Physician ‘e-ok’ deemed OK by most fiscal intermediaries
Physician e-ok’ deemed OK by most fiscal intermediaries
Is home health ready for the technology and the new rules?
Regardless of policies and intermediary acceptance of the technology, the use of physician electronic signatures is still comparatively new to the industry, and thus far, the majority of home health agencies still rely on traditional pen-and-ink signatures. Lorraine Waters, RN, BSN, CHCE, MA, director of Southern Home Care in Jeffersonville, IN, for example, notes that her agency does not utilize electronic signatures and is unaware of any agency in Kentucky (as well as southern Indiana) that does. "We use laptops for charting but still maintain paper charts, which we have the physicians sign," she says.
And while Craig Jeffries, Esq., CEO of Healthspan Services Inc. in Johnson City, TN, has not yet implemented the physician electronic signature technology at his agency, he sees it as something toward which the industry is moving. "Anything electronic like this is very cost-saving," he says, adding that his agency already is working with a Beta site where prescription refills can be issued over the Internet.
"The technology is there, and it is certainly something we would like to use in our agency," Jeffries says. "We are very progressive when it comes to information systems, but the problem is often that the physicians’ offices are not as advanced when it comes to these types of electronic systems. So we haven’t been able to link up with an office yet."
Then there are agencies such as Henry Ford Home Health in Detroit, which is ready, willing, and able to implement the use of physician electronic signatures into its daily operations. So convinced are the people at Henry Ford that electronic signatures are the wave of the future, they are already developing a set of policies and safeguards to maintain the integrity of patient files and ensure security for the day they begin using electronic signatures. Henry Ford’s intermediary is United Government Services (UGS) and is not accepting electronic signatures at this time.
Greg Solecki, vice president of Henry Ford Home Health, says the technology has a lot of potential. "We think it’s an iron-clad process, and we think it improves efficiency and helps us not only get the physician signature but the information that we need to be more informed when we make [our] first home visit."
What types of safeguards has Henry Ford implemented? For starters, explains Solecki, "We have policies on inpatients’ signature requirements in the medical record. We have confidentiality statements that specify that physicians are aware that access to electronic systems will be monitored and that any misuse is a violation of our policy and that they will be held responsible.
"We also have policies on obtaining a user ID, and a policy on creating and changing passwords and also one on reporting security violations. We have one covering changes in a physician’s status with respect to changes in employment and terminations," Solecki says. "We think this will be HIPPA-compliant [Health Insurance Portability and Accountability Act] and feel these safeguards illustrate our desire and intent to maintain the confidentiality of electronic records and ensure that the information entered by a physician is appropriately authenticated. We think we have all the bases covered."
A+ for PPS
Solecki sees electronic signatures as a tremendous asset to agencies, especially in light of the final prospective payment system (PPS) ruling. "I think it’s the way to go because it will ensure our compliance with a signed physician order, and, as we get into PPS and final payment orders, electronic signatures will be a big help.
"There are lots of benefits to electronic process in addition to getting the signature on a timely basis," he adds. "But with the advent of PPS we really like the idea because it will help us to use the rapid anticipated payment system. If we don’t send out the bill within the 60-day period, then we would need to rebill and start the process all over again. With an electronic signature, we will be able to bill more efficiently and more effectively on a daily basis and thereby keep the cash flow stable."
In a recent policy clarification for member agencies, the National Association for Home Care (NAHC) reported that with the exception of UGS, all home health fiscal intermediaries (FIs) follow the HIM-11 guidelines for accepting physician electronic signatures. The rules require that the following instances be addressed:
- authentication and dating of signatures, which may include signatures, written initials, or use of a unique identifier;
- prevention of unauthorized access;
- procedures for rebuilding records if the system breaks down.
In addition, the other FIs (Palmetto, Wellmar, Blue Cross of California, and Maine Blue Cross) require any agency using physician electronic signatures to submit a written copy of its policy to the FI, which is required to keep that policy on file.
In the event an FI does not know whether an agency is accepting electronic physician signatures and the FI denies a claim based on "no physician signature," the agency may be able to obtain reversal of the denial on reconsideration by submitting the appropriate documentation, including a copy of its electronic signature policy.
Final standards not yet released
Providers should note that the Department of Health and Human Services proposed standards for electronic signatures in 1998 (see NAHC Report #778, go to www.nahc.org) to address HIPAA provisions related to security of electronic transmission of certain health information.
The standards have not been finalized. How-ever, once a final rule is published, the FIs will be required to make changes to their electronic signature policies and home health providers will be required to conform. The HIPAA proposed standard would require certain security service features such as message integrity, nonrepudiation, and user authentication. At the time the proposed standard was published, only digital signature-based techniques met the criteria.
UGS, for its part, has received a growing number of calls regarding the use of physician electronic signatures and has put in a request for information/interpretation from the Health Care Financing Administration. Who knows? Maybe Henry Ford will be able to get its electronic signature program up and running sooner than it thinks.
[For more information, contact:
- Craig Jeffries, Healthspan Services Inc., 525 North State of Franklin Road, P.O. Box 5159, Johnson City, TN 37602-5159. Telephone: (423) 926-3338.
- Greg Solecki, Vice President, Henry Ford Home Health, 1 Ford Place, 4C, Detroit, MI 48202. Tele-phone: (313) 874-6500.
- Lorraine Waters, RN, BSN, CHCE, MA, Director, Southern Home Care, 1806 E. 10th St., Jefferson, IN 47130. Telephone: (812) 283-2602.]
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