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LEVERAGING HIPAA...continued from page 9 August 2002 department when hired. She uses this to individual employee numbers allow card to gain access to restricted areas and companies to identify and conduct levels clock-in for work. During the course of of training appropriate to the access level her workday, the card is used in conjunction with a password, to access kiosk of employees. computers for Internet access and other Future initiatives will allow for Intranet terminals to view PHI. If medical information must be accessed from the HIM to populate the HRIS database automat- and outsourced Internet-based training department, the system that reads the ically when training is complete. bar coded information on the patient Conversely this same process provides record also reads the proximity card to timely notification when training compliance has not been met. This signifi- determine whether she has appropriate access level. This ensures information is cantly reduces resource consumption as checked out to a specific person (rather HIPAA training requirements grow. than a department), who is responsible This integration also enables the quick for the record until returned. Note that provision of specific information and every step of the way, this access is captured and logged for later archival, and if review purposes. documentation for audit or annual necessary, audit purposes. Conclusion–the real benefits Another possibility is the integration If the process appears daunting, bear in with human resources information systems (HRIS) such as ADP or similar The process should not be executed in mind that the steps are relatively simple. products that use an “open” database. one meeting or by a single department. Linking information classification codes The key to success is careful preparation WEB RESOURCES Editor’s conferences, compliance resources, and note: Website links. Don’t miss out–Be sure to Periodically read the articles BNA provides on the we publish a Members Only section of the HCCA listing of helpful Internet and email Website. resources. If you know of Websites that may be helpful to compliance professionals, please ■ HCCA’s quick survey results submit them to Margaret Dragon at http://www.hcca-info.org/html/ mrdragon@ziplink.net compliance.html#Survey Be sure to visit the HCCA Website: ■ HCCA’s Second HIPAA Readiness http://www.hcca-info.org to find the Survey most up to date listings of upcoming http://www.hcca-info.org/documents/ 10 of the classifications and the participation of business unit managers and supervisors. Their input in assigning the classifications to the information is essential. Starting small however, does not waste time. This process is rather modular and can be implemented over time. Organizations should not expect to get perfect information classifications. They can however, expect to achieve a vastly improved system that provides safe, timely, and functional information management in an increasingly complex environment. Once this initial process is complete, the opportunity to link classifications to human resources’ databases, physical security devices, HIM management programs, and time keeping instruments increase the effectiveness of business processes. Obviously, increasing benefits are derived proportionately from the maximization of automation and the information that can be leveraged as a result. ■ report02_final.pdf ■ EMTALA changes–pages 31469- 31479 http://www.access.gpo.gov/su_docs/ fedreg/a020509c.html ■ Review of Medicare Outlier Payments at Rhode Island Hospital for Fiscal Year 1999 http://oig.hhs.gov/oas/reports/region1/ 10100527.pdf Continued on page 12
By Norman Radies Editor’s note: Norman Radies is the Chief provider must meet the physician <strong>Compliance</strong> Officer for Pediatrix Medical supervision requirements, while the Group, Inc. He may be reached at services of auxiliary personnel in the 800/243-3839, Ext. 5133. outpatient setting must meet the requirements of the “incident to” rule. Like many physician practice This rule requires the physician to personally render a professional service to organizations, increased utilization of non-physician which the auxiliary personnel’s service is practitioners (NPPs) has been necessary an incidental, yet integral part [of the to meet the needs of patients and diagnosis and treatment of a patient’s clients. Correspondingly, increased regulatory scrutiny of services rendered by however, that the physician must see injury or illness]. This does not mean, NPPs has elevated the need to ensure the patient on each occasion of service that all your i’s are dotted and t’s are (e.g., routine follow-up visit) by auxiliary personnel. Use of the “incident to” crossed. If you do business in multiple states and serve a Medicaid population rule also requires that auxiliary personnel are employed by the physician and in each, you will likely be faced with a complex set of issues when staffing your are unable to be paid directly for their practices, scheduling your patients, and services. billing for services rendered by NPPs. Since most commercial payers do not The scheduling of patients, staffing of enroll NPPs and few non-government the practice, and documentation contracts explicitly define physician requirements are affected by the type of supervision requirements, this article NPP rendering services, as well as the will focus on the government payer location and type of services rendered. requirements, primarily Medicaid. For example, if you schedule a Medicaid patient for an initial visit The first step is to gain a clear understanding of the regulatory distinction office suite, the incident to provisions when a physician is not present in the between mid-level providers (i.e., described above cannot be met. Even a advance nurse practitioners, physician routine follow-up visit (except 99211) assistants, certified nurse midwives, performed by auxiliary personnel cannot be billed to Medicaid when a physi- etc.) and auxiliary personnel (i.e., nurses, psychologists, technicians, therapists, cian is not present and immediately and other aides). available in the office suite (“incident to” does not apply to the inpatient setting). Documentary evidence must sup- In order to bill their services under the physician’s name and provider identification number (PIN), a mid-level dent to requirements have been port that all relevant supervision/inci- met. NORMAN RADIES Lastly, it is important to recognize that some Medicaid programs limit reimbursement of NPPs services to as low as 65% of the physician fee schedule amount. Each state Medicaid program is authorized to establish its own physician supervision requirements for services rendered by NPPs. Physician supervision requirements can range from “physician is available by telephone” to “the physician must be present and immediately available to assist while the service is being rendered.” Maintain oncall logs and attendance records to support that supervision requirements have been met. Some Medicaid programs require the billing of all services by the actual provider. In other words, services rendered by a mid-level NPP must be billed under the NPP’s name and PIN, regardless of the level of physician supervision. Many state programs maintain a Website and on-line access to provider manuals. State Medicaid links are available through both government and private sites such as http://www.geocities.com/ medicaid.geo/index.html, Murphy’s Unofficial Medicaid Page. Continued on page 12 11 August 2002
Page 1 and 2: Volume Four/Number Eight August 200
Page 3 and 4: DON’T MISS OUT! ON THE CALENDAR U
Page 5 and 6: FOCUS ON ETHICS & COMPLIANCE Compli
Page 7 and 8: system. Other advantages include ea
Page 9: uation as unique. The divide and co
Page 13 and 14: feature article Editor’s note: Th
Page 15 and 16: there are so many issues that have
Page 17 and 18: 3. Have a witness! Do interviews wi
Page 19 and 20: leagues. Physicians can hear the me
Page 21 and 22: Alyse Hutchinson, Associate Complia
Page 23 and 24: many tasks forces as they deemed ap
Page 25: Editor and Publisher: Margaret R. D

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