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Optimizing and Maintaining Operations and Workflows:HIM Life in a COVID World

Angela Rose, MHA, RHIA, CHPS, FAHIMA

Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB

8/25/2020 © 2020 MRO. All rights reserved. 1

Listen to the recording of this webinar by clicking the link below

https://info.mrocorp.com/webinar/2020/pt1-recording


Today’s Panelists

Angela Rose

VP of Implementation Services and Corporate Policy


Rita Bowen

VP of Privacy, Compliance and HIM Policy

Stephanie Kindlick

Sr. Director of Marketing& Host

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About MRO


MRO Overview


2ndLargest Disclosure

Management Provider

#1KLAS Category Leader

for 7 Years in a Row

Company Established in 2002

Meet Today’s Speakers


Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB

VP, Privacy, Compliance and HIM Policy, MRO

In her role as Vice President of Privacy, Compliance and HIM Policy, Bowen ensures new

and existing client HIM policies and procedures are to code. Bowen also serves as the

company’s Privacy and Compliance Officer (PCO), assuring timely reporting of any

disclosure incident. She is also responsible for reviewing legislation to assure industry

response and compliance within MRO. Bowen has more than 40 years of experience in

Health Information Management (HIM), holding a variety of HIM director and consulting

roles. Bowen currently sits on The Sequoia Project Board of Directors and is an active

member of the American Health Information Management Association (AHIMA). She

served as AHIMA President and Board Chair, as a member of the Board of Directors for

six years, and of the Council on Certification for three years. Bowen has also served on

the AHIMA Foundation Board of Directors, serving as its Board Chair. She has been

honored with AHIMA’s Triumph Award in the mentor category; she is also the recipient of

the Distinguished Member Award from the Tennessee Health Information Management

Association (THIMA). Bowen is an established author and speaker on HIM topics and has

taught HIM studies at Chattanooga State and the University of Tennessee Memphis.

Bowen holds a Bachelor of Medical Science degree from Emory University in Atlanta, GA

with a focus in medical record administration and a Master’s degree in Health Information/

Informatics Management Technology from the College of Saint Scholastic in Duluth, MN.


Angela Rose, MHA, RHIA, CHPS, FAHIMA

VP, Implementation Services and Corporate Policy

As Vice President of Implementation Services for MRO, Rose oversees, and coordinates activities

related to successfully onboarding new clients to MRO’s Release of Information (ROI) platform.

She has more than 25 years of experience in Health Information Management (HIM), with

focused expertise in privacy and security. Prior to joining MRO, she served as Director of HIM

Practice Excellence for the American Health Information Management Association (AHIMA). Rose

is an active member of the American Health Information Management Association (AHIMA) and

currently serves as the Education Co-Chair of the Pennsylvania Health Information Management

Association (PHIMA). Rose is an established author and speaker on various HIM topics. She has

served as adjunct faculty and various HIM Advisory Boards. She currently serves on the

University of Pittsburgh’s and Temple University’s HIM Advisory Boards. She received her

Bachelor of Science in HIM from the University of Pittsburgh and Master’s in Health

Administration from the University of South Florida.


Agenda


Agenda

• Environmental Scan

• Legal Requirements • HIPAA Compliance

• Other Federal Laws

• Telehealth

• Coding and CDI

• Release of Information

• Telecommuting Checklist

• Management and Thought Leadership

• Questions and Discussion


Current Environment


Current Environment

• Healthcare Right Now• Healthcare environment becoming overwhelmed (again)• Quarantine/Stay-at-Home/Roll back orders • Social distancing/Mask requirement• Remote workforce• Increased use of telehealth • Patients afraid to seek medical help

• Challenges • Increased demand (varies by state)• Shortage in supplies (again)• Shortage in resources (again)• Exhausted and limited workforce • Continuously changing environment (laws, restrictions, etc.)

