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Raleigh Orthopaedic Clinic of North Carolina will pay $750,000 to settle charges that it violated the Health Insurance Portability and Accountability Act of 1996 Privacy Rule. The group allegedly handed over protected health information for approximately 17,300 patients to a potential business partner without first executing a business associate agreement.
HIPAA-covered entities cannot disclose protected health information without authorization, and the lack of a business associate agreement left this information without safeguards, rendering it potentially vulnerable to misuse or improper disclosure.
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Raleigh Orthopaedic is a provider group practice that operates clinics and an orthopedic surgery center in the Raleigh, North Carolina, area.
The Office of Civil Rights, a division of the U.S. Department of Health and Human Services, launched its investigation of Raleigh Orthopaedic following receipt of a breach report on April 30, 2013. The investigation found that Raleigh Orthopaedic released X-ray films and related protected health information of 17,300 patients to a group that promised to transfer the images to electronic media in exchange for harvesting the silver from the X-ray films. Raleigh Orthopedic allegedly failed to execute a business associate agreement with this company prior to turning over the X-rays and health information.
[Also: OCR unleashes second wave of HIPAA audits, but will it diminish patients' privacy and security expectations?]
In addition to the $750,000 payment, Raleigh Orthopaedic is required to revise its policies and procedures to establish a process for assessing whether entities are business associates.
It is also required to designate a "responsible individual" to ensure business associate agreements are in place prior to disclosing public health information to a business associate; create a standard template business associate agreement; and establish a standard process for maintaining documentation of business associate agreements for at least six years beyond the date of termination of such a relationship. The group also must limit disclosures of personal health information to any business associate to the minimum necessary to accomplish the purpose for which it was hired.
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"HIPAA's obligation on covered entities to obtain business associate agreements is more than a mere check-the-box paperwork exercise," OCR Director Jocelyn Samuels said in a statement. "It is critical for entities to know to whom they are handing personal health information and to obtain assurances that the information will be protected."
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The tool will help create a more accurate profile of behavioral health patients and identify any gaps in care.
Greenway Health CEO Tee Green revealed on Wednesday that he is handing the chief executive role at the EHR company he co-founded over to Scott Zimmerman.
Green will continue full-time as executive chairman, according to the company, including a focus on innovation as the company is working to transform itself from an electronic health record and practice management vendor into a population health and revenue cycle specialist.
Before taking the helm of Greenway, Zimmerman was president of Televox, which provides patient engagement communications tools.
Zimmerman also has worked at Boston Scientific, GE Healthcare and Merck during his career.
“It’s a privilege to be working alongside the Greenway Health team to support caregivers in this time of change,” Zimmerman said in a statement. “It’s exciting to be a part of an organization working to deliver the technology, people and processes that can impact the clinical excellence and financial success of our customers. I am looking forward to doing everything I can to help further that mission.”
Zimmerman’s appointment marks the second C-level announcement in recent months. In December 2015, Greenway named Robert Ellis as its new chief financial officer. Ellis came from Vista Equity Partners, where he was a managing director.
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U.S. Senators and Representatives introduced a bill on Wednesday that would reduce the meaningful use reporting period from a full year to 90 days – and do so in 2016, a move pressed by healthcare organizations across the country.
Sens. Rob Portman and Michael Bennet and Reps. Renee Ellmers, Tom Price, Bobby Rush and Ron Kind introduced bipartisan legislation.
CHIME, the Medical Group Management Association, the National Rural Health Association, the Federation of American Hospitals and physician groups, not only support the bill, but have also pressed lawmakers for it.
Many of the organizations wrote CMS on March 15, asking for a 90-day reporting period for 2016.
[Also: Healthcare providers press CMS for 90-day meaningful use reporting]
“A preliminary yet critical step to facilitate increased provider success, we respectfully request CMS adopt for the 2016 reporting year the same 90-day reporting period policy for participants in the Meaningful Use program that was offered in 2015,” they wrote to CMS Acting Administrator Andy Slavitt.
CMS required a full year reporting period last year, but later reduced the requirement to 90 days in a rule that also reduced the number of meaningful use, Stage 2 requirements.
