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ROI in the Business Office: Why HIM Should Keep a Watchful Eye – HIM Scene

Posted on August 16, 2017 I Written By

The following is a HIM Scene guest blog post by Lula Jensen, MBA, RHIA, CCS, Director of Product Management at MRO.  This is the second blog in a three-part sponsored blog post series focused on the relationship between HIM departments and third-party payers. Each month, a different MRO expert will share insights on how to reduce payer-provider abrasion, protect information privacy and streamline the medical record release process during health plan or third-party commercial payer audits and reviews.

According to most business office staff, pulling information and releasing medical record documentation to payers is a necessary evil to get claims paid and reduce accounts receivables. It is not their core competency.

Whether the request is unsolicited or solicited by the payer, time required to compile information and respond wreaks havoc on business office productivity. Also in efforts to meet payer deadlines and expedite claims, human mistakes can be made. Incorrect patient information might slip through the cracks.

Despite concerns, many business office directors prefer that payer disclosures be sent out by their own business staff—versus by the HIM department. If your organization follows that practice, this HIM Scene blog post is for you.

Two Types of Business Office Requests

There are two instances of business office Release of Information (ROI) to know: unsolicited and solicited requests. The unsolicited process takes place when medical documentation containing all the additional information pertinent to the service being billed is submitted proactively by the provider with the initial claim. The solicited process occurs when the original claim is sent without additional supporting medical record documentation and the payer subsequently (during the adjudication process) determines that additional information is needed. The payer then places a request for the additional documentation from the provider.

Unsolicited Releases During Claims Processing

The purpose of releasing information during claims processing is to expedite payment. In an effort to get the claim paid faster, medical records are sent proactively with the claim. This is especially true for high-dollar claims, payer policies, readmissions within 30 days and the published Office of Inspector General (OIG) Work Plan.

Sounds like a good intention with the organization’s best financial interests in mind. However, three concerns arise when business offices send medical record documentation to payers—versus having HIM professionals take charge.

  1. Business office staff may not know which parts of the medical record will be required to support the claim. Often, the entire chart is sent—a process that is not practical for high-dollar or long-length-of-stay cases.
  2. Sending the entire record is also not compliant with HIPAA’s Minimum Necessary Standard. By sending too much information, hospitals are at risk for HIPAA breach.
  3. Upon receipt of prepay documentation, the payer’s staff logs each record received, scans or otherwise digitizes the documents, and incorporates them into their own electronic systems. This creates a huge administrative burden on payers.

Similar challenges ensue with solicited payer medical record requests that occur during the adjudication process or retrospective reviews.

Business Office Disclosures for Payer Audits and Reviews

There has been significant uptick in payer audits and reviews, a topic that was covered by HIM Scene last month. This includes governmental and third-party commercial. According to one central business office director at an MRO client site, “The pull lists for payer audits and reviews keep getting longer and the piles of medical records to send keep getting higher.”

To reduce administrative burdens with payers, some organizations are allowing payers direct access to their EMRs and EHRs to obtain the required information during audits and reviews. While this process may lighten the load for billing personnel, it is laden with additional privacy risks.

Business office personnel complain about the travails of responding to all the various requests for records. However, a significant number of business office directors still insist on owning the ROI process for payer audits and reviews. When this is the case, there are several important steps for HIM directors to consider.

Three Steps for HIM: Educate, Track and Talk

For both types of business office disclosures, it is important to educate billing staff about the implications of a HIPAA breach and privacy risks listed above. Establish an organization-wide standard for ROI to keep PHI safe during all types of business office disclosures. Educating all personnel involved in business office ROI (whether for claims processing, audits or reviews) helps relieve frustration with the record release process.

Billers should also track which specific records, and what sections of each, were sent. By documenting and then reviewing this information, organizations gain valuable knowledge about payer trends—insights that can be used to prevent denials and negotiate more favorable terms for payer contracts.

Collaborate with privacy and the business office to determine which release information to track. Then establish a common database or software application to document each release to payers. Here are four ways to make the most of business office ROI tracking data:

  • Look for patterns in what payers are requesting. Any trends in payer request activity could offer opportunities for provider improvement.
  • Identify risk. Analytics can help business offices detect weaknesses in the revenue cycle, involving coding, documentation or other internal processes.
  • Educate coders, biller, collectors, physicians, etc. on payer trends and how collaboration can promote accurate, complete billing for services rendered and support a claim via medical record documentation.
  • Use data analysis. When payer contract negotiations arise, use payer trend statistics to your advantage in the next round of negotiations.

