Manage My Practice

I am fortunate to be serving on the North Carolina MGMA Medicare Committee this year.  When we met yesterday, the members were asked why we wanted to be on the committee.  I said I couldn’t believe any practice manager wouldn’t want to be on the Medicare Committee!  I want to be on the front lines, asking questions and trying to understand the massive changes hitting our practices daily.  Don’t you? If you’re not a member of your local or state manager’s group and you’re not volunteering on one or more committees, why not?

Important Information and Reminders About the Upcoming Version 5010 and ICD-10 Transitions

CMS has resources for providers, vendors, and payers to prepare for the transition. Fact sheets available for educating staff and others about the transition include:

The ICD-10 Transition: An Introduction

Talking to Your Vendors About ICD-10 and Version 5010: Tips for Medical Practices

Talking to Your Customers About ICD-10 and Version 5010: Tips for Software Vendors

Compliance timelines, materials from CMS-sponsored calls and conferences, links to resources and sign up for email updates here

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Medicare FFS 5010 Program: Taking EDI to the Next Level- Ninth National Education Call on Medicare Fee-For-Service (FFS) Implementation of HIPAA Version 5010 and D.0 Transactions

August 25, 2010
2:00pm To 3:30pm EST

The Centers for Medicare & Medicaid Services (CMS) will host its ninth national education call regarding Medicare FFS’s implementation of HIPAA Version 5010 and D.0 transaction standards on August 25, 2010.  This session will focus on the 835 Electronic Remittance Advice transaction.  Subject matter experts will review Medicare FFS specific changes as well as general information to help the audience prepare for the transition; the presentation will be followed by a Q&A session.

Registration will close at 2:00 p.m. EST on August 24, 2010, or when available space has been filled.

Target Audience: Vendors, clearinghouses, and providers who will need to make Medicare FFS specific changes in compliance with HIPAA version 5010 requirements.

Subject: Medicare Fee-For-Service (FFS) Implementation of HIPAA Version 5010 835 Electronic Remittance Advice Transaction

Agenda:

* General Overview

* Medicare Specific Changes

* Timelines and Deadlines

* What you need to do to prepare

* Transaction Specific Issues

* Q & A

Conference call details:

Date: August 25, 2010

Conference Title: Ninth National Education Call on Medicare Fee-For-Service (FFS) Implementation of HIPAA Version 5010 and D.0 Transactions

Time: 2:00 p.m. – 3:30 p.m. ET

In order to receive the call-in information, you must register for the call. It is important to note that if you are planning to sit in with a group, only one person needs to register to receive the call-in data.  This registration is solely to reserve a phone line, NOT to allow participation.

Registration will close at 2:00 p.m. ET on August 24, 2010, or when available space has been filled.  No exceptions will be made, so please be sure to register prior to this time.

1. To register for the call participants click here.

2. Fill in all required data.

3. Verify your time zone is displayed correctly the drop down box.

4. Click “Register”.

5. You will be taken to the “Thank you for registering” page and will receive a confirmation email shortly thereafter.   Note: Please print and save this page, in the event that your server blocks the confirmation emails.  If you do not receive the confirmation email, please check your spam/junk mail filter as it may have been directed there.

6. If assistance for hearing impaired services is needed the request must be sent to medicare.ttt@palmettogba.com no later than 3 business day before the event.

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Social Media

Note: I am republishing this to my email subscribers because none of the links worked the first time around. I’ve fixed everything now – so sorry for the error – must have been healthcare fatigue!

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I’ve noticed that a lot of people in healthcare seem unusually tired and even, if I dare say so, somewhat cranky.  This includes me.  I’ve decided we’re all suffering from healthcare fatigue – fatigue from dealing on a daily basis with so much change, uncertainty, and financial stress.  Here’s my top ten list of healthcare management stressors accompanied by posts I’ve written that discuss the topic or suggest resources for the challenge.

10. Red Flags Rules – on again, off again, patients don’t want to have their pictures taken or let you copy their driver’s licenses.

• Red Flags Rules (RFR) Delayed for the Fifth Time – This Time Until December 31, 2010
• Red Flags Rule and Identity Theft Prevention: You Don’t Have To, But You Should!

