Delays in Breach Notification = OCR Fines

The first OCR fine for 2017 was issued to Presence Health for delay in notifying 836 patients of a breach experienced in 2013. Presence Health met the requirement of notifying HHS of the breach within 60 days after the end of the calendar year in which the breach is discovered (notification took place January 31, 2014).  

There have been many articles written about the need to investigate a potential breach, and establish what happened, how it happened and do a thorough job in getting as complete as possible, the names of all individual affected by the breach so that notification can take place. What you don't want to do is forget the breach notification rule that states that for a breach of any size, patients must be notified "without unreasonable delay, but in no case longer than 60 days." Certainly, there are a few exceptions like law enforcement delay and other rare situations, but the rule is clear.

The fine is significant enough, but remember that along with the OCR fine, generally comes a corrective action plan (CAP). In this particular case, there was a requirement to revise existing policies and procedures related to the Breach Notification rule. Training materials would also need to be updated and provided to appropriate workforce members with documentation of the date the training was provided. Evidence of compliance with the CAP is always required.

A couple of key takeaways include noting that the OCR will investigate all breaches and that it generally takes a good bit of time for the OCR to make their determination based on information requested and provided. The fine, if infractions are identified will follow and the CAP will take resources and an investment on the facility's part. Breaches and their impact are significant and the financial costs associated with them run deep.  

Read the full article here   

  

Production Pay and Revenue Cycle Management

AHDI has published a position paper that was released at the annual convention in Indianapolis earlier this month.  In this paper, the association presents the current state of healthcare documentation and why it is essential to consider a more flexible compensation model that takes into account the many other duties of the professional medical transcriptionist. 

In a recent article published in For The Record, Sherry Doggett, President of AHDI states "There are many things that medical transcriptionists perform in many scenarios in the work envionment that really are not conducive to production pay."  Additionally, healthcare documentation specialists (MTs) are often asked to move from one computer to another, a different transcription platform or system, work back and forth between straight transcription and speech recognition, work multiple accounts and different doctors through a single shift.  All of these transitions are counter productive.  

Take into consideration different account specifics that vary within a single account to accommodate different physicians' style and add the numerous queries and flags MTs notate throughout the day, the corrections they must make to errors during dictation.  These things take time - uncompensated time and you have the makings of upheaval that may erode the future of this important sector.  When allied health professionals consider their work to be of decreasing value and say they work in a "sweatshop for minimum wage," it is beyond time to pay attention to the type of comments seen here.  

Year after year, healthcare documentation specialists have been asked to do more for less while the commoditization of this profession has been squeezed from every angle.  It is considered a cost center when there has been a failure to recognize the value of this knowledge-based field.  Consider coding.  How can coders code without the documentation that tells the unique patient's story and is the basis for coding?  How is it we will be able to move successfully into ICD-10-CM/PCS without better and more specific documentation?  

It is interesting to observe the conflicting opinions about whether or not front-end speech is better for quality patient care.  On the topic of front-end speech, Jeffrey Linder, MD believes that "physicians are more likely to see and respond to alerts if they are using an EHR."  While the AJR published a study that revealed a 23% error rate in front-end speech compared to 4% in dictation/transcription reports.      

In all the efforts to employ technology to improve healthcare, the technology advances absolutely have their place and merit in moving us away from paper.  That said, providers are faced with more demands, larger case loads and in truth they need choices that suit their preferences that will lead to efficiencies.  Forcing any one solution on multiple providers will be met with resistance and will not accomplish the goals of patient safety and better outcomes.  Rather, in a current article, Nick vanTerheyden, MD states "The most appropriate means of documentation is the one that is most effective and productive to a physician's workflow.  It will take a combination to deliver the highest clinican satisfaction."    

When all is said and done, it seems that in order to get more information, meet the needs for the clinical documentation improvement required for ICD-10-CM/PCS, and achieve meaningful use goals, healthcare organizations that intentionally keep dictation and transcription as well as other options will come out on top.  Looking at creative compensation methods for the professionals behind the scenes that help produce these quality documents from which coding and billing take place must move higher in priority in order to keep them engaged.  Many have left the profession already due to poor compensation and we cannot afford to lose any more at a time when the language of medicine is a premium concern.  We must value these hard-working professionals and look at other areas for controlling costs in the revenue cycle.     

Smart Moves for Smarter EHRs

In a couple of recent articles that are not connected, there is an underlying connection.  One, in "For the Record" discusses The Hazards of Note Bloat and the unintended consequences of having a lot of information that doesn't truly say much about the complexity of the patient's condition, not to mention that it is "difficult to view, notes lengthen and errors accumulate."  But wait, aren't EHRs supposed to reduce errors?  The article goes on to explain how narrative (dictation/transcription) notes have been reduced, but not completely eliminated.  It also discusses speech recognition and its implementation this month. 