Talk with local payers and stay updated on policy changes related to claims processing, audits and retrospective reviews. Open communication with each payer is recommended to ensure records are sent in the most secure way possible. Communication with payers also reduces phone tag and minimizes payer-provider abrasion.

Finally, due to the importance of collecting medical record documentation, health plans are willing to pay for records. Business offices and HIM departments fulfilling these requests are encouraged to discuss and pursue reimbursement from payers.

About Lula Jensen

In her role as Director of Product Management for MRO, Jensen drives product enhancements and new product initiatives to ensure MRO’s suite of solutions enable the highest levels of client success and end-user satisfaction. She has more than 15 years of experience in healthcare, focusing on Health Information Management (HIM), Revenue Cycle Management, analytics, software development and consulting. In addition to holding product management roles at McKesson Health Solutions and CIOX Health, she also served as Revenue Cycle Manager at Fox Chase Cancer Center and taught a course on ICD-9 CM Coding and Reimbursement at Bucks County Community College. Jensen is an active member of the Healthcare Financial Management Association (HFMA), American Health Information Management Association (AHIMA) and Pennsylvania Health Information Management Association (PHIMA); she is a 2005 PHIMA Scholar Award recipient. Jensen holds a B.S. in HIM from Temple University and an M.B.A. in Health Care Administration from Holy Family University.

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Finding Civility in Payer Relationships: Audits, Reviews and HIM – HIM Scene

Posted on July 19, 2017 I Written By

The following is a HIM Scene guest blog post by Greg Ford, Director, Requester Relations and Receivables Administration at MRO.  This is the first blog in a three-part sponsored blog post series focused on the relationship between HIM departments and third-party payers. Each month, a different MRO expert will share insights on how to reduce payer-provider abrasion, protect information privacy and streamline the medical record release process during health plan or third-party commercial payer audits and reviews.

Civility is defined by Webster’s as courtesy and politeness. It is a mannerly act or expression between two parties. While civility in politics has waned, it appears to be on the rise in healthcare.

New opportunities for civility between payers and providers have emerged with the shift from fee-for-service to value-based reimbursement. Population health, quality payment programs and other alternative payment models (APMs) are opening the door to better collaboration and communications with payers. Optimal patient care is a mutual goal between payers and providers.

HIM professionals can also contribute to stronger payer-provider relationships. Our best opportunity to build civility with health plans and payers is during audits and reviews. HIM professionals who take the time to understand the differences will make notable strides toward a more polite and respectful healthcare experience.

Payer Audits vs. Payer Reviews: What’s the Difference?

It’s no secret to most HIM professionals that the volume of health plan medical record requests continues to increase significantly. In fact, between 2013 and 2016 the number of requests for HEDIS and Risk Adjustment reviews increased from one percent to 11 percent of the total Release of Information requests received by MRO.

The main difference between audits and reviews is the potential negative financial impact to providers. Payer audits include risk for revenue recoupment while payer reviews do not.

For example, audits conducted by third-party payers are intended to recoup funds on overpaid claims. The most common reason for a post-payment payer audit is to confirm correct coding and sequencing as billed on the claim to determine if payment was made to the provider correctly. In audits, the health plan’s intention is to recoup funds on overpaid claims.

Payer reviews do not carry financial risk to the provider. Instead, payer reviews deliver valuable insights providers can use to improve their relationships with health plans and patient populations.

The Upside of Payer Reviews

HEDIS and Risk Adjustment reviews are the most common types of payer reviews. Payer data submissions for HEDIS are due to the National Committee for Quality Assurance (NCQA) by June of every year. Medicare Risk Adjustment results are due in January and Commercial in May.

Since these payer reviews both overlap and occur simultaneously, HIM departments are deluged with medical record requests. Understanding the importance of these reviews improves communication between HIM, Release of Information staff and health plan requesters.

HEDIS Reviews

HEDIS reviews can benefit providers during contract negotiations because the HEDIS performance rankings can be used to gauge the quality and effectiveness of different health plans for potential participation with the facility.

Risk Adjustment Reviews

With these reviews, health plans are required to prove the needs of the population to CMS so they can continue to provide services for higher risk patients and pay providers for the care of this population.