9. HIPAA - don’t be fooled, HIPAA is not something we handled years ago and it’s taken care of; there are new requirements and penalties associated with HIPAA breaches.  HIPAA is a biggie and something that now infiltrates almost every facet of healthcare.

• ARRA Changes Rules for HIPAA – Did You Miss These Three February Deadlines?

8.  Employment Uncertainty – both for you and your staff – the aftermath of layoffs can be even more demoralizing to those who didn’t lose their jobs.  Also, many healthcare entities are still freezing raises.  If I hear one more time “we’ll just have to do more with less” I might just scream.

• My Take on “10 Ways to Keep Employees Happy” in Medical Practices
• Dear Mary Pat: Should Staff Be Allowed to Use The Internet on Their Smart Phones at Work?

7. Unrealistic Workloads – directly related to #9, most staff and managers have much more work to do than they did just two years ago. Couple that with the ability for managers to be available and work by computer, phone, text message, email or Skype 24/7 and you have fatique that you understand only when you truly, truly stop and wind down for more than three days at a time.

• Long Vacations are Good for Employees, the Company and Me!

6.  Hospitals Buying Practices – this could be a good thing or a bad thing, but as you and I know, change is completely unnerving to most people.  Hospitals have very different cultures than private practices and trying to marry the two takes skill, patience and excellent leadership.

• Change in the Group Medical Practice: Customers, Consequences, Control, and Culture

5.  Stimulus Money for Using EMRs – it’s a big decision and many practices are very nervous about purchasing an EMR.  Many think that meaningful use components are unrealistic and even more are fearful of the inevitable productivity drop when the EMR is implemented and for months afterwards.

• ARRA Eligible Providers: Who Is Eligible to Receive Stimulus Money and How Much is Available Per Provider?
• FAQ on HITECH, Meaningful Use, Eligible Providers, and the Stimulus Money
• Ten Reasons Why (Some) Physicians Aren’t Rushing to Adopt EMRs
• Electronic Medical Record Guru Rosemarie Nelson Reveals Best EMR Product on the Market Today

4. Unhappy Patients – lots of patients are also trying to do more with less (argghhh!) and are avoiding coming to the doctor whenever possible.  The front desk staff and the phone staff in particular are getting a lot more heat when they inform patients they’ll have to make an appointment.

• 50 Customer Service Ideas to Treat Your Patients to Friendly, Easy and Unexpected Service
• How To Be A Billing Advocate for Your Patients
• How to Apologize to a Patient
• A Memo to the Staff: The Preciousness of Patients

3.  PECOS – be glad if you don’t know what PECOS stands for, or be very, very afraid.

• Providers Without a PECOS Record Will Receive a Letter From Their Medicare Administrative Contractor (MAC)
• My Notes from the CMS Open Door Forum on May 19, 2010: PECOS, DMEPOS and Blue Ink on Paper Forms
• Is Your Practice Ready for the 60-Day PECOS Countdown?

2. Medicare Reimbursement – this year has been as exhausting as watching a single point of ping pong played for hours – there will be cuts, there won’t be cuts, there will be cuts, there won’t be cuts.  Gird your loins as the November 30 deadline looms for the next potential cuts.

• Deja Vu All Over Again: The Medicare Fee Cut is Pushed Back to November 30, 2010
• Attention Medical Practice Staff: Medicare Changes the Rules for Credentialing and Retro-Billing
• 91 Physician Organizations Sign Statement Naming Congress in “Mismanagement of the Medicare Program” and Imploring it to “Honor its Obligation”

1. The Bottom Line – we have RAC audits, more pre-certification and pre-authorization and pre-notification requirements, more denials, high deductible plans, formularies and 50 other things that are making it difficult to know which hoop to jump through to get paid.  Expenses continue to go up, reimbursement continues to go down, and the healthcare world spins faster and harder, making us all wonder when it will, or if it ever will slow down.

• There is No Such Thing as a 10-Minute Office Visit
• The ABN: The Most Misunderstood and Underutilized Document in Healthcare
• 101 Ideas for Increasing Revenue and Decreasing Expenses in Your Medical Practice
• How to Develop a New Financial Policy For Your Practice: A Short Course

Healthcare reform is a top priority of the Obama administration and as a result the government will be watching closely to make sure healthcare providers are getting on board with Electronic Health Records (EHR). And while the 2014 deadline may seem like plenty of time to make the conversion, in reality it’s a pretty ambitious target date.

