All Entries in the "Access Q&A" Category
HIPAA Q&A: Notice of Privacy Practices
Q. Is there a need to keep the acknowledgment form when we provide a Notice of Privacy Practices (NPP) to a patient? If so, how long must we keep it?
A. Covered entities (CEs) must keep records for six years to demonstrate their compliance with the HIPAA Privacy Rule. CEs must retain the signed acknowledgment form to demonstrate compliance with the NPP requirement.
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, a nationally recognized expert on patient privacy, information security, and regulatory compliance, answered this question. She is associate executive director of Health Information Management (HIM) at Scott & White Healthcare in Temple, TX. Some of her publications were used as a basis for the Health Insurance Portability and Accountability Act of 1996 privacy regulations.
How are you complying with Red Flags Rule?
I am looking how other facilities are complying with the Red Flags Rule and how they are documenting these? How do you determine what a ‘true” Red Flag is?
Patient Access Q&A: Red Flags Rule
Editor’s note: This is the fourth and final in a series of Q&As with Paul Shorrosh, MBA, MSW, CHAM, CEO of Database Solutions, Inc.
Q. The Red Flags Rule is a big deal in preventing medical identity theft, and patient access plays a big role. Do you have any advice/tips for the patient access folks regarding that?
A. This is getting tougher because just when hospitals most need to verify that one unique patient identifier that doesn’t change (Social Security number), more patients are reluctant to share it. Without adequate technology to verify a patient’s identity, address, and insurance information, a registrar is going to err on identity theft, leaving the hospital vulnerable.
Identity verification software vendors will likely shift from transaction-based pricing to subscription or flat-fee pricing to help hospitals shoulder the burden of checking every patient for identity verification.
Patient Access Q&A: Trends
Editor’s note: This is the third in a series of Q&As with Paul Shorrosh, MBA, MSW, CHAM, CEO of Database Solutions, Inc.
Q. What have you seen recently with clients as far as registration goes? What are the trends where revenue cycle teams are erring and what should they be doing to fix these problems?
A. Missing pre-certifications and prior authorizations, medical necessity/ABN failures, and wrong insurance information continue to be at the top of most hospitals’ error list. Also, RAC audits have brought the Medicare Secondary Payer Questionnaire, observation vs. inpatient stays, and physician orders to the front. Guarantor and subscriber demographic information continues to be a challenge, as well.
For previous questions and answers on the Patient Access Resource Center, go here:
CHAM study guide
I plan on taking the CHAM exam in January, but I am not employed by a Health Access facility. (self employed/billing). I have registered for the Elearning module on the NAHAM website. The resource does not give specific information that will be addressed on the exam.
i.e.: Joint Commission standard on Disaster Recovery plan for electronic systems.
Does anyone out there have a hard copy study guide that I can purchase?
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.
Q&A: Critical Access Hospitals
Question: Are Critical Access Hospitals safe from a RAC audit?
Answer: No. Medicare auditors can visit CAHs just as they would a larger facility, according to members of The RAC Report advisory board.
Q&A: Observation hours
Q: When would you start charging observation hours post op if the order is written and the patient meets criteria?
A: Start billing after the physician writes the observation order and when nursing documentation reflects the beginning of the observation time (usually 4-6 hours after surgery or the time when observation criteria are met).
This question was answered by Deborah K. Hale, CCS, president of Administrative Consultant Service, LLC.
Q. How many interviews should I conduct when filling a patient access staff position?
Q. How many interviews should I conduct when filling a patient access staff position?
A. Each candidate should have a minimum of two interviews on two different days. This is an absolute rule, as the second interview will allow you to determine whether the candidate can arrive on time and act appropriately more than once. I learned this trick at a conference, and once I implemented it, I immediately saw the value in multiple interviews on different days. One candidate we interviewed showed up late and dressed inappropriately for the second day, so we did not hire that candidate.
Because we’re looking to fill more entry-level positions, layers and layers of interviews are not necessary unless you are hiring someone who needs specific knowledge, such as supervisors, insurance verifiers, and financial counselors.
Source: Michael S. Friedberg, FACHE, CHAM, in his book, Staff Competency in Patient Access, Copyright 2007 HCPro, Inc.
Q: What do critical access hospitals (CAHs) who have elected Method II have to provide to their fiscal intermediary (FI) to help determine eligibility for the primary care and specialty bonus?
Q: What do critical access hospitals (CAHs) who have elected Method II have to provide to their fiscal intermediary (FI) to help determine eligibility for the primary care and specialty bonus?
A: Critical access hospitals (CAHs) that have elected Method II for payment of outpatient services should supply their fiscal intermediary (FI) with a list of their physicians, by specialty, that have reassigned their payment to the CAH. Your FI will determine which physicians are eligible for the primary care bonus and which should receive the specialty bonus. A Healthcare Common Procedure Coding System (HCPCS) code accompanying the AG modifier denotes a primary physician, and one with the AF modifier denotes a specialty physician.
Remember that FIs will only pay the bonus for primary care designations of General Practice, Family Practice, Internal Medicine, and Obstetrics/Gynecology, for the zip codes designated as primary care scarcity areas. The FIs will only pay the bonuses for physician provider specialties, other than Oral Surgery (dentists only), Chiropractic, Optometry, and Podiatry, for the zip codes designated as specialty physician scarcity areas. Quarterly payments should be made to CAHs, where applicable, one month after the close of a quarter.
Source: Centers for Medicare and Medicaid Services