Friday,
October 10, 2003
Vol. 6, No. 81
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"Strategies for Health Care Compliance," a 12-page monthly newsletter, helps you thrive in the ever-changing compliance environment by providing easy-to-understand compliance advice and analysis of the latest regulations. Each month, this newsletter offers how-to tips, features about your peers, policies and procedures, and tools for improving the efficiency and effectiveness of your corporate compliance programs. To learn more, click here or
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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 Kate Alvarez at kalvarez@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
HIPAA compliance for company health plans
Q:
We are a home care agency, and we've completed our Health Information Portability and Accessibility Act (HIPAA) privacy rule preparations as a health care provider. Several sources have told us we need to have a HIPAA privacy manual for the health plans we provide for our employees. Can we purchase a manual or a template for this type of manual and modify to fit our agency? A local law firm has told us that it can prepare a manual for us for $10,000-$20,000. Is there a way to develop this manual at a lower cost?
A:
Health care providers, health plans, and health care clearinghouses that transmit health information in electronic form are "covered entities," and must comply with the HIPAA privacy rule. Compliance requirements differ depending upon the insurance status of the health plan, i.e. if the plan is self-insured, fully insured, a small plan, or a large plan. If the health plan is fully insured, your insurance company is most likely handling the compliance procedures. In the case of a self-insured company, the employer is responsible for the health plan's compliance with the privacy rule. The compliance deadline for large health plans was April 14, 2003, but the deadline for small health plans is not until April 14, 2004.
Typically, third party administrators (TPAs) oversee self-insured health plans and have some of the responsibilities for HIPAA compliance. If you are using a TPA, first contact them to determine what Privacy Rule compliance steps it has taken, and what available resources it has. It is important to understand that the employer ultimately has responsibility for its health plan's compliance with the privacy rule. You should treat the preparation of your health plan's compliance manual with the same care as preparations for the health care provider compliance manual.
There are varying requirements for health plans versus health care providers. You may use the original health care provider version of the manual as a foundation for the health plan manual, but you should significantly revise it in order to make it suitable from a health plan perspective. A qualified lawyer or consultant should perform this task.
You may obtain a template and revise it to create your health plan manual. However, there is a potential for error if the template and/or your revisions are not accurate. If you choose to use a template, a qualified lawyer should review it. Although it is probably less expensive, a manual adapted from a template may not be as thorough as one a law firm prepares. Any inaccuracy risks a violation of the privacy rule, potentially leading to additional costs down the road. Keep in mind, the compliance manuals for both the health care provider and health plan are meaningless until you implement the manuals' policies and procedures, and put them to use in your company's daily practices.
This question was answered by Cheryl S. Camin, JD, MPH, attorney in the Corporate Healthcare Section of the full service law firm of Gardere Wynne Sewell LLP www.gardere.com.
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Tell us about your financial policies.
Click here to take our quick survey on your financial policies and procedures.
LIVE AUDIOCONFERENCE: GET CASE STUDIES FOR EFFECTIVE HIPAA COMPLIANCE
AUDITING AND MONITORING
Attend the 90-minute live HCPro audioconference, "Effective Auditing and Monitoring for HIPAA Compliance: How to Ensure Consistency with Your Privacy and Security Programs," on October 30 and make sure that your privacy and security practices and controls meet HIPAA requirements. To register or learn more, CLICK HERE or call 800/650-6787 and mention source code EZ22356G.
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JOIN THE COMPLIANCE MONITOR TEAM.
Are you a compliance expert? We're looking for compliance experts in coding, billing, documentation, HIPAA, EMTALA, Stark, laboratories, and many other areas of compliance. If you are interested in answering questions from your peers, please e-mail Compliance Monitor editor Kate Alvarez.
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Pay-Per-View article:
Don't sit back and wait for new E/M guidelines
When the new E/M level guidelines are announced, all EDs will have a set of rules they can follow for standardized evaluation of visits. Until then, facilities should continue perfecting their current systems. It would be a costly mistake to stop monitoring the process of selecting E/M levels just because new guidelines are in the works.
"While we are waiting for the new E/M codes to be established, we still need to work on overcoming documentation and coding barriers," says Mary Boruff, RHIA, senior consultant at Pershing Yoakley & Associates in Knoxville, TN.
For example, if the medical documentation does not substantiate the charges for an encounter, the hospital could be losing revenue. "Your methodology can be perfect, but if it is not supported by medical documentation, you are not coming full circle," Boruff says. The only way to know whether your process is working is to test the system. This requires a time investment, but the payoff can be well worth the cost, she adds.
To find out more about the new E/M level guidelines, order the pay-per-view article "Don't sit back and wait for new E/M guidelines." The cost is $10. Subscribers to the online version of Briefings on APCs have free access to this article. Subscribers to the print edition can find it in their October issues.
A $30 steal.
You can read this article and much more in the October issue of Briefings on APCs. Your cost: Five stories for only $30. You'll also learn how to be ready for E/M guidelines, how to cope with the loss of corridor payments by improving revenue, how to create a query policy to streamline process, and why poor documentation and modifiers are at the top of the OIG's compliance 'hit list.'
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Unhappy patients can cost more than you realize
The internal culture at a hospital has a lot to do with patient satisfaction levels, and that in turn can make a difference in revenue and liability. We've planned an audioconference that will show you how to make changes that count.
You'll learn to watch for the common pitfalls, including working with the various departments to ensure a good network for communication between departments, how to provide better patient services, improve documentation to reduce patient and malpractice claims, and develop strategies to manage the compliant process.
Join us for "Patient Satisfaction and the Bottom Line: Successful Strategies to Raise Revenue and Reduce Liability" on Thursday, November 20 beginning at 1 p.m. Eastern. To register or to learn more, CLICK HERE or call our Customer Service Team at 800-650-6787. Please mention source code EZ23271A when you call.
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HIPAA and return to work notices
Q:
Prior to the HIPAA, our Human Resources policy regarding returning to work after being ill was if employees were out sick for three consecutive days, they had to bring a doctor's note back with them stating the dates of the illness, the diagnosis, and that they were in sufficiently good health to return to work. This policy is not related to workers' compensation. Can we still require the note, or should we change our policy?
A: To read the answer to this question, click here.
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Quick survey:
Does your organization train employees on Medicaid compliance issues?
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: 68%
- In 7 to 12 months: 17%
- In 12+ months: 9%
- We do not plan to audit: 6%
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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.
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Share the news
You've been benefiting from our informative
e-mail newsletter, so why not pass on this resource to your peers? Sign up a colleague and get $20 off your next purchase on HCPro's Healthcare Marketplace!
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Send your comments and questions about Compliance Monitor Q&A to:
Kate Alvarez
Editorial Assistant
kalvarez@hcpro.com
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