It’s likely that most of the focus for healthcare organizations over the next four years will be placed in three areas:

• getting a comprehensive EHR application in place within the organization
• making sure it can freely exchange data as part of the national system
• converting the existing paper records into electronic files

But there’s one other critical area that could be easily overlooked: faxes. Every day, healthcare providers exchange thousands of pages of patient, insurance and other data by fax. There are several reasons for this preference for faxing over email.

The big one is the requirements of the Health Information Portability and Accountability Act (HIPAA). According to HIPAA, email is not secure enough to transmit confidential patient information. It can be intercepted and read too easily, thus violating a patient’s right to confidentiality. Faxing is the only form of electronic transmission acceptable under law.

Even if they could use email, many physicians would still choose not to. They don’t like to have their email in-boxes filled with a lot of information they’d prefer be handled by their staff, and they fear being inundated with SPAM.

Another reason for the preference for faxes is many healthcare providers still use paper charts, which is the reason President Obama is pushing for the move to EHR. If a paper record needs to be forwarded from one provider to another, or to the same provider working out of multiple locations (two offices, a clinic, a hospital), the easiest way to get it there is to fax it.

One of the drawbacks to a fax machine is that although it transmits the documents electronically, the readable output is still on paper. If you want to store it electronically, either as part of an EHR or in anticipation of one, someone will need to scan it and save it. Turning paper into electronic documents can quickly become a time and resource sink.

There is a solution that both keeps the legal and practical advantages of faxing while eliminating the need for additional scanning – an Internet fax service. With these services, documents are transmitted using fax protocols (thus meeting HIPAA requirements), but are sent and received as attachments in email accounts. The default format is PDF, but better services give you a choice of document formats so you can integrate them into your EHR.

With an Internet fax service, electronic documents can be easily forwarded, attached to electronic medical records and stored. There’s no paper to misplace, no ink to smear, and no chance that a document relating to patient A will end up in patient B’s file because two faxes got mixed together.

On the sending side, an Internet fax service can be tied into the provider’s contact management system, eliminating the need to dial a phone number on a keypad and stand at the machine while the fax goes through. This method not only saves time, it also prevents a patient’s confidential medical information from being accidentally faxed to Petersen Auto Body –avoiding another potential HIPAA violation.

Unlike many improvements in the medical world, which tend to cost more to implement, an Internet fax service can help seriously reduce costs over using fax machines. Elimination of the paper used to print faxes alone can save thousands of dollars. Add in the elimination of the machines, the dedicated fax lines, toner and electricity and you’re potentially saving thousands more.

I asked Steve to expand on the MyFax product.

Q: What EMR systems is your product currently working with?

A: We have integrated with many EMR systems including NextGen and eClinical Works.

Q: What is involved (time, money) in interfacing your product to an EMR?

A: We have very robust APIs that enable us to complete the integration within a few weeks. If the integration is delayed, it’s usually due to business issues such as contract negotiations or legal matters.

Q:  Can you explain in more detail the process to fax electronic medical records to a party outside the practice?

A: A doctor or nurse working within an EMR can fax directly from it. The document is then securely sent through our infrastructure. All data is encrypted in transit and then delivered to the recipient.

Q: What benchmarks can you give for the time it takes for a medical office employee to receive a fax, identify it as belonging to a specific patient, and index the fax into the EMR?  Number of faxes one employee can receive, identify and index in an hour? A day?

A: Faxes are delivered right to the EMR. MyFax provides an indexing file which the application reads, and then puts the file in a work folder where the user can action it. From this point of view, it is then a question of the efficiency or capability of the employee and/or the actual EMR system.

For even greater efficiency, if the EMR system has OCR or Bar-coding capability, the fax can be directly attached to the patient record.

Q: Is your product priced by subscription or transaction volume, or some other way?

A: MyFax is Software-as-a-Service (SaaS) and is subscription based. We work with customers to create tailored subscriptions based on their business and fax needs.

