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As promised by the Department of Health and Human Services' Office for Civil Rights (OCR) and mandated by the HITECH Act, HIPAA compliance audits have begun, and 20 organizations were visited during the pilot phase of the program.
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Members of the patient access staff at Catholic Health Initiatives Nebraska now play a role in complying with The Joint Commission's requirement that patients be offered educational materials on advanced directives when they are admitted, says Lauree M. Miller, director of patient access.
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Unintentional fraud can take many forms in patient access areas, including some involving protected health information (PHI), says Dan Schulte, executive vice president of revenue cycle solutions at The Outsource Group in St. Louis, MO.
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When Lauree M. Miller, director of patient access at Catholic Health Initiatives Nebraska in Lincoln, became the organization's coordinator of admissions, patient access didn't have anyone represented on the hospital's committee that oversees accreditation by The Joint Commission.
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Although there is no way to know exactly what documents you will be asked to provide in the initial HIPAA compliance audit notice from the Department of Health and Human Services' Office for Civil Rights (OCR) there are some items you can expect to see on the list, according to experts interviewed by HIPAA Regulatory Alert:
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If you stick to one teaching style for all of your patient access staff, this process can result in poor morale, warns Tracy Abdalla, assistant manager of hospital access services at University of California -- Davis Medical Center Hospital.
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Below are examples of questions used to prepare registrars at Catholic Health Initiatives facilities in Nebraska for surveys by The Joint Commission:
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Take the time to provide training to provider offices about insurance guidelines and registration processes, because this training is a good way to encourage collaboration with patient access, recommends Kellie Hawkins, director of patient access for Shady Grove Adventist Hospital in Rockville, MD.
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A well-prepared team that understands roles and responsibilities when a notice of a HIPAA compliance audit is received is essential for every organization and should be established long before a notice is received, suggests Chris Apgar, CISSP, president of Apgar & Associates, a Portland, OR-based consulting firm. Educate them about the purpose of the audit, and give each person specific responsibilities, he says.
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The Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare and Medicaid Services (CMS) have issue Notices of Proposed Rulemaking that are open for comment until May 7, 2012.