In both cases, medical records are needed to provide the analysis, so HIM is involved.

HIM’s Role: Reimbursable Release of Information

In 2015, 85 percent of MRO’s audit and review requests came from third-party vendors representing health plans. Both post-payment audit and review requests are typically chargeable to the requesting party. Due to the importance of collecting medical record documentation, health plans and payers are willing to pay for records.

HIM professionals are encouraged to pursue reimbursement for payer requests. This is especially true if your HIM department is working diligently to accommodate the payer deadline for record receipt.

A provider’s Release of Information staff should be able to work directly with these requesters to ensure payment for the timely delivery of records. HIM professionals can reduce payer-provider abrasion and ultimately strengthen relationships to improve compliance. It’s the first step to increasing civility in healthcare.

Watch for our August HIM Scene post to learn more about how to secure patient privacy when sending records to payers and health plans.

About Greg Ford
In his role as Director of Requester Relations and Receivables Administration for MRO, Ford serves as a liaison between MRO’s healthcare provider clients and payers requesting large volumes of medical records for purposes of post-payment audits, as well as HEDIS and risk adjustment reviews. He oversees payer audit and review projects end-to-end, from educating and supporting clients on proper billing practices and procedural obligations, to streamlining processes that ensure timely delivery of medical documentation to the requesting payers. Prior to joining MRO, Ford worked as Director of Operations and Sales at ARC Document Solutions for 15 years. He received his B.A. from Delaware Valley University.

If you’d like to receive future HIM posts in your inbox, you can subscribe to future HIM Scene posts here.

The Disconnect Between Patient Experience and Records Requests – HIM Scene

Posted on April 19, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the HIM Series of blog posts. If you’d like to receive future HIM posts in your inbox, you can subscribe to future HIM Scene posts here.

This week I met with one of the digital marketing team at a children’s hospital. We had a great conversation about the hospital website and the way the hospital’s website represented the organization to the patient. Plus, we talked about how patients choose to interact with the hospital through their website. There are a wide variety of patient requests through the website, but one of those requests was a request for their patient record.

It wasn’t really a surprise that this digital marketer didn’t really know the details of what’s required for a patient to make an appropriate medical record request from his hospital. In his defense, he didn’t usually answer the questions, but just created the website that collected the questions. However, it was quite clear that the workflow for any medical records request was to send it to their HIM department and let them figure it out.

Most organization then have their HIM staff play phone tag with the patient to explain how to make a proper records request which will allow them to release the information to the patient. The progressive organizations might send the patient an email. However, many of them will then ask the patient to mail, drop off or fax in the official records request. If this sounds painful, I can assure you that it’s as painful as it sounds.

This illustrates the massive disconnect between creating a great patient experience and most organization’s current records request process. Please note that I’m not blaming the digital team at hospitals for the issue and I’m not blaming the HIM people for this problem. I’m blaming the disconnect between the two organizations because the only way to solve this problem is to have both organizations involved.

The best patient experience would actually be for the patient to go to their patient portal and download their whole record. Maybe we’ll get their one day, but there are hundreds of systems in a hospital where a patient’s data is stored. So, it’s going to take a while for us to reach the point where a patient can self-service their data requests.

Since I’m not holding my breath on this amount of data sharing happening between disparate systems, I’m more interested in making the current processes so it’s a seamless experience for the patient. If you can model a medical records request on paper, then you can do it digitally. To their credit, I’ve seen a few organizations working on this. In fact, their system is part education about records requests and part getting the information that’s needed to fulfill a records request.

It’s time that HIM and a hospital’s digital and tech teams come together to make the process for requesting records a seamless patient experience. And if you think using a fax machine is a seamless experience for patients, then you’re part of the problem.

If you’d like to receive future HIM posts in your inbox, you can subscribe to future HIM Scene posts here.

The Cost of Encouraging Patient Engagement

Posted on June 15, 2016 I Written By

Erin Head is the Director of Health Information Management (HIM) and Quality for an acute care hospital in Titusville, FL. She is a renowned speaker on a variety of healthcare and social media topics and currently serves as CCHIIM Commissioner for AHIMA. She is heavily involved in many HIM and HIT initiatives such as information governance, health data analytics, and ICD-10 advocacy. She is active on social media on Twitter @ErinHead_HIM and LinkedIn. Subscribe to Erin's latest HIM Scene posts here.