Steve Adams is the vice president of marketing for Protus, a provider of communications tools for small-to-medium-businesses and enterprise organizations, including the MyFax (www.myfax.com) internet fax service; my1voice, a virtual phone service; and Campaigner, an e-mail marketing service. He can be reached at sadams@protus.com.

With so much going on in healthcare, it would not surprise me if a lot of practices missed the February 2010 deadline for three expanded HIPAA rules.  This expansion was dictated by the Health Information Technology for Economic and Clinical Health (HITECH) Act passed by Congress in February 2009.

If you haven’t already, get started now with the new requirements.

1. New obligations for business associates (BA) – February 17, 2010 Remember that a BA is a person or organization outside of your entity with whom you share protected health information (PHI) so they may provide services to you.  Good examples are your billing service, collection agency, attorney, consultant, computer vendors, attorneys and providers of documentation abstracting or coding services.  Under HITECH, BA have the same responsibilities for breaches as the healthcare entity does, but it is the healthcare organization’s responsibility to have an updated, signed BA agreement in place that describes this new responsibility.  Here is an excellent example of a BA agreement (first link under Publications) that you can download and tweak for your practice.
2. New disclosure agreement provision – February 18, 2010 This is a big one! Patients now may waive their right to have you file their medical insurance, pay for your services themselves and request that their medical information NOT be disclosed to their insurance plan or any other entity.  In other words, patients may elect to become “self-insured”.  I recommend that you create a new financial class for these patients so they neither fall into the standard self-pay/financial assistance class or into their actual insurance class.  These patients, if you have any, will need to be identified according to their wishes, which could mean that they want you to file insurance for some services and not for others.  This means their record must be tagged for what records can be released and what records cannot.  There could be an argument made either way for whether or not these patients should receive self-pay discounts that you have in place for your non-insured patients.  I would be interested to know how different groups have decided to handle this.  There are sample forms for PHI disclosure accounting and for patients to request an accounting of PHI disclosures in the Manage My Practice Library under Operations.
3. Information breach notification – February 22, 2010
   We’ve heard a lot about this one as the media (along with HHS) must now be notified if a PHI breach involves 500 people or more.  Breaches are being reported weekly as non-encrypted laptops are stolen or repurposed, and as copier hard drives (story here) go unnoticed as a security risk.  If a breach involves 500 people or less, each individual must receive written notice with details of the breach, the information disclosed, and the steps being taken by the practice or entity to avoid any future breaches, as well as explaining the rights of the patient(s) in protecting their private healthcare information.  Several of my employees have received notification letters from health plans and they have been horrified that this could happen.  Note that entities that secure health information through encryption or destruction don’t have to provide notification in the event of a breach!

Enforcement is also beefed up.
Criminal penalties will apply to covered entities that violate privacy rules AND to those organizations’ individual employees (can you track who accesses whose records when?)  Civil penalties have been increased and harmed individuals may share in the booty.  Probably most importantly, HITECH gives state attorneys general the power to enforce HIPAA rules.

Other resources:

HHS FAQ on HIPAA Privacy

AMA HIPAA Resources

Healthcare Blog Listing

With huge growth in 2009, social media is not just a passing trend used by online marketers; it’s a real, effective method of communicating ideas, sharing information and connecting with people across all age and socioeconomic groups. Healthcare, while slower to adopt the social media wave than other industries, is coming to realize the potential social media tools provide to develop connections with patients, potential patients, along with other physicians and healthcare leaders around the world.

What are some of the driving forces behind this explosion in popularity? One reason is that as consumers, we’re no longer trusting of advertising and we don’t want to be marketed to, we want to be engaged, build a relationship, make the company earn our trust and hear our friends or family’s review of their experiences. In fact, studies show that today, only 14% of people trust advertising, whereas 78% of people trust recommendations and referrals. Companies are using social media outlets to build relationships, trust and encourage recommendations and referrals from their engaged consumer base.  As practice, hospital and physician growth are so strongly correlated to patient referral and recommendation volumes, it is only natural healthcare organizations look to social media outlets to continue to foster patient relationships and increase referral volumes.

