Friday,
August 8, 2003
Vol. 6, No. 63
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On Complianceinfo.com
Sample compliance policies and procedures. (For subscribers to
Strategies for Health Care Compliance only)
Sample audit programs. (For subscribers to
Health Care Auditing Strategies only)
The
OIG Work Plan for Fiscal Year 2003
Ask the Expert
Compliance Hot Topics: Billing and
Coding, EMTALA, Stark, HIPAA
Question of the Week
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Welcome to Compliance Monitor
Q&A!
Our mission is to answer your difficult
compliance
questions—and your simple ones, too. To submit a question, send
it to Compliance Monitor Q & A editor Melissa
Osborn at mosborn@hcpro.com.
We hope you enjoy this service and we
welcome your feedback.
This week's questions
Pay-per-view article
Quick survey
Questions
and Answers
Are insurance companies business associates
under HIPAA?
Q:
Do you have to track (for an accounting) disclosures made under 164.512 of
the privacy rule, for which an authorization or opportunity to agree or
object is not required?
A:
Yes, these are typically the disclosures that need to be tracked. This is
somewhat oversimplified, but think of all protected health information (PHI)
disclosures as falling into one of the following three broad categories:
Those made for treatment, payment, and health care operations
Those made for public health, national priorities, and similar reasons
Those made with the patient's explicit authorization
The privacy rule suggests that disclosures in the first category are
appropriate by definition. And disclosures in the third category should not
be a surprise to the patient, since an authorization was obtained. That
leaves the second category of disclosures as the ones needing to be tracked.
They may be disclosures that patients are less aware of occurring in our
health care system today.
This question was answered by Kate Borten, CISSP. Since managing the
first comprehensive information security programs at Massachusetts General
Hospital in the mid '90s and later at CareGroup, she formed The Marblehead
Group, Inc., a national security and privacy consulting firm focused on the
health care industry.
Back to top
Do your joint ventures meet the letter of the law?
The Office of Inspector General (OIG) is taking a hard look at joint
ventures in health care that violate the letter of law by benefiting one
side of the venture, or only a few physicians. Join us for "Physician/Hos
pital Joint Ventures: How to Achieve Compliant, Beneficial Joint
Ventures," a live 90-minute audioconference on Wednesday, September 3.
You'll learn to develop legal, compliant joint ventures that are in
compliance with OIG guidelines and appropriately benefit hospital profits,
patients, physicians.
To register or to learn more, CLICK
HERE or call our customer service department at 800/650-6787. Be sure to
mention source code EZ1653E.
New ezine: Health Care
Auditing Weekly
Setting up and maintaining an
auditing program is never an easy task,
but HCPro now offers a free resource that delivers
helpful news and advice each week!
Introducing Health Care Auditing
Weekly, the new e-mail newsletter
designed for healthcare internal auditors
and compliance professionals. Click here to sign up for your
complimentary subscription.
Pay-Per-View article:
Security rule: Risk analyses help prioritize your efforts
Conducting a security risk analysis will help you determine where to
spend your time and money-and where not to waste your resources.
After performing your assessment, you may be willing to accept certain
risks, especially those with a low cost and a low likelihood of occurrence.
. . .
Go to "Security rule: Risk analyses help prioritize your efforts
for the rest of this article. The cost is $10. Subscribers to the online
version of Strategies for Health Care Compliance have free access to
this article. Subscribers to the print edition can find it in their August
issues.
A $30 steal!
You can read this article-and much more-in the August issue of Strategies for Health Care Compliance. Your
cost: Five stories for only $30! You'll learn the ABCs of responding to
Medicare audit letters, how risk analysis can help prioritize your security
rule efforts, how to get it right with adverse events during clinical
trials, five sure-fire training tips for E/M coding, and how whistleblower
retaliation laws pose compliance challenges.
Back to top
A how-to resource for conducting successful internal investigations
and audits
The new book, "See for
Yourself: A Health Care Provider's Guide to Conducting Internal
Investigations and Audits," will show you how to conduct your own
internal investigations and audits from start to finish. It offers practical
advice and real-life examples on how to plan and staff an internal
investigation or audit, and provides detailed information on the legal
issues involved.
To order, or learn more, go to: http://www.hc
marketplace.com/Prod.cfm?id=1742&s=EB1054G
Or, call 800/650-6787 and mention source code EB1054G.
What is the time limit to adjust claims?
Q:
How far back can a facility go to rebill or adjust claims to CMS for missed
opportunities with C codes?
A: To read the answer to
this question, click here.
Back to top
Quick survey:
How difficult do you find it to structure compliant physician recruitment
arrangements?
To submit your answer, go to the Question
of the Week at
Complianceinfo.com.
Here are the answers to the last survey:
When will your organization begin
auditing its HIPAA compliance program?
- Within the next six months: 74%
- In 7-12 months: 13%
- In 12+ months: 9%
- We do not plan to audit: 4%
Back to
top
Network with your audit colleagues
"Audit Talk" is a new,
moderated chat forum that members can use to post messages or questions for
their peers 24-hours-a-day. "Audit Talk" offers a free forum to network,
share ideas, and solve problems for those in the audit industry. Getting
involved is easy. To subscribe, just send your request to this e-mail: owner-audit_talk@hcpro.com.
Share the news!
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informative
e-mail newsletter, so why not pass on this
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colleague and get $20 off your next purchase on HCPro's Healthcare Marketplace!
Send your comments and questions about
Compliance Monitor Q&A to:
Melissa Osborn
Managing Editor
mosborn@hcpro.com
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