • Perform a cost analysis to determine your organization's Labor Costs • Inform your staff of eligibility and guidelines for charging different requestors

9. 6. Updating HIPAA Compliance Policies • Challenge: • Compliance Policy • Documented policy that outlines the steps taken by an organization to ensure a diligent attempt to protect the privacy and security of patient records • Must dictate how the organization will react to a breach • Risk Analysis • Designate officers • Encryption • New BA Agreement- Equally as liable as Covered Entities • Solution: • Consult with experts to build a program that complies with the standards set forth by HITECH • Distribute policy to employees • Follow policy

10. 7. Data Breaches • Challenge: • Breach - “Generally, an impermissible use or disclosure under the Privacy Rule that compromises the security or privacy of the protected health information.” • Breach response process • Investigate and document incident • Risk Assessment - Determine threat, if any, to patients • Breach notification requirements • Review and update protocols, procedures and policies to mitigate future risk • Solution: • Implement detailed Breach Policy • Designate an Incident Response team/lead

11. 8. Responding to Meaningful Use Requests • Challenge: • Meaningful Use -When the requested records exist on an EMR system and the records are requested to be delivered in electronic format, you must respond to the request within 3 days • Solution: • Qualifications -Familiarize yourself and your staff • Patient or qualified requestor submit written or oral request • Fully electronic records (not paper or hybrid) • Records delivered in electronic format • Outlined process -Develop and follow a plan • Screen mail • Determine if request meets Meaningful Use criteria • Document in EMR system • Process request • Burn to encrypted disc or use other encrypted transfer • Mail encrypted disc or arrange pick up • If records are unavailable, the patient must be notified within 3 days

12. 9. Managing the Business of ROI • Challenge: • Staffing • Billing • Status request calls and correspondence • Release of records • Track completed requests • Solution: • Implement a comprehensive ROI practice that encompasses the issues • mentioned throughout this presentation • Highly skilled and knowledgeable of industry guidelines • Appropriate for volume • Allows your facility to meet the restrictive guidelines established by HITECH and Meaningful Use • Implement a system to generate invoices at proper rates, monitor payments • Quality assurance - check files & authorizations • Encryption • Tracking

13. 10.Overcoming Common Misconceptions • Challenge: • HIM staff can be reduced because of EMR systems • All other systems are up to speed with EMR system • Once the EMR system is rolled out, the job is done • Solution: • Prepare for EMR system transition: • An implemented EMR system requires: • Upgrades • Training • User management • Physician Adoption • Staff your department appropriately • Consider temporary staff or outsourcing • Improve imaging systems, billing systems, administrative scheduling systems etc…

14. Summary • HITECH and Meaningful Use aim to maximize patient care • Implementing an EMR system is a tool to realize that goal, not the goal itself • Providers must consider the unintended downstream effects when choosing their EMR system and make the necessary changes to their procedures and policies to comply with recent rulings • www.onesourcedoc.com/hitech

15. Questions/Comments