As of February 2010, where is the healthcare industry in its adoption of this social media explosion? Larger organizations and health systems are utilizing the power to connect, share and engage their patients.  While, on average, smaller private physician groups and individual physician offices are still slightly hesitant and dipping their toes in the social media pool cautiously.  One can understand why healthcare professionals do need to take a more strategic approach to interacting and engaging patients online with potential HIPAA privacy issues and other challenges looming. However, with a carefully crafted social media strategy, many health organizations are realizing the benefits of becoming more accessible in their marketing and reaching out to inform, educate and build trust with patients.  According to Ed Bennett (edbennet.org) hospitals are currently at a 53% adoption rate, with 336 Facebook pages, 430 Twitter Accounts, 254 YouTube Channels and 70 blogs. In total, 557 health systems are reported to be participating in some capacity with social media, with the term “social media” encapsulating many forms and tools, including Facebook, Twitter, YouTube, blogs, LinkedIn, Flickr, and a number of patient forums.

How are healthcare organizations using these tools effectively? Let’s focus on the top three tools currently adopted and being utilized in the healthcare social media sector.

Facebook: Physician practices and health systems alike are using Facebook as a dynamic, community-based website.  It has become a place where physicians and leaders can post timely, organic or professional videos to educate patients and also connect on a more personal level.  As a valuable resource for health information sharing, many organizations are taking the embarrassment out of sensitive subject matter and addressing specific medical problems, questions and issues for patients. Also, introductions to staff members and tours of the facilities are assisting organizations with connecting with their patients outside the four walls of their office and building rapport before patients even arrive for their appointment. Practices are also encouraging patients to participate and engage on their site through discussions and contests.  Private practitioners are more likely to start their social media strategy with just a Facebook Fan Page, while larger health systems and hospitals are embracing other social media tools in combination with Facebook in their initial strategy.

Twitter: Twitter is being adopted quickly by the larger health systems as a way to share information, publicize events like health screenings, fairs and clinics and also connect with other health organizations.  I like to think of it as a public relations channel for these hospital and health systems.  What’s great is that in short, 140 character or less “tweets”, these organizations are sharing a wealth of information to their patients and those patients are finding ways to access this health information and the system like never before.  Overall the smaller, private practitioners are not as quick to adopt Twitter as they are a practice website or even Facebook, but many are starting to realize the benefits of utilizing this community as a way to share their expertise and knowledge, along with driving traffic to their websites.

YouTube: Healthcare organizations are using YouTube like their own, private television station that can be shared with millions of viewers across the world.  Again, more popular amongst the larger health organizations, videos of procedures, interviews with clinicians, tours of new facilities and patient testimonials are being posted in a searchable, user-friendly manner to continue to enhance brand awareness, build trust and gain patient loyalty.  This social media tool can be used much like Facebook, easing patient fears and answering tough or embarrassing questions. It can also give patients a visual insight into the facility so they know what to expect before arriving at an appointment or for a procedure.  It can act as an online referral source, highlighting patients that have had outstanding experiences and are recommending that organization to over a billion of their closest friends and family online. YouTube is the second largest search engine and healthcare professionals are quickly utilizing its power to share and connect with patients.

The fact of the matter is that for all industries, including healthcare, social media is both a curse and a blessing. Patients, who are now consumers with choices, can post content and interact freely with their physicians and their hospitals, sharing both outstanding experiences and negative experiences.  Many health professionals are worried about their vulnerability, but social media is real life, online.  As 2010 progresses, you’ll be seeing more and more attention placed on social media by healthcare professionals and by the end of the year, it will be a necessity for organizations to be participating and engaging online, or be left out.

I think so.

But I know I’m probably in the minority.  Many managers do not approve of employees using their phones for social media (Twitter, Facebook, etc.) at work, but I am actually okay with it when used with discretion. Unlike computers, with smart phones you do not need to worry about viruses infecting the office network.

Most managers accept and allow employees who smoke to step outside at least twice a day to smoke a cigarette.  Doesn’t it seem fair to allow everyone else to take a phone break to check messages, make calls and text a few people?

Here are some objections I’ve heard to allowing staff to use their phones at work, and my answers.

“They’ll never get any work done if you let them play on their phones all day.”

