You should know this:  Policies and Procedures and Documentation Requirements are part of the Final Rule; and in paraphrasing CFR 164.316(a) you MUST maintain site specific policies and procedures documentation that defines how your organization will comply with HIPAA security policies. Furthermore, CFR 164.316(b)(1) states you must maintain written policies and a record of the action, activity, or assessment.

Do you have written policies to comply with the new standards?  Do not worry if you don’t because many practices do not – YET!

There is HELP here for you…

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1. Your Policies and Procedures Are Incomplete If They Don’t Include a Security Risk Management Process
2. Know Your Medical Practice Risks – Meaningful Use 15
3. Meaningful Use Tip to Recording a Problem List

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1. February 29, 2012 is Last Day to Submit Meaningful Use Data for Stage 1

RM:  Jackie, can you describe for me what BACTES Imaging does?

JA:  BACTES Imaging brings real value to your practice by mitigating HiTECH risk, maximizing resources and saving money. It is a really unique time right now with Meaningful Use and ICD-10- Practice Managers are busier than they have ever been! We have two main specialties that Practice Managers just love.  They are Release of Information (ROI) and EMR Scanning and Conversions.

RM:  Can you describe your ROI services?

JA:  As you know, doctors’ offices are overloaded with requests for information from attorneys, insurance companies, other doctors’ offices and patients. Reading through each request to ensure they meet compliance regulations and are fulfilled in a timely manner is very time-consuming. We can take over that responsibility fully. We come into your office once a week to review your requests, obtain the records and fulfill the request. We can also fulfill the requests off-site in a secure, centralized location in Orlando.  Best of all, this service is completely free to the doctor. We’re paid by the office requesting the information.

RM:  Wow, that’s a great service. I know a lot of Practice Managers who would really love to outsource their Release of Information requests. What kind of risk is there in hiring a company like BACTES to fulfill these requests?

JA:  Now is a great time to outsource ROI.  HIPAA and HiTECH compliance is complex. The new HiTECH regulations have really ratcheted up.  BACTES is considered a ‘business associate’ under HIPAA rules. We sign a business associate agreement under the newest HiTECH regulations umbrella, which means we share in the liability should anything go wrong. But, our quality control is unparalleled.

RM:  Tell me more about your quality control measures.

JA:  Sure. Before a medical record is sent out, it goes through 5 levels of quality control to make sure everything is correct. We ensure that we have the correct patient name, the correct data service and the correct address for the requestor before a record is sent out the door. We can really help Practice Managers optimize their resources by focusing on what they do best and outsourcing the rest to trusted, high quality service providers.

RM:  That sounds great. Let’s talk about your EMR scanning and conversion services.  Do you do that onsite at the doctors’ office?

JA:  Actually, we can do the conversion either onsite or remotely at our Orlando Service Center.  We can digitize paper charts, and upload to any EMR system. In fact we work with hundreds of different EMR systems. EMR conversions are very labor-intensive for doctors’ offices. Not only are your team members doing their old jobs, but now they’re learning an EMR system and beginning to enter new data into the EMR. Additionally, if the office is converting all of their old paper records to the EMR system, then the team is adding paper scanning to their already stretched resources. This increases the possibility of making mistakes. BACTES specializes in these conversions and can focus all of our resources on ensuring that records are converted properly and adhere to all compliance regulations.

RM:  What does this service cost?

JA:  Cost is dependent on the number of records involved in the conversion. But, if you consider the cost of hiring temporary staff to handle the conversion or paying overtime to your existing team, providing training plus the cost of equipment, outsourcing your conversion makes a lot of sense. According to the MGMA, over 50% of EMR implementations fail. We help you make sure you do it right the first time.

RM:  What kinds of controls are in place to ensure the quality of the EMR conversion?

JA:  Again, we have the highest quality control measures for our EMR conversion process. We can help determine what charts to scan, what portion of a chart to scan and when to scan it. All charts are bar coded and tracked throughout the process. We have several sets of eyes doing quality control.

RM:  How long does an EMR conversion take?

JA:  The length of time involved depends on the number of records to convert and the size of the office.  We have worked with all sizes of offices ranging from single doctor offices up to multi-office conversions. We handle all of it locally at our Orlando Service Center. We can pick up records weekly and take them to the service center where we have fast scanning equipment. I like to tell my clients that their “charts will never be far from home”.

RM:  Jackie, what’s your role in BACTES?

JA:  I am the Area Manager of the Orlando Service Center.  I’ve lived in Florida for the past four years providing a local resource to practices in the Orlando area. BACTES is a national company but regionally owned and operated. We just celebrated 20 years in business; the Orlando Service Center has been around for the past 17 years. We encourage anyone considering using BACTES for either ROI or EMR conversion to ask us for references.

RM:  What’s the best way for people to learn more about how BACTES can help them?

JA:  You can visit our website at www.bactes.com or contact me directly at jalfonso@bactes.com or call me at 407-473-3384.

RM:  Thank you, Jackie.

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What were your biggest challenges in 2011?

28% – keeping up with changes in compliance measures

28% – transitioning to an EHR/EMR system

14% – managing expenses

30% – miscellaneous “other” items

What do you foresee as your biggest challenge in 2012?

57% – transitioning to an EHR/EMR system

43% – preparing for ICD 10 – 5010 migration

What’s your main focus for your practice in 2012?

72% – managing ICD 10 transition / controlling expenses

28% – EMR/PM implementation

What’s the one thing you wish you had support for right now?

58% – managing ICD 10 transition / handling collections

14% – EMR implementation

14% – Meaningful Use

14% – miscellaneous “other” items

If you could change anything about your practice, what would it be?

100% – miscellaneous “other” responses

Are you going to attest for Meaningful Use in 2012?

100% – Yes

How do your goals and challenges match with these responses?  If you’d like to have your thoughts included in our summary, we’re keeping the survey link open for one more week. Visit the following link to access the survey:

Practice Manager Survey

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1. The 5 W’s to Implementing the Security Rules for Meaningful Use in Your Practice
2. Your Policies and Procedures Are Incomplete If They Don’t Include a Security Risk Management Process
3. Demystifying Meaningful Use

A well-trained medical biller on your team is your best weapon in keeping your practice revenue flowing smoothly.  Proper use of CPT codes and knowledge of a variety of your local insurance companies and major health plans will help you establish a database of knowledge to employ in creating effective collection policies for your practice. Additionally, a few simple techniques will help you to begin 2012 with a strong collections process in place.

1. Develop and Communicate an Upfront Collections PolicyIt’s important to have current benefit plan information on file for each patient so that you can accurately calculate any co-pays or deductibles for your patients.  It’s a good policy to check your patients’ insurance coverage during their initial visits each new plan year.  If the patient has a co-pay or deductible, collecting it at the time service is rendered significantly reduces the number of potentially uncollectible accounts.  Review your new patient paperwork to ensure that any changes in policies or procedures have been accurately incorporated into these forms.  Data collection is half the battle in ensuring efficient claims processing for services.
2. Train Staff on Proper Collection TechniquesMake sure that your staff understands your collections policy and is comfortable enforcing it.  Use role-playing techniques until your front desk team members are confident in talking with patients about their financial responsibilities.
3. Educate Patients on Their Financial ResponsibilityIf you clearly communicate your payment policies and are consistent in enforcing them, then patients know what to expect when they visit your office. Give them multiple ways to pay their bill by offering cash, check and credit card options.
4. Offer Financial AssistanceWith the growing number of uninsured or underinsured patients in our country, it’s important to have a financial aid policy to assist patients in need.  You can also offer assistance to patients in finding community or government programs to help with medical expenses.  Lastly, low or no interest financing will allow patients in need to receive necessary medical treatment.

Another technique that’s on the rise is for medical practices to establish a line of credit from a financial institution to manage cash flow inconsistencies, particularly during the first quarter when deductibles must be met before insurance company payments begin.  As practices convert to the ICD-10 Version 5010 HIPAA transaction standards, which went into effect on January 1, 2012, some experts are advising that a line of credit will help to minimize cash flow disruptions that may result from this conversion.  Information about ICD-10 Version 5010 can be found on the Centers for Medicare & Medicaid Services website at https://www.cms.gov/ICD10/.

In summary, it’s important to understand the intricacies and complexities of insurance plans, medical billing, as well as government programs and regulations covering the payment of insurance claims.  With this knowledge in hand, you can create the business processes and policies to support the efficient operation of your medical practice and maintain a steady revenue stream.

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1. Creating Practice Policies For Collecting Patient Payments
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3. Working Accounts Receivable – Part One

Keep in mind that you will need numerators and denominators in order to completely attest, so I recommend having those numbers handy or at least access to a dashboard or reporting tool that has that information easily accessible. What is a numerator? It is the satisfying number to meet the requirement. What is the denominator? It is the complete grouping that was considered for the measure. There are also denominator exclusions for many of the measures. This specific exclusion type means the patients who were not eligible for some medical or non-medical reason for the particular measure even though they may have been in the denominator grouping for that measure.

And….if you are looking for even more links, tools and assistance with Meaningful Use, feel free to check out the Meaningful Use section of our blogposts for more information.

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The very first Administrative Standard refers to the prevention, detection, containment and correction of any security violations. As we’ve discussed over the last few weeks, if you are attesting to Meaningful Use, Measure 15 outlines the requirement of a security risk analysis that addresses potential security gaps and provides clear direction on managing and preventing security risks. Furthermore, this security management process must be documented and contained within the practice’s P&Ps. These P&Ps will assist you in meeting compliance standards and protecting you in the event of an audit.

We have developed a checklist to guide practices in a review and update of their P&Ps to ensure that they address all of the HIPAA Security Rule Standards. You can download a copy of this document on our website at www.practicemanagersolutions.com.

Beyond the requirements of the HIPAA Security Rule, P&Ps are important in establishing clear expectations of how various stakeholders interact with your practice. They guide you in the day-to-day operation of the practice including instructing staff members on how to perform various functions, establishing patient guidelines for everything from missed appointments to insurance payments, and give the practice manager objective means for evaluating and managing the effectiveness of the practice.

If you haven’t looked at your P&Ps lately, now is a good time to not only incorporate and/or update your security management process, but also determine how effectively they reflect the reality of your practice management. A good P&Ps manual will include at a minimum the following sections:

Patient & Staff Safety

Patient and staff safety is a primary concern in the medical practice.  Policies and procedures should exist for:

• Cleanliness of exam rooms
• Sterilization of medical equipment
• Availability of protective gear to prevent the spread of infectious disease

Insurance and Billing Procedures

Effective billing procedures will help ensure the financial viability of the practice. A policy should exist informing patients on how the billing process works, including what their responsibilities are in providing payment for services. The staff requires guidelines on how to process medical procedures for insurance payment through proper coding of procedures and effective interaction with insurance companies.  Procedures should exist for the collection of delinquent accounts, resolution of discrepancies and the appropriate write-off of uncollectable debt.

Human Resources Policies

Like any business, your practice has policies that outline employment practices for your staff.  Your P&Ps should clearly describe the policies for items such as:

• Vacation time
• Sick days
• Holidays
• Employment reviews
• Pay raises and pay scales

Administrative Functions

Administrative P&Ps define how the front office interacts with patients. It sets the initial tone for the patient experience. They should cover:

• Days and hours of operation
• After hours calls
• Appointment scheduling
• Maintenance of the waiting room
• Office opening and closing procedures
• Proper hand-off of patients to the medical staff

In summary, Policies and Procedures promote consistency in performance of all functions within the practice. They provide effective communication channels with staff and with patients, as well as third-party stakeholders such as insurance companies and labs. Inclusion of a robust security management process protects you in the event of a Meaningful Use audit. Regular review of your P&Ps should include staff to guarantee they accurately reflect the day-to-day realities of running the practice. A P&P review can guarantee that your communication materials, including your website, contain the most up-to-date policies for patients ensuring a calm and efficient patient experience.

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1. Know Your Medical Practice Risks – Meaningful Use 15
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A thorough security risk assessment should include the following components:

1. A review of current security procedures related to your EHR. Be sure to include clinicians and management, as well as IT, in the review process.
2. Risk management procedures in your practice as well as any third parties who have access to information from your EHR system.
3. Threats to not only the confidentiality but also the integrity and availability of protected information.
4. Measures to identify future security risks.
5. A process for integrating continuing security updates.
6. A regular review process to manage future changes.

It’s not enough to merely conduct a security risk assessment, you must also address any security gaps to ensure that your EHRs are fully protected. So, if you’ve identified problems with the security of your EHRs, you should develop a plan and timeline to fix those risks. Only then can you truly meet Measure 15.

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I’m wishing each and every one of you a very happy holiday season filled with the perfect mix of friends, family, relaxation, fun, self-reflection and time for yourself.  I look forward to hearing about your journey throughout the coming year.

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The biggest impact of the delayed deadline is to give early adopters a more reasonable timeline for implementing important Stage 2 functionality in their EHR technology. Since final Stage 2 criteria aren’t set to be released until June of 2012, this decision will give providers ample time to implement new software and meet the new challenges of Meaningful Use Stage 2. As a side benefit, providers who attested to Stage 1 in 2011 will be eligible for three years of Stage 1 payments.

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