This week, let’s touch on a few hot topics in the industry.
Homebound Status Rule Update
The Homebound status specific detailed documentation is changing on November 19, 2013. CMS Change Request 8444 states there are two main criteria for homebound status.
Criteria 1: If, due to illness or injury the patient requires supportive devices such as w/c, crutches, or special transportation, or assistance of another person, OR have a condition that would make leaving their home medically contraindicated and the clinician must clearly document this information.
Persons who meet one of two Criteria 1 requirements must also meet BOTH of the following:
Criteria 2: There must exist a normal inability to leave home AND leaving home must require a considerable and taxing effort that is well documented.
Criteria 2 “there exists a normal inability to leave home” looks like the most difficult threshold to meet because it is now coupled with “a considerable and taxing effort.” Most agencies focus on the latter section, but seldom on the first section. Note that the new rule requires BOTH. Expect denials to be on the rise.
HIPAA HITECH HIM Overview Checklist
- Use and Disclosure of PHI Policy
- Incidental Disclosure Policy
- Accounting of Disclosures Policy
- Confidentiality Policy
- Patient to Access Policy
- Right to Amend Medical Record Policy
- Authorization Requirements for Records Policy
- Patient Right to have Copy of EMR Policy
- Business Associates Policy Updated
- Notification of Breach Policy
- Sanctions Policy
- Security Review: Passwords, Encryptions, Time out for Devices, Minimum Access (Need to Know)
Modifications of Forms to Meet Updated Rule:
- Patient Bill of Rights
- Employee and Subcontractor Code of Conduct
- Employee Security of PHI Attestation
- Disclosure of PHI Authorization
- Patient Access Request
- Request to Rescind Authorization
- Request to Amend Medical Record (Paper and Electronic)
- HIPAA Security Checklist and Review
Has Your Agency Developed Forms For:
- New Requirements
- Restricting Disclosure of PHI for Patients Paying Out of Pocket
- Orientation for New Hires HIPAA Privacy, Security, and HITECH
- Annual HIPAA HITECH Privacy and Security
- Orientation for New Hires Corporate Compliance
- Annual Corporate Compliance Refresher
ICD 10-CM Provider Implementation Strategies
Everyone is now talking about ICD-10. Recently, we did an article on “ICD-9-CM to ICD-10 Coding: Creating the Practical Transition Plan.” Clearly, this major coding change means millions of individuals must learn thousand of new codes, plan new process/operation changes, and implement this major shift throughout the entire healthcare industry in nearly every department in a coherent orderly fashion. If they do not, it is feared the payment system could be seriously disrupted.
It is expected that the implementation of ICD-10 eventually will led to an overall improvement in quality of care, reduce fraud and abuse as well as cost. Have you conducted a gap analysis to see how ICD-10 will impact daily, weekly, and monthly tasks of the following:
- Patient intake and admission processes and reports
- Referral Sources
- Clinicians and physicians
- Coding specialists
- Case management processes
- QA and QIO processes
- HIM/IT processes
- Compliance program and team
- Auditing processes and Auditors
- Billers and RCM processes
- Operational processes and personnel
- Senior leadership
- Education and Training Needs
Consider the impact of the new education and training on present operations. Identify the resources needed.
|Be certain you choose a strong project manager for this impact assessment/gap analysis. You need someone who can lead the analysis, assemble key contacts and teams, develop team created recommendations and designs with timelines and appointed responsible persons for implementation. Have a solid communication strategy, develop interview schedules of personnel and establish an organization implementation strategy after the project plan has been approved. A strong well thought out plan is the first step toward success.|