My Answer: I only hire adults.  I expect adults to have a reasonably well-formed work ethic that is demonstrated by doing work first, and doing non-work on breaks and briefly other times.  If the practice can’t run without me peeking over their shoulders every hour or so to see if they’re working, then I am not a very good manager.

Performance measures are a great way to set guidelines for what work must be done.  If the employee is meeting their performance goals appropriately, why shouldn’t they be able to take a micro-break to catch up on life?

“Employees should do work at work and save their home life for home.”

My Answer: Employees are people with busy lives, lots of commitments and lots of responsibilities outside of work.  Every single one of us needs to attend to our personal lives for some part of the day.  Most of it can be dealt with at lunch or during breaks, but sometimes people need to attend to their lives at work.  I want them to be able do that, within reason, because it is a realistic response to life in 2010.

“What if staff using the Internet on their phones puts the practice at risk?”

My Answer: If you have done a good job of educating your staff about confidentiality and HIPAA, you should have no worries.  In short, staff should not reveal any patient information (via spoken, written or digital communication) to any third party for any reason besides those dictated in your Notice of Privacy Practices (NPP).  Your HIPAA education plan should be reviewed and updated annually to include any policy changes due to the use of social media for personal and practice purposes.

Click here for the December 9th UPDATE I posted on SubroShare’s announcement that they will not be focusing on physicians as clients.

I recently interviewed Stephen Ambrose, the Founder and CIO of SubroShare®, a database of medical record requests. Steve has a lot of passion for his innovative product and envisions SubroShare® playing a starring role in payer contract negotiations.

Mary Pat:  Steve, what is subrogation?

Steve: Subrogation is a legal right and necessary tool used throughout the insurance industry with many types of policies.  It allows insurers to recover part or full amounts of claim monies, which they have previously paid out to, or on behalf of a claimant.

In certain circles, subrogation is considered the “great equalizer” because it allows insurers to reduce or eliminate the passing of unnecessary cost related to third-party liability (TPL) claims, to policyholder premiums and provider reimbursement rates.

Overpayment of health care claims is a form of “waste” in cases where previously paid health care claims are re-billed to a third party and subsequently paid for again as part of a successful injury claim settlement.

Mary Pat: How does your product SubroShare® relate to subrogation?

Steve: First, apart from Medicare’s MSP (Medicare Secondary Payer) program, I know of no law or obligation where injury claimants or their attorneys must proactively volunteer information to a health payer, alerting them of a case, where the payer has a right to recover.  For this reason payers have always been responsible for data mining claim form information, and to this end, use software products and vendor services to do so.

SubroShare® recognizes that the claim form/data itself is limited in holding the correct, identifying data for third party cases.  In many cases, the use of the claims data results in payers having false positives or dead end investigations.  Even claims vendors who claim to use the ‘latest and greatest’ tools, freely admit that they do not find all of the cases available to the payer.

Our company has developed a new patent-pending technology in Collaborative Subrogation®, where we work to connect just one small part of a health provider’s record department with an applicable payer. This is only for certain ROIs (Release of Information) made by the patient or their attorney involved in a patient’s injury claim.

Mary Pat: What is the physician’s office or healthcare provider’s role?

Steve: In most payer agreements, the health provider has a contractual obligation to provide coordination of benefits (COB) and third party liability (TPL) information to the payer, when known.  This is reflected in certain sections of the CMS 1500/UB-04 forms and their 837 data record electronic counterparts.

The SubroShare® exchange handles non-billing TPL data, specific ONLY to those times where a record request is made on a patient of the provider.  This ROI Data, is submitted to SubroShare® at the time of  record request fulfillment, by the provider submitting either a one or two page fax / secure email attachment. The first page is typically only a ¼-page section and the second page is a copy of the request letter, sent by an attorney (if applicable).

Providers can learn more by watching the provider tutorial here.

Mary Pat: How does this sharing of information work within HIPAA rules?

Steve: Under 45-164.501 of the Health Insurance Portability and Accountability Act (HIPAA), the ROI data that is collected and shared between health providers and payers, through the SubroShare® network, is specific to insurance subrogation operations and falls under the HIPAA provision of “Payment”, in the automatic exclusion of “Treatment”, “Payment” and “Operations”.