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More widespread implementation of gaps in care programs is essential to realizing the value of population health management, according to a new report from the Workgroup for Electronic Data Interchange.
In its study, "Closing Gaps in Care through Health Data Exchange," WEDI defines those gaps as the discrepancy between evidence-based best practices and the care that's actually delivered to the patient.
At too many providers, that chasm is still too wide, according to the report. Better IT infrastructure – enabling more robust exchange health data, automating identification of information gaps and streamlining care coordination – is needed to bridge it.
Toward that end, WEDI offers five key takeaways:
1. Education and communication are essential to making providers aware of the value of identifying and closing gaps in care. "Providers appear to lag behind health plans in implementing gaps in care programs," according to the report. "Challenges include the lack of sufficient resources or education about how to maximize workflow changes and effectively close gaps in care."
2. Gaps in care can adversely affect provider performance. "Surveyed providers are significantly more concerned than health plans that gaps in care pose a threat to their organization by affecting clinical performance, financial performance and the ability to retain patients," according to WEDI.
3. Programs to address gaps in care offer a high return on investment. "Improvements were observed in quality outcomes such as access to behavioral healthcare, pediatric and adolescent check-ups and medication adherence," according to the report. "Reductions in utilization of ambulatory care, hospital admission and hospital readmission were also observed."
4. Better consensus is needed to develop and standardize quality measures and methodologies for data exchange among payers, providers and patients. "The terminology, standardization and scope of gaps in care measures need more clear definition and alignment between health plans and providers before actionable data harmonization can occur," WEDI researchers say. "Best practices need to be disseminated that illustrate stakeholder roles, automation of workflow and quality improvement.
The report also points to other barriers such as the "provenance, quality, completeness, timeliness, transparency and accuracy of data." More widespread use of open API and element - based exchange could help address these
5. Fixing care gaps will only grow in importance as value-based models evolve and access to care and coverage expands. "As newly eligible consumers continue to enter the health insurance marketplace and access healthcare, it will be essential for stakeholders to develop effective healthcare communication, prevention and education and intervention strategies to improve the quality of patient-centered care," the report says.
"As we increasingly grow fee-for-value arrangements in our nation, it is critical that we look to methods automate gaps-in-care – to not only ensure that data moves seamlessly between clinical systems and payment systems but that the information is useful and actionable for clinicians and patients," WEDI founder and former HHS Secretary Louis W. Sullivan, MD, said in a statement.
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The Act to Prevent Opiate Abuse by Strengthening the Controlled Substance Prescription Monitoring Program also sets a cap on number of days for opioid prescriptions and requires doctors to undergo addiction treatment every two years.
New York's Mount Sinai Health System is joining other high-profile health systems across the nation in embracing OpenNotes, an initiative that gives patients access to their care provider's notes in their medical records.
The notes are available for the first time in the health system's online electronic health record portal, called MyMountSinaiChart. Users can now read details of their office visit from the convenience of their personal computer, tablet or smartphone.
MyMountSinaiChart, launched in 2012, also enables patients to communicate with their doctor, access test results, request prescription refills and manage appointments.
The goal of OpenNotes is to improve transparency, communication and trust between patients and physicians – and it's working, Mount Sinai officials say.
[Also: OpenNotes: 'This is not a software package, this is a movement']
"When patients can access their physicians' notes, they can better understand their medical issues and treatment plan as active partners in their care," said Sandra Myerson, chief patient experience officer at the Joseph F. Cullman, Jr. Institute for Patient Experience at Mount Sinai.
"This can ultimately lead to improved patient engagement, patient empowerment, and communication between patient and physician."
"Patients expect and deserve to have full access to their medical records and the Mount Sinai Health System is committed to meeting this expectation," Jeremy Boal, MD, chief medical officer at Mount Sinai Health Systems, said in a statement.
Four Mount Sinai physicians in various clinical practices conducted the initial OpenNotes pilot beginning in December 2015.
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Revenue cycle management has gone from being a "back office" function to an "end-to-end" system that begins at patient intake or even before, claims specialists say. Advanced technologies, in tandem with improved workflows and better data have resulted in RCM systems that encompass the entire healthcare enterprise.