• Risks • Compliance • Customer Service


Legal Requirements in a DisasterCivil Rights Laws and HIPAA Flexibilities

During the COVID-19 Emergency


HIPAA Compliance

• Treatment

• Public Health Activities • To a Public Health Authorities (45 CFR §§ 164.501 and 164.512(b)(1)(i))

• At the Direction of a Public Health Authority or Foreign Government Agency (45 CFR 164.512(b)(1)(i))

• To Persons at Risk (45 CFR 164.512(b)(1)(iv))

• Disclosures to Prevent a Serious or Imminent Threat (45 CFR 164.512(j))

• Disclosures to Family, Friends, and Others Involved in an Individual’s Care and for Notification (45 CFR 164.510(b))

• Disclosures to the Media or Others Not Involved in the Care of the Patient (45 CFR 164.510(b))

• Minimum Necessary (45 CFR 164.502(b))


General Requirements

HIPAA Compliance

• Media Access to Individual PHI in Facilities (5/5/2020)• NO CHANGE - Disclosures of PHI to media is not permitted

• Media and film crews are not permitted without patient authorization even if faces are blurred or masked; must obtain a valid signed HIPAA authorization

• Contacting Former COVID-19 Patients about Blood and Plasma Donations (6/12/2020)

• Contacting a patient about blood and plasma donations is permitted under HIPAA as a population-based health care operations activity

• May not constitute marketing


General Requirements

HIPAA Compliance

• Permitted disclosures • To provide treatment

• Required by law

• To notify a public health authority to prevent or control spread of disease.

• First responders at risk of infection

• Necessary to prevent/lessen threat to the health and safety of a person/public

• Correctional institution

• Law enforcement official with lawful custody of an inmate/other individual


Disclosures to Law Enforcement, Paramedics, First Responders, and Public Health

HIPAA Compliance

• Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency

• Enforcement Discretions • Business Associates - OCR will not impose potential penalties against providers or their

BAs under HIPAA provided:

• BA makes good faith disclosure for public health

• BA informs CE within 10 calendar days of the disclosure

• Community-Based Testing Sites During COVID-19 - Retroactive to 3/13/2020

• OCR will not impose penalties or violations in connection with good faith participation in the operations of testing sites


Enforcement Discretions and Waivers

HIPAA Compliance

• Applies to the following provisions of the HIPAA Privacy Rule: • Requirements to obtain a patient's agreement to speak with family members or friends

involved in the patient’s care (45 CFR 164.510(b). )

• Requirements to honor a request to opt out of the facility directory (45 CFR 164.510(a))

• Requirements to distribute a notice of privacy practices (45 CFR 164.520)

• Patient's right to request privacy restrictions (45 CFR 164.522(a))

• Patient's right to request confidential communications (45 CFR 164.522(b))


Limited Waiver of Sanctions and Penalties

Other Legal Requirements

• 21st Century Cures Act • Information Blocking Rule and Interoperability

• SAMHSA 42 CFR Part 2 Revised Rule – effective 8/14/2020• Treatment records created by a non-part 2 provider not covered

• Records from a Part 2 provider to a non-provider and incorporated into non-provider’s records are covered

• Disclosure consent no longer requires specific individual name

• New list of activities considered payment and healthcare operations permissible with written consent

• Permits disclosures for care coordination and case management with written consent

• New opioid treatment program provisions


Other Federal Laws

Telehealth


Telehealth Today

• 0.1% to 43.5%

• 9% to 51%

• 50 states

• 9 million

• $27 billion

• https://aspe.hhs.gov/system/files/pdf/263866/HP_IssueBrief_MedicareTelehealth_final7.29.20.pdf


https://aspe.hhs.gov/system/files/pdf/263866/HP_IssueBrief_MedicareTelehealth_final7.29.20.pdf

Telehealth

• Centers for Medicare and Medicaid (CMS) • Licensing requirements

• Telehealth and audio-only visits

• Expanded services for beneficiaries

• Billing

• Drug Enforcement Agency (DEA )• Remote prescribing

• Department of Health and Human Services/Office for Civil Rights (HHS/OCR)

• Video technologies use

• Breach penalties due to telehealth not pursued


Relaxed Rules and Requirements

Telehealth Tomorrow

• Continued growth

• Permanent place in healthcare

• Policy and procedure needs

• Business Associate Agreements

• Documentation requirements

• Legislation changes • Protecting Access to Post COVID-19 Telehealth Act

• KEEP Telehealth Options Act


Coding and CDI


Coding and CDI

• Staffing

• Morale

• Communication with providers

• Many changes with coding guidelines related to COVID-19• A lot of questions and new processes for second-level reviews, etc.

• Focus of providers on treatment not documentation


Challenges and Tips

Release of Information



• About 50% walk-in windows closed

• Alternative workflows in place

• Workforce • Remote

• Skeleton crews

• Volumes