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Tuesday, March 19, 2013

HIPAA Notice of Privacy Practices Require Changes by Sept. 23

The HIPAA mega rule published on Jan. 25, 2013 in the Federal Register (78 Fed. Reg. 5566). The rule includes four different final rules that modify the requirements for "covered entities," notably what must be included in the Notice of Privacy Practices that must be posted in medical facilities and provided to patients upon request.

Covered entities are health care providers that transmit health information in electronic transactions directly or through others; clearinghouses; and health plans. 

The mega rule requires covered entities to make changes to the Notice of Privacy Practices by Sept. 23, 2013. For most medical practices, the additions to the Notice are:
  • Describe the types of uses and disclosures of protected health information that require an authorization. For example, the Notice must be clear that the patient must authorize the use of their information for marketing by third parties like pharmaceutical companies.
  • Clarify that the patient will receive notice of any breach of privacy or security for their protected health information.
The updated Notice must be made available to patients and posted in a clear and prominent location on or after the revision date .

To hear more detail about these changes, participate live in the Searfoss Consulting Group's Gimme 15 Minutes webinar on March 20. Registration is free. Or download the podcast available on March 21 to listen at any time! For the slides used in the presentation, you need to participate live or purchase the archive.


Friday, March 8, 2013

BA Agreements require changes by Sept. 23, 2013

The HIPAA mega rule finalized a number of changes to the privacy and security requirements for medical practices. Get what you really need to know about the new requirements for your business associate (BA) agreements in 15 minutes.

From the Searfoss Consulting Group - only $15 for video, podcast and handouts in this cram session.

Click here to order online for instant access.

Friday, October 7, 2011

5 year record retention for Maryland

Ever wonder how long to keep medical records? In Maryland, the requirement is generally for 5 years. For pediatric patients, records are kept until the patient is 21 years of age, or for 5 years, whichever is longer. Its a very straightforward rule. See below, item F (emphasis added).

The section also clarifies what needs to be in the record. See item B (emphasis added). This is the standard that is used by the Board of Physicians in their investigations of licensed medical professionals.

COMAR 
TITLE 10 Department of Health and Mental Hygiene
07.02.20

Clinical Records.

A. Records for all Patients. Records for all patients shall be maintained in accordance with accepted professional standards and practices. 

B. Contents of Record. Contents of record shall be:
  1. Identification and summary sheet or sheets including patient's name, social security number, armed forces status, citizenship, marital status, age, sex, home address, and religion;
  2. Names, addresses, and telephone numbers of referral agencies (including hospital from which admitted), personal physician, dentist, parents' names or next of kin, or authorized representative;
  3.  Documented evidence of assessment of the needs of the patient, of establishment of an appropriate plan of initial and ongoing treatment, and of the care and services provided;
  4. Authentication of hospital diagnoses (discharge summary, report from patient's attending physician, or transfer form);
  5. Consent forms when required (such as consent for administering investigational drugs, for burial arrangements made in advance, for release of medical record information, for handling of finances);
  6. Medical and social history of patient;
  7. Report of physical examination;
  8. Diagnostic and therapeutic orders;
  9. Consultation reports;
  10. Observations and progress notes;
  11. Reports of medication administration, treatments, and clinical findings;
  12. Discharge summary including final diagnosis and prognosis;
  13. Discipline assessment; and
  14. Interdisciplinary care plan.
C. Staffing. An employee of the facility shall be designated as the person responsible for the overall supervision of the medical record service. There shall be sufficient supportive staff to accomplish all medical record functions. 

D. Consultation. If the medical record supervisor is not a qualified medical record practitioner, the Department may require that the supervisor receive consultation from a person so qualified. 

E. Completion of Records and Centralization of Reports. Current medical records and those of discharged patients shall be completed promptly. All clinical information pertaining to a patient's stay shall be centralized in the patient's medical record. 

F. Retention and Preservation of Records. Medical records shall be retained for a period of not less than 5 years from the date of discharge or, in the case of a minor, 3 years after the patient becomes of age or 5 years, whichever is longer. 

G. Current Records—Location and Facilities. The facility shall maintain adequate space and equipment, conveniently located, to provide for efficient processing of medical records (reviewing, indexing, filing, and prompt retrieval). 

H. Closed or Inactive Records. Closed or inactive records shall be filed and stored in a safe place (free from fire hazards) which provides for confidentiality and, when necessary, retrieval.

Monday, September 12, 2011

Article on private payer quality programs (subscription)

Read the Part B News article by Grant Huang. It features quotes from me, Anders Gilberg and Larry Epstein. No, I swear I didn't influence the list of interviewees!



09/12/2011

Monday, August 29, 2011

Article on fraud and abuse in MD MGMA MediNews

Thanks to the Maryland Medical Group Management Association for publishing this article. Its on page 10. Love international intrigue.

The International Industry of Mystery: Medicare Fraud
July-August 2011

Tuesday, August 23, 2011

Two articles on my view of ICD-10 implementation

Thanks to ICD-10 Watch for interviewing me after the Centers for Medicare & Medicaid Services (CMS) call on ICD-10. I felt it could have been soo much better! And here are some of comments to their reporter after the call.

ICD-10 Superbill: Will superbills survive ICD-10 implementation?

ICD-10 Implementation: How to get your staff ready to use ICD-10 codes