The next article talks about the value of outsourcing as a cost-savings process to reduce costs and how this is happening in a big way in Canada.  This model has been shown again and again to be cost effective and many hospitals across the US have already embraced this practice to help reduce costs.

In yet another article, 3 major healthcare groups were identified as having caught the financial flu and are not doing particularly well at this time. 

In reviewing the 3 unrelated articles, it became apparent that there may be a myopic view of how to balance reducing costs with optimal EHR utilization.  Consider this.  EHRs are here to stay.  We need them and the value they bring to healthcare overall.  What we don't need is documentation that doesn't improve the quality of the patient encounter.  We need streamlined, content-rich, not bloated notes that drone on endlessly with what the previous note stated.  We need to optimally enable physicians so they have the time to see a growing patient population, not spend endless hours doing their own data entry.  We also must get the level of detailed specificity now that will be needed as the ICD-10 date edges ever closer.  Healthcare organizations must be fiscally healthy enough to provide care and continue to be viable as baby boomers get to Medicare age.  So yes, they do absolutely need to cut costs in the right places but keep those that enhance their revenue capabilities. 

Here's the conundrum in summary.  If healthcare organizations and hospitals focus only on reducing costs at the expense of eliminating medical transcription/editing, they are using a tunnel vision approach that will reduce costs but will simultaneously fail to optimize reimbursement.  Complete, detailed documention renders optimal coding, which leads to appropriate and optimal reimbursement.  If this process becomes muddy through "note bloat" or abbreviated input from extremely busy clinicians, the revenue cycle process may breakdown and the endless cycle of trying to reduce costs and not optimize documentation will continue. 

Stop the broken cycle of cost-cutting measures as the only option.  It's time to see the bigger opportunity and realize the value gained in the outsourced model of quality dictation/transcription and speech editing process to capture all the details needed for ICD-10 today.  This can get healthcare organizations over the financial flu and on the road to recovery. By adopting a practice of excellent documentation practices, these 3 unrelated items can become related in a way for long-term success with the EHR and improve patient outcomes as one of the most important goals.          

Medical Transcription - The Gold Mine

While EHRs are going in rapidly across the country, it's important to remember that the demand for value in reducing costs, improving patient safety and providing access to more Americans still leads the charge when it comes to why we move to electronic systems in health care. One of the best ways to enhance the value in EHR systems data mining and research is to keep a robust, detailed record of each individual patient who has a unique history unlike any other. Medical transcription/editing captures details provided by clinicians that are crisp and precise filled with data and information that can get us to the goal of improved patient outcomes through the application of secondary healthcare data. There are a number of reporting agencies that are making results available to anyone who is interested in taking a look. Organizations like the Leapfrog Group, Health Grades, Bridges to Excellence along with a score of others, provide information on various diseases and outcomes. Some secondary data use reporting is required such as core measures reporting. And when I say required, I mean that there is a 2% penalty in market-basket outcomes if you choose not to report. It is probably reasonable to anticipate that the number of hospitals reporting outcomes and the agencies to which they report will also increase. This is why it is a key fundamental and logical approach that the use of dictation and medical transcription or medical editing with speech recognition tools will be the best way to capture these necessary details and be able to produce content-rich results when reporting outcomes to continuously improve care. Nine of 10 Healthcare executives agree in a survey conducted by Pricewaterhouse Coopers (PWC) that secondary use of health information will significantly improve the quality of care and that those benefits will improve in the future. A clear two/thirds anticipate a huge increase within the coming two years. (1) Consider the AMIA findings of the gains that can be made from the expansion of knowledge about diseases, treatments and make strides in public health along with advances in privacy and security. (2) There is much to be gained as we move into this era of using secondary data to advance healthcare and this can best be achieved if we continue to capture the details provided by clinicians through the dictation and interpretation process. The outcomes, however, will only be as good as the content from which the information comes - that's why dictated/transcribed reports are a gold mine of information. To in any way short-cut details will severely limit the wide-range of benefits.

EHR Process: Speak Your Preference

EHRs and meaningful use (MU) are getting so much publicity. There is the carrot (financial incentive) and stick (reduced reimbursement) approach to get them in place by 2014 with the promise of reducing costs, improving patient outcomes and patient safety. Through all of this publicity, seems we haven't heard enough from the chief care giver - the physician.

Many of the EHRs that have been approved by CCHIT don't include a dictation/transcription option. CCHIT may not ultimately be the approval body. Interestingly enough, MU definitions haven't been finalized. So there are goals to meet that haven't been fully defined and timelines that associations like the AMA and AHA along with a host of other national groups that have spoken clearly about how the all or nothing MU criteria plan is ill-advised. They agree that the timeline is not realistic.