We all know that healthcare providers want to encourage patient engagement to ensure patients have the information they need to manage conditions and share information with other providers. There has been a longstanding push for the adoption and maintenance of personal health records for many years to give patients the power to share and disseminate information wherever it is needed. We have seen a remarkable new interest in this with Meaningful Use and population health initiatives. Since HIM professionals are charged with maintaining and producing legal copies of records, we are aware that the tasks surrounding these processes can be very expensive. This is especially true if any of the tasks are not handled properly and breaches of protected information occur.

My concern is that lately I have heard many discussions that are pushing for more access yet with fewer costs to patients to encourage patient engagement. Some are even pushing for patients to have “free” access to records- paper or electronic. Don’t get me wrong, I am a huge proponent for patients having copies of their records and I personally keep copies of my own records. The Office of Civil Rights (OCR) recently published further guidance on charging for records. In a nutshell, the OCR says: “copying fees should be reasonable. They may include the cost of labor for creating and delivering electronic or paper copies; the cost of supplies, including paper and portable media such as CDs or USB drives; and the cost of postage when copies of records are mailed to patients at their request.” The OCR actually has the authority to audit the costs of producing records if they feel your organization is violating this patient right and overcharging for release of information.

Living in a state such as Florida where the state law has allowed facilities to charge up to $1 per page means most facilities have charged $1 per page without blinking an eye. The latest OCR guidance has led to questioning if that amount is actually “reasonable” or true to cost. Afterall, HIM professionals must use expensive systems, supplies, and labor costs to produce these records. Many organizations have outsourced release of information functions (another cost) but it is still the responsibility of the custodian of records to oversee the processes for compliance.

That being said, it is beneficial for HIM departments to evaluate the expenses and methods used to produce records as technologies and laws change. Dr. Karen Desalvo of the Office of the National Coordinator (ONC) strives to lead the EMR interoperability movement. At the top of the ONC’s list of commitments is consumer access to records. HIM professionals should continue to assist in the quest for interoperability and electronic data sharing at the notion of patient engagement. We must lead patients to use EMR patient portals and facilitate the efficient electronic data sharing among healthcare providers. We must be creative in lowering overhead costs to produce and maintain the records in order to ensure costs are affordable for healthcare consumers. There will always be costs associated with this important task, whether on the provider’s end or the patient’s end, just as costs are incurred with most services or products in every industry.

If you’d like to receive future HIM posts by Erin in your inbox, you can subscribe to future HIM Scene posts here.

HIM Professionals and the Patient Portal

Posted on October 21, 2015 I Written By

Erin Head is the Director of Health Information Management (HIM) and Quality for an acute care hospital in Titusville, FL. She is a renowned speaker on a variety of healthcare and social media topics and currently serves as CCHIIM Commissioner for AHIMA. She is heavily involved in many HIM and HIT initiatives such as information governance, health data analytics, and ICD-10 advocacy. She is active on social media on Twitter @ErinHead_HIM and LinkedIn. Subscribe to Erin's latest HIM Scene posts here.

One of the hot topics in healthcare that has been consistently developing and growing over the past few years is the patient portal. Since many different EMRs and portal platforms are used across hospitals and physician offices, each facility is left to develop policies and procedures for what will be released through the portals and how they will be used. There are no specific standards for patient portals, aside from those needed to meet Meaningful Use requirements, which results in different experiences and functionality for end users.

HIM involvement with patient portal implementations has been a little spotty over the years from what I gather from my peers. I heard someone say we “missed the boat” on patient portals. I don’t necessarily agree but I do see inconsistencies in the level of HIM involvement. When it comes to developing policies governing the content that will be released through the portal, HIM professionals are the experts on this initiative. HIM professionals have always been the stewards of the medical record and keeping release of information processes secure and appropriate. There has been a focus on encouraging patients to keep a personal health record long before EMRs and patient portals came to exist. So how could some HIM professionals get left out of the patient portal process?

My first assumption is that patient portals came to exist mostly, although not solely, as a result of Meaningful Use initiatives. If you have had similar experiences to mine, you have witnessed Meaningful Use initiatives typically being handled by IT professionals. As a result, patient portals have fallen under that umbrella from a technology standpoint but I see great opportunities for HIM professionals to be involved to optimize the content shared for the end users. Since the main intent of patient portals is to encourage patients to be engaged in their own care, these portal initiatives have much more benefit beyond attesting to Meaningful Use and should be incorporated into organizational strategic plans for patient engagement.