This means that patient authorization is not necessary, nor can the patient request to withhold the limited disclosure of their PHI to SubroShare and eventually, to their health insurance company.

Finally, every health provider who participates with SubroShare® must sign a HIPAA Business Associate agreement, which is signed digitally on the joining section of our website.

Mary Pat: What is the health plan or payer’s part of this?

Steve: Payer members or Subscriber Entities of SubroShare® login and freely search for established Certified Recovery Reports® within our system.  Once found, the payer downloads the information, which both guarantees policyholder involvement and uniqueness from any existing payer’s claims management software and vendors.

Mary Pat: I can see how this benefits the payer, but how does it benefit the physician practice?

Steve: Under the new HITECH guidelines to go into effect in later 2010, health providers cannot receive compensation from the transfer of PHI. Therefore, we felt it prudent to be able to create financial transparency on both the payer and provider sides of SubroShare®.

Essentially, providers will know the specific payers who downloaded their submitted ROI data, as well as the date of download and patient referenced.  This data, coupled with a provider’s analysis on the amount of paid claims for such patients, provides a clearer picture on the fact that a provider is now becoming a new type of asset to the payer and to an extent, which can be measured by the provider, as well as the payer.  We believe such a change in value could denote an improvement in reimbursement levels within various payer relationships.

Mary Pat: Could payers use this information to deny payment or request a refund for payments already made?

Steve: There are numerous laws and rules, inherent to different states, communities and health plans, allowing for cost avoidance.  This term denotes when a government, commercial or self-insured payer determines that a policyholder’s care should be or will be covered by a payment party other than themselves.

Unfortunately, we cannot keep a health payer from pursuing cost avoidance policies, which they have in place.  However, I’d like to mention that not all plans have this provision; and for those which do, this simply makes the point that it could be a future point of provider-payer negotiation, perhaps with relation to all such claims, not just the ones from SubroShare®.

Mary Pat: If the practice uses an outsourced company to copy medical records, can the medical records company send the information to SubroShare®?

Steve: Yes, provided two conditions are met.

First, the health provider is the one, which joins SubroShare® – not the outsourced company.  Health providers can give their login details and appropriate permissions to their ROI or outsourced information vendor.

Second, the outsourced vendor MUST have an existing HIPAA Business Associate Agreement with any applicable health providers.  I assume this is the case anyway, but if I didn’t mention it the answer would be less than complete.

Mary Pat:  It’s a leap of faith you’re asking a medical practice to take, isn’t it?  Is there any way you give the practice a guarantee of negotiating better fee schedules with payers, or any way you could compensate them for their time?

Steve: I don’t think the leap is that large…here’s why.  Its becoming increasingly obvious that past provider strategies on reimbursement rates will be largely overshadowed and trumped by a tightening healthcare system and monies, which are drying up for many of its participants.  If the monies are not there for payers, they won’t be there for providers.

SubroShare® creates revenue, without charging higher premiums to policyholders, but rather, in redistributing monies, which are generated through the legal industry and might never make their way back into the healthcare arena.  Providers need to look at the information, which they are already holding.  Can it help their valuation and reimbursement with payers?  I suppose that’s up to each payer.  Medicare already has demo programs, which trade off payment for valuable data submission and we expect that to find its way into the private payer sector as well.

Our President and both sides of Congress have made it very clear that finding and reducing waste is one of the top priorities.  Therefore, we want our collaborative model to demonstrate to today’s leaders that payers and providers CAN work together for the good of the system.

Mary Pat:  What would you say to a practice manager to convince them to work with SubroShare?

Steve: As a practice manager, if you are bitter about “what insurers have done TO you?”, then you are not the right practice for SubroShare®.  You’ll probably be coming on through payer mandate, as your payers adopt  these measures.  I will state that voluntary participation will offer you the ability to proactively come to the  negotiating table with results in hand.

If you understand that it’s about future positioning and NOT the payer taking advantage of you, then you’ll  begin to understand the importance of positioning and collaborative strategy.  We’re in a whole new arena of healthcare and old models and adversarial relations will not do well.

There is no cost to join, no cost to participate, no software to buy or integrate and no patient authorization  necessary. All that is required is a fax and a simple internet connection.  Please visit us here or call (804) 750-1389 for more information.