We probably all can agree that EHR implementation without meaningful use doesn't get us to the goals promised. And we understand that it is a given to migrate away from paper records. However, the rush to get it done seems to put physicians and a practical improved approach to healthcare delivery in the system that we have, in the backseat.

Let's look at this from an objective perspective. Now we have healthcare reform. That's great news for so many who don't have healthcare today. It means that an additional 32 million (estimated) Americans will have access to healthcare who previously did not or did if their conditions became critical enough for them to present to the ER. What will healthcare reform do to physician case loads? To hospital census? Let us not forget that we have an aging population with baby-boomers approaching retirement. Do we have enough physicians for all this increased volume?

Now let's look at how many EHR systems approach healthcare documentation. They are designed for the physician to become the data entry clerk - and in truth, many are operating this way today. VA's VISTA system, Kaiser Permanente, and there are a host of EHRs designed for ambulatory settings and physician office practice that utilize the same approach.

Here's a thought. Do you see the president of a bank entering deposits and counting out cash at his bank? No, so why would we ask our most highly educated member of the healthcare delivery team to become a data entry clerk?

Currently 1.2 billion patient reports are created by expert medical transcriptionists who have trained and many have become credentialed in their field. Narrative dictation captures the unique circumstances of each individual patient. No two patients are alike in their history and even presenting symptoms. And to leave out important details of the patient's additional illnesses can most certainly impact hospital and physician revenue. So why would we A. slow physicians down entering the detail and B. risk lower reimbursements?

The purpose of this blog post is just simply this. Consider: The physicians who are mostly going to be time and resource-impacted by EHR implementation need to speak out in favor of the ability to continue to document patient encounters in the most efficient and complete way. Physicians' voices must be heard in this evolution to electronic records. What EHR systems must do is provide an avenue for physician choice in documentation practices.

If physicians want to self-enter - then that should be an option. However, for those physicians with a patient case-mix that is complex and those with multiple medical problems, their option to continue to dictate will mean the difference in their ability to increase the demand on their time as patient loads increase.

Physicians - please speak up - be sure that you have options in how you document patient encounters. You are the CEO of the healthcare delivery team and the process needs to provide better patient safety and ensure that your time is optimized while ensuring appropriate reimbursements for all you do.

Changes in Healthcare, Changes in Medical Transcription

Let’s talk about change for a minute, shall we? Change is something that happens in every aspect of our lives – we get older (dang it!), our kids do, we move and relocate, we get new cars, we utilize better technologies, we have way more than 3 or 4 channels on TV, we don’t have to wash dishes by hand, we have energy efficient appliances that do more, cost less to use and in general improve our efficiency.

All change is not bad – but change is a fact of life. Let’s face it, many of us used to transcribe on typewriters with carbon paper or at the very least white out. We have seen various renditions of voice capture hardware. Long distance used to cost hundreds and hundreds of dollars on even modest plans. Now most everyone gets unlimited long distance for about $25 or perhaps even VOIP for a flat rate.

This industry has witnessed many changes and evolutions. We must embrace change – many of us should be change-agents by now because of the many changes we have witnessed, been through or otherwise led changes.

Most of you know what kind of crisis healthcare is in. And you also know that we have a President who vows to fix healthcare so everyone can have access. The debate is long and volatile about how to exactly get it done the best way, however, we know that the “status quo is not an option on the table,” as stated by Barack Obama. We have already been impacted in many ways by healthcare reform.

The drive to push costs down is being driven by a huge number of reasons. MS-DRG changes, ICD-10 upcoming, RAC audits nation-wide, POA (present on admission) to name a few and with 54% of the nation’s hospitals operating in the red and 80% of those with 500+ beds in the red, our healthcare system must change and is changing - now. That means we must evolve with this change.

I know many people like their present routines and don’t want to change, but the EHR is shrinking our market share. That’s simply the truth. Those with the best skills, the most differentiators and the willingness to change and evolve as our sector does will never worry about a job.

Did you know that people who are optimistic about change, even life-altering change live longer than those who are not? These people have the secret recipe of not only making lemonade with the lemons that come their way, they are also constantly seeking out enough lemons to make lemon meringue pie! Be creative and keep a smile close at hand.

We are not witnessing an end-game strategy, it is an evolving shift - and as Darwin said, “it’s not the strongest or the largest of the species that survives, but the one most adaptable to change.” So please everyone know what’s going on in our profession, be the best you can be – make yourselves indispensible to your employer! Be flexible and know what the drivers are in what’s taking place here and let’s move forward together and succeed!

Happy Memorial Day Weekend!

MT Relevance in Healthcare's Future

There is a lively discussion taking place here not just on the topic of mandatory credentialing but also the facts around MT relevance and our place in healthcare documentation's future. There are a number of great issues being presented and the burning questions seem to be larger than life.