There has been a lot of discussion around the struggle of increasing patient portal participation. A common factor in patient portal adoption is the lack of patient competencies in using the technology involved. Some patient populations do not frequently use computers, email, or mobile applications which are all a part of the patient portal functionality. To address this at my facility, we created a position within the HIM department to coordinate all patient portal functions including enhancing the user experience by creating frequently asked questions and answers, troubleshooting issues that patients may have when attempting to login, and resetting portal passwords as needed among many other initiatives. Policies were developed to address who can have access to the portal information, how the patients confirm their identity to log in, what is released, and the duration of the availability of the information. We have an interdisciplinary team that contributes to the patient portal process but having the point person reside in the HIM department makes the most sense for governing the entire concept.

One thing to remember is that patient portals do not eliminate the need for traditional release of information processes because we release information to many different requestors for different purposes. The portal does not include every patient document due to the sensitive nature of some results therefore requests for entire charts and abstracts are still necessary in some cases. Patients should participate in the portal for the personal benefit of being proactive in their own healthcare but they should not expect it to replace release of information. I encourage HIM professionals to be involved in the patient portal process in an administrative capacity. The strides made with patient portal optimization are key in optimizing the transition to health information exchange (HIE) concepts which also require heavy HIM involvement.

If you’d like to receive future HIM posts by Erin in your inbox, you can subscribe to future HIM Scene posts here.

Why Can’t Release of Records Be Automated Through A Patient Portal?

Posted on March 31, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I was in a recent discussion with one of the leading providers of release of information services, HealthPort about EHR’s impact on the release of health records. In our discussion, I asked why the release of health records can’t be completely automated through a patient portal. In my mind, meaningful use is requiring that healthcare organizations put a patient’s record up on a patient portal, so shouldn’t that mean that the release and disclosure of patient records would become obsolete?

Of course, I was applying a limited view to what’s required when a disclosure happens and who is making the records request. In most cases, it’s not the patient requesting the record and these third parties don’t have access to the patient’s portal. Plus, the release and disclosure of patient records often requires accessing multiple systems along with assessing which information is appropriately included in the disclosure. The former is a challenge that can be solved, but the later is a complex beast that’s full of nuance.

In order to clarify some of these challenges and explain why a patient portal won’t replace all records requests, here’s a short interview with Jan McDavid, Esq., General Counsel at HealthPort.

Q: What are HIPAA requirements around “charging” for copies of records, and what are considered “reasonable” costs?

A: HIPAA is very clear that its pricing applies only to copies provided to “individuals,, which HIPAA defines as the person who receives treatment—the patient. HIPAA guidance pertains only to patient requests for medical records, approximately seven percent of all requests received by healthcare providers.

The majority of records are requested by physicians for continuing care, governments for entitlement benefits, insurers, and inquiries from attorneys, according to internal data from HealthPort’s 2014 record release activity nationwide.

Within the realm of patient requests, providers can charge patients no more than their labor costs to produce the record, plus supplies and shipping. No upfront fee to search or retrieve records may be charged to patients.

Q: Why shouldn’t records just be free now that they are electronic?

While many believe the cost to produce records should be negated once information is digital, there are misperceptions and logistics that must be understood. The process of disclosure management (release of information) involves many steps that still require human intelligence and intervention—especially on the front end of the process (receiving, validating and approving the request). Here are three examples:

  • The authorization must be adhered to strictly, which often requires contacting the requester and explaining that some of the records they requested may not be available, or may require very specific patient authorization.
  • Information is commonly pulled together from multiple sources and systems (paper and electronic) to fulfill a request. While providers are working toward completely electronic environments, almost all still have a combination of paper and electronic. Depending on who makes the request, every single page of a record may require review.
  • Staff releasing records must be trained on HIPAA, HITECH, the Omnibus Rule, state and federal subpoena requirements, and specific state and federal laws for drug, alcohol, HIV/AIDS, mental health, cancer, genetics, minors, pregnancy, etc.

Q: If the EHR is in the portal, what other records aren’t in the EHR that HIM staff has been aggregating in a records request?

A: Not all patient information is automatically included within the patient portal view, nor should it be. Each provider organization determines what EHR information is posted to the portal and what patients can do within the portal (e.g. requesting refills, scheduling appointments, viewing lab results, etc.). HIM experts are key in these decisions.