With the right automation tools and revenue cycle support, experts say healthcare providers should be able to improve their cash flows by collecting patient payments up front, determining precise eligibilities and filing clean claims to payers.
With the fee-for-service business model changing to prospective payment and value-based care, healthcare organizations are undergoing a cultural shift that dramatically alters their approaches to patient intake, eligibility verification and claims processing. These are issues that providers will have to understand and adjust to accordingly, says Jose' Rivera, vice president of physician solutions development at Santa Rosa, Calif.-based Visiquate.
"Fee-for-service is going away and bundled payments will come to fruition," he said. "We will see a resurgence of capitation because it puts the risk back on the provider. Organizations were able to overcome ICD-10, but as the model moves toward quality I think we'll see another resurgence of value proposition payer mixes."
As a result, Rivera believes it will be a lot more difficult to get paid. Meeting the challenge means physicians must become educated on tracking quality metrics and reporting them to payers, he says.
"This is a formidable task because different payers with different contracts all want slightly different quality metrics," Rivera said. "It's a big question mark in the back of my mind."
Emphasizing intake
RCM specialists agree that patient intake is a critical part of the revenue cycle process and that if they aren't emphasizing it, they need to do so immediately. Collecting patient deductibles, co-payments and eligibility authorizations is paramount for boosting the organization's cash flow as well as for ensuring clean claims, Rivera said.
"That is the front line – they need to capture that information correctly and guide it to the right places," he said. "When it comes to authorizations, we are still in a prehistoric environment where a payer has to be called on the phone and it's a half-hour wait to get the authorization. This process definitely needs to be upgraded."
Patient registration is undergoing dramatic change, with intake clerks "being asked to do more and more," says Colleen Wood, vice president for the Eastern U.S. at Jacksonville, Fla.-based Availity.
RCM technology at the point of intake should be leveraging technology for patient data capture as well as having credit and debit card readers for upfront payments, she said. And while some providers – especially physicians – have been reluctant to ask for payment upfront, collecting deductibles and co-payments at intake fosters cash flow while informing patients of their obligations.
"As patients, they should want to know how much it will cost," she said. "This is an opportunity for them to ask about costs and manage their dollars, which they couldn't do previously."
Receiving deductibles and co-payments not only improves cash flow, it also creates a more comprehensive patient profile, Wood said.
"It goes deeper than just getting deductibles and co-insurance," she said. "It is the total dollar for the patient and provider experience. Deductibles are part of the equation, but the challenge is that there is a ton of data about patients being eligible for services, but also the benefit level each payer covers and how it is going to be covered. Providers need to realize they need to get the total dollar and understanding of the benefit level for every patient, whether it is in the physician or hospital setting."
Illuminating the buckets
Although the emphasis is on intake, the back end of the revenue cycle continues to be as vital as always and clean claims remain the key to prompt payment. Still, there are stumbling blocks in the claims filing system, says Jay Deady, CEO of Greenwood Village, Colo.-based Recondo.
"On the back end, we need to identify the buckets and reasons why claims aren't adjudicated cleanly," he said. "When we illuminate those buckets, patient ineligibility and lack of authorization are still the main reasons for denials."
Electronic data interchange transactions with payers is still the standard for eligibility and authorization data, but Deady's research shows that the information can be wrong up to 25 percent of the time. On the whole, however, the process has improved immensely in the past few years, he said.
"We're getting more information earlier, getting more information cleared earlier and more is being done earlier," he said.
Many moving parts
While the end-to-end revenue cycle system has become more automated, there are "still a lot of moving parts" within the process, noted Mike Nissenbaum, CEO of Dallas-based billing contractor Aprima.
"There are so many changes just on what is covered and how much will be paid," he said. "There are constant changes in plans and the payers can modify formularies and delay them up to six months. That is very stressful. If we don't pay attention to all these rules changes, our clients suffer."
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More than 100 million records reportedly were compromised in 2015 in healthcare, which now is the top industry for cyberattacks, according to new IBM research.
Claiming that it was "startled" by VA officials' recent testimony, the committee put strict conditions on full funding that a Senate committee already approved.