Read this and more below:

For the purposes of history, very few professions willingly seek regulation and credentialing. AAMT/AHDI has always known we would have our work cut out for us by going down this road. But history has also shown that professions that are unwilling to self-regulate will either be (a) forced into regulation by the government or (b) forced out of relevance by technology and automation. Any unregulated, noncredentialed profession that can’t demonstrate a significant value-add is bound for marginalization. And unless you’re completely isolated from what’s going on in our industry right now, that is exactly what’s happening to our profession

Here is a final excerpt from that final post made by Lea Sims regarding what our choices are when faced with the reality of what is happening and why we need to engage this entire sector. We must face the facts of the transformation that is taking place - thought provoking:

...So…it’s really up to every MT, not to AHDI. How long can you count on your behind-the-scenes, no-credential, no-accountability, low-visibility role to sustain you in healthcare? Most experts say that within the next 5 to 10 years, a great deal of what you are doing will be automated (if you don’t believe that, you should be attending HIMSS) and all healthcare might need an MT for is to capture some complex narrative at the acute care level. All “normals” will give way to automation. All “templates” will give way to automation.

What value will you demonstrate to healthcare of the future? What cost-saving solution can you demonstrate? What ability to protect the patient can you market? What assistance with clinical decision-making can you offer? Instead of arguing with me here about what you are NOT, how much time are you spending thinking about what you ARE? You can say “no” to “risk management” as a value-add role, but what are you willing to say “yes” to? That’s all healthcare is going to listen to, folks.

When it comes to the art of this profession, at the end of the day, is our role to simply document what is dictated or is there an element of critical thinking involved? I have to say that some of the many MTs I know make sound decisions and corrections every day, many times a day - because they have the skill to do so. There is compelling information here that we all need to consider as those who would suggest that our role is clerical and therefore potentially just an expense that systems and technology can replace or do we choose to validate our skills and evolve them to the next wave in healthcare reform?

The issues around AHDI and what we do in support of MTs is substantial. That too, has evolved. Yes it is true that AAMT was different in earlier years, but as all things must, we had to change our mission and direction because frankly our members needed more. In order to provide membership with relevant and meaningful offerings, we too had to evolve with healthcare. Membership in AHDI is substantive and provides value in many forms. Through the Knowledge Base (KB), advocacy, credentialing, continuing education, leadership development, standards of practice, networking and more.

Will end this here but would ask that our members start speaking up and share what you think. And don't just tell us - tell those who are hearing misinformation. What is AHDI doing that we need to do more of? What aren't we doing that we should? And what do you think about some of the comments that have been made on this post? Do you agree or disagree? What further points need to made. We are listening - and your thoughts matter.

The Perfect Day

Everyone has a vision of the perfect day. Sunshine blue skies at the beach. Fresh powder on the slopes for spring skiing. A quiet afternoon with a favorite book. A day at the spa for pampering and indulgence. The list goes on and everyone has their own vision of what that day might look like. For me, the perfect day would be the one where the following takes place:

Morning: Healthcare documentation professionals everywhere have joined forces and now more than 200,000 have found common ground and been heard clearly above the noise and chatter of healthcare reform. They have united and have secured their future as professionals who have for years contributed tremendous value to patient care. This profession was long thought of as adding cost, but it has come to light that this documentation sector adds exceptional value to accuracy and completeness in a patient's medical reports. It is what we do, and yet so few people know it or appreciate our knowledge. They say "we type what is dictated." Anyone who has ever done this job knows it is so much more than that. Until we as a profession can put aside the pointing fingers at problems, placing blame, quit focusing exclusively on pay first, measure our contributions and begin to demonstrate the value add, we cannot experience that perfect day. Are you ready for that perfect day? I say it is long overdue. No matter how tough we think we have it, we don't have to look very far to see those in much worse circumstances. We have time to recast our future, but we cannot do it alone. Let's work together towards that perfect day.

Afternoon: The next part of my perfect day would be the evening news stating that scientists around the world have confirmed that we have finally slowed and turned back the clock on global warming. The news report would go on saying....Evidence now shows that so many people continue to do little things to make a big difference and there is now solid proof that the polar ice is once again gaining mass and polar bears are making a strong recovery. Fewer species are facing extinction and our timeline for climate change has dramatically improved. And with alternative energy sources and creative technologies, there is an excellent chance we can turn this around completely. Now that would be a perfect end to a most excellent day!

This week, we will celebrate Earth Day on 4/22 and National Arbor Day on 4/24. As we think about the things we can do to improve our world, let us also think about how we sustain our professional world and move it forward for a better career and one that brings not only job satisfaction at the end of each day but the promise for even better days ahead where we embrace new technologies and put our expertise to work. Now wouldn't that really be a perfect day? Be part of the solution - take action - talk to your employer today about the tremendous value you provide every day!