My personal list of new employee orientation best practices has been shaped by my experiences in private practices as well as hospitals. Every organization has different resources to draw upon, but each group has core goals that must be fulfilled by a good orientation:

• completion of paperwork including federal and state W-4s, I-9, direct deposit and benefit elections
• emergency contact information (included in hospital employee health intake)
• orientation to the organization, including designations, specialties, departments, sites, affiliates and an organizational chart
• completion of mandatory annual training such as safety, standard precautions, and HIPAA
• mechanics of name tags, parking tags, lockers, keys and codes
• signing off on understanding and agreement to confidentiality, compliance and personnel policies

In addition to these core goals, critical information to be shared during this time should minimally include:

• personnel policy review with emphasis on important (typically abused?) policies
• code of conduct/ shared basic competencies (mission and values, professionalism, communication, chain of command)
• computer security (passwords, internet policy, protection of PHI)
• workstation ergonomics and patient lifting policy (sadly lacking in many medical practices)

Important training that is rarely covered:

• Customer service (what is it and how do we measure our success or lack thereof?)
• Cultural sensitivity and diversity training
• Non-clinical employees’ role in medical emergencies
• Personal safety (coming in early or leaving late, patients threatening staff by phone or in person)
• Expectations for the first 90 days (training, communication, questions, problems)

Making Orientation Memorable

(more…)

UPDATE on July 4, 2009: I’ve been having problems with the links in this article and I’ve found that the HITTG website has vanished!  I’ve not been able to find out where it went.  If anyone has any information, please let me know.  You can search for NPIs for free here, and see below for the reason why the offer changed from free to $19.95 (still a great deal!)

Until recently you could download one directory during every update cycle completely free of charge.

I wish we could keep doing that, but here’s what happened:

• Literally hundreds of downloads were being taken “against the rules,” that is, people were creating multiple accounts and downloading multiple states every month. That cost us serious bandwidth problems, and slowed down our site for everyone. Eventually, it crashed our site, broke some stuff, and threw us offline for quite awhile.
• We put about 45 hours of work each month into processing the data, turning it into software, and uploading it so you can access it. Unfortunately, so few people were buying our non-free products that we were frankly losing money.

Those two things, taken together, meant that if we were going to keep doing NPIdentify Desktop — the best NPI directory on the planet — we would have to start charging a little bit for it, both to prevent the download avalanche, and to hopefully at least break even.

We’re truly sorry! But the good news is that we’ve reduced the price, so for those of you that have been paying for multiple states, now you’ll be paying far less! For those who were, well, shall we say “fibbing,” you’ll be paying a little bit more. It’s still the best NPI directory out there, and it’s still the least expensive, with all of the others running at least $39 per state!

Here’s my original article:

I had the pleasure of interviewing Marti Jensen of HITTG Consulting recently.  Marti was kind enough to answer lots of questions about himself, the company, and their new product NPIdentify.

He said, “I’m looking for a doctor that uses email.”  He said he would not use a doctor that doesn’t use email because he doesn’t have the time to fool around on the phone when he needs an appointment or has a question.  Of course, in the practice, we don’t have time to fool around on the phone either, and we’d LOVE to do everything via email, but this is something that seems hard to implement.

Why?

1. Everyone (including me) is uncertain about privacy and HIPAA when communicating with patients electronically.
2. Everyone (including me) worries about the liability issues related to electronic communication with patients.  How do you index it on the EMR?  Do you print it out if you’re using paper charts?
3. Systems that are designed to facilitate email with patients seem limited and restricted as to specific uses like making appointments.
4. Managers worry that email opens the door to patient communication falling through the cracks when we/they are already working very hard to keep that from happening.
5. Most wonder if it is worth adopting technology early when it’s expensive and untried.
6. Most wonder how many patients would really communicate electronically if given the chance.

If you could design a safe, low-risk system to communicate electronically with your patients, what would be the uses for this system? What are your communication logjams? Are you aware of or using any systems that have cracked the electronic communication conundrum?

Here’s another article on doctors using email: Why Doctors Don’t Email Patients.

Photo by Andi Berger/Dreamstime.com