Author Archive for Dom Nicastro

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.

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.

Collecting ED co-pays

I am the supervisor of a patient access department that also includes ED triage. I am looking for information on collecting ED Copays.

Does anyone have helpful information or programs that they have put together? I would appreciate any feedback.

Thank you
Lori Weber

How do you hold your Patient Access team accountable?

Scoring matrix?

Weekly reviews?

Benchmarking is so crucial to a patient access team’s success. I want to know your story. How do you keep your patient access team accountable? And how does it help you down the road?

Share your story here, and perhaps it would make a great column for another site we run, www.healthleadersmedia.com.

Question on the HINN

Q.  We are not sure how to implement the Preadmission/admission HINN. At what point [does] it get delivered to the patient? Does there need to be an inpatient order? If they did not meet inpatient criteria, why would there even be an inpatient order? I could see this possibly happening for direct admits from the doctor’s office in which the hospital is not in agreement. But what about those in the ED where the majority would be? Our understanding is this is used for patients who do not meet either Observation or Inpatient criteria.

A. In order to be effective, a Preadmission/Admission HINN must be delivered to the patient (or his/her representative) no later than the date of admission.  Ideally, the HINN would be delivered at the earliest opportunity, if not prior to admission, then at the time of admission, during the registration process.  The inpatient stay generally begins at the time of the physician’s written  admission order, so whether there’s a written order at the time of delivery of the HINN depends upon when the HINN is provided.  If provided prior to admission, there would be no written order.  If provided after admission, presumably there would be a written order.

Remember, that it’s the physician who orders the admission.  Although in the best case scenario the physician’s decision as to whether to admit to inpatient care or to order outpatient observation is guided and informed by case management (CM) and utilization review (UR) staff, it ultimately is the physician’s decision.

In the case where the hospital believes that the admission does not meet inpatient guidelines for coverage under Part A, the hospital must provide the Preadmission/Admission HINN in order to reserve its right to bill the patient if Medicare denies coverage for that stay.  When a HINN is provided, the hospital is simply stating that, based upon its understanding of Medicare inpatient guidelines, the hospital doesn’t believe that Medicare will pay for the stay under Part A.  Medicare, however, will ultimately determine whether that stay is covered under Part A.

The Preadmission/Admission HINN is most likely to be used where the patient understands from the outset that this stay is not likely to be covered by Medicare, and they are expected to assume responsibility for that inpatient stay.  Perhaps they have other health care coverage that they believe will cover that inpatient stay.

The Preadmission/Admission HINN only indicates that the hospital believes the inpatient admission does not meet Medicare’s inpatient guidelines.  Observation services are outpatient services.  Therefore, different coverage criteria apply to determine whether observation services will be covered by Medicare.

If covered, those observations services will be covered under Part B, not Part A.  In those cases where it isn’t clear that the patient currently meets inpatient guidelines, but the physician determines it isn’t safe to discharge the patient, it may be appropriate for the physician to order observation care to monitor the patient and obtain additional information regarding further care.  It would be inappropriate to provide a Preadmission/Admission HINN when the hospital believes that the observation care meets Medicare medical necessity requirements.

Editor’s note: This question was answered by Judith L. Kares, JD, an instructor for HCPro’s Medicare Boot Camp – Hospital Version. Kares was a speaker on the HCPro, Inc. audio conference, Master the HINNs: Integrate Policies and Procedures into Hospital Operations.

Get staff members to know HIPAA

The American Recovery and Reinvestment Act includes many changes for HIPAA.

Your patient access staff members should know them.

Here’s a white paper to help them get started:

HIPAA and the HITECH white paper

Sample survey to patients

I am looking for a sample survey to give to patients. I need feedback to have continuous improvement.

Is anyone willing to share the survey tool they are using?

Carole L. Sraver
Director, Patient Access
Washington Adventist Hospital

Don’t delay because of Red Flags Rule delay

The Federal Trade Commission (FTC) pushed back its compliance date Thursday on the “Red Flags Rule” from May 1 until August 1, giving healthcare facilities considered to be “creditors” three extra months to implement an identity theft prevention program.

But that does not mean healthcare entities should delay implementing a program–especially when you’re dealing with the FTC, an organization known for harsh punishment and corrective measures.

“Don’t forget, this is a much different agency than [Office for Civil Rights] and CMS, the enforcement agencies for HIPAA, and if they do show up, the consequences will likely be severe,” says Kate Borten, CISSP, CISM, president of The Marblehead Group in Marblehead, MA.

The Red Flags Rule aims to keep the FTC away. It forces any organization considered to be a “creditor” to implement programs to identify, detect, and respond to patterns, practices, or specific activities that could indicate identity theft.

Read my full piece on healthleadersmedia.com.

HIPAA and the HITECH Act

Your patient access staff members can never know enough about HIPAA.

I authored a white paper analyzing the new laws in the Health Information Technology for Clinical and Economic Health Act (HITECH Act) – or Title XIII of the American Recovery and Reinvestment Act of 2009, signed February 17.

Visit our Revenue Cycle Institute to download the white paper, HITECH Act and HIPAA: Strengthen your HIPAA compliance and training programs; prepare for new laws under the American Recovery and Reinvestment Act of 2009.

I’ve also written some columns about the subject for our daily online healthcare news Web site — www.healthleadersmedia.com:

• No panic about HITECH
• HHS issues draft guidance on securing PHI

Thanks!

Dom Nicastro
Senior managing editor
Patient Access Resource Center

Got a success story with HINNs?

Looking for a successful case study for an audioconference. If you have one and would like to speak to it in an audioconference with us, please let me know!

Thanks!

Dom Nicastro