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House approves healthcare reform bill
Q&A: Red Flags Rule
Q. How does the HIPAA privacy rule coincide with the new Red Flags Rule, which requires providers with covered accounts to contact law enforcement if the provider suspects identity theft? May providers release PHI or discuss the patient’s case with law enforcement officials?
A. The Red Flags Rule does not require you to notify law enforcement officials of suspected identify theft. Instead, the rule permits you to do so. Most states' identity theft protection laws allow this as well. Informing law enforcement officials about a PHI breach and its nature does not violate HIPAA. Patient authorization is necessary before you disclose any specific identifiable information to law enforcement officials. Absent specific authorization, release of PHI to law enforcement would violate the HIPAA privacy rule.
Advising patients to contact law enforcement is the best course of action. If warranted, notify law enforcement of the breach and provide the perpetrator’s name if known, but don’t provide a list of affected patients.
Editor’s note: Chris Apgar, CISSP, answered this question. This is not legal advice. Consult your attorney regarding legal matters.
Red Flags Rule enforcement delayed to June 1
The Federal Trade Commission is delaying enforcement of its identity theft Red Flags Rule for a fourth time, pushing back the November 1 deadline to June 1, 2010.
The latest delay comes at the request from Congress, which is considering exempting entities with fewer than 20 employees from the identity theft rule.
The House of Representatives passed the bill late last month. The Senate is now considering the bill.
The previous delay announcement—from August 1 enforcement to November 1—came in July. The House Appropriations Committee requested the additional three months to educate small businesses about Red Flags Rule compliance. The delay also allowed financial institutions and creditors more time to implement written identity theft prevention programs, according to the FTC.
Red Flags requires creditors and financial institutions to have in place identify theft prevention, detection, and response systems. The rule is mandated by the Fair and Accurate Credit Transactions Act of 2003.
Red Flags was initially supposed to go into effect November 1, 2008, but was pushed back to May 1, 2009, then to August 1, 2009, then to November 1, 2009, and now to June 1, 2010.
Build accountability into your Revenue Cycle
Revenue cycle managers constantly search for the perfect benchmark information to compare their team’s work with others.
Don’t search too hard, says Michael S. Friedberg, FACHE, CHAM, associate vice president of patient access services for Apollo Health Street, a national revenue cycle solutions firm in Bloomfield, NJ.
It can be good to compare nationally or even regionally, but some of the best benchmarks are right under your roof.
Benchmark against yourself, Friedberg said in the September 22, HCPro, Inc. audio conference, “Use Patient Access Benchmarks to Improve Registration Accuracy.”
Hold your team accountable. Do you sit back regularly and look at the big picture for your team rather than just put out fires?
In the audio conference, Friedberg pointed to passages in “Leadership,” former New York City Mayor Rudolph Giuliani’s 2002 book, as some great examples of holding staff members accountable.
Guiliani met with the leaders of each of NYC’s police precincts once a week, reviewing crime numbers. If there were a rise in certain crimes, the mayor asked why and what the respective leader was doing about it.
Giuliani built accountability into New York city government. You can build it into your revenue cycle team.
Dunn Memorial Hospital in Bedford, IN, is doing it now.
Stephanie Smithson, CHAM, the patient accounts director, says the facility implemented best practice key performance indicators (KPIs) for the entire revenue cycle. KPIs are metrics that illustrate how to improve your revenue cycle.
Dunn’s patient access benchmarks include:
- 2% or less error rate at time of billing
- 95% pre-registration rate
Dunn creates action plans for areas below benchmark, Smithson says. Dunn also implemented ED point-of-service (POS) collections.
“ED POS collections is a new area for us, and we are actively working through the issues with ED Nursing Management to resolve,” Smithson says. “We are actively using our performance matrix to assign shifts and for evaluations.”
Each revenue cycle team reports numbers monthly to the hospital finance committee and the hospital board. A core group meets weekly to complete and report outstanding issues for the entire revenue cycle.
What has the revenue-cycle-wide initiative done for Dunn?
- Allows staff members to meet and interact on all points of the revenue cycle
- Educates staff members how each area interacts within the revenue cycle and what issues they have
- Gives team leaders a voice and chance to showcase their team’s improvement
- Exposes leaders to other leaders’ strategy on handling problems within their own areas
Dom Nicastro is a senior managing editor at HCPro, Inc. in Marblehead, MA. He edits the Briefings on HIPAA and Health Information Compliance Insider newsletters. E-mail him at dnicastro@hcpro.com.
Benchmarking in patient access
We presented an audio conference, “Use Patient Access Benchmarks to Improve Registration Accuracy,” September 22.
These days, it seems all patient access departments are ramping up efforts to be accurate, considering the economic climate.
Take a look at some of the tools we offered during the show:
- Audit tool for consistent education
- Training checklist
- Manual monitoring tool
- Outline of Albany Medical Center's training program
- Productivity standards
- Dashboards
- Audit QA
- Standard set of elements of scorecard
AHA RAC Program Update answers provider questions
And while DRG and coding reviews could begin as soon as November, the AHA says CMS may delay the onset of medical necessity reviews so it can first establish a process that would give providers the ability to re-bill all eligible outpatient claims. CMS previously announced medical necessity reviews would begin in January 2010.
Establish a relationship with patient financial services staff
The crossover between patient access and case management is natural. Share this tip with your ED case managers:
Patient financial services (PFS) counselors offer various assistance to patients. They:
- Speak with patients about insurance coverage or the lack thereof
- Offer to assist with originating a Medicaid or free/charity care application
- Try to answer any questions related to the financial obligations resulting from the patient’s ED visit/hospitalization
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Workers’ compensation
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No-fault motor vehicle insurance
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State crime victims’ insurance funds
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Charity care, such as professional home visits, durable medical equipment, or free transportation
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Individual state public health resources
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Individual hospital funded programs for post acute needs
Another Medicaid reduction possible when stimulus funds are gone
Source: American Medical Association
MSP makes 2010 OIG Work Plan
Something that definitely should be on your radar: The OIG promises reviews of Medicare Secondary Payer (MSP) issues.
Read about it in the Work Plan.
CMS releases new RAC FAQ
Q: How long is the RAC discussion period?A: The discussion period begins with the time of notification (demand letter for automated reviews and the review results letter for complex reviews) through the time recoupment occurs. The discussion period normally requires written notification to the RAC. The discussion period does not extend the provider's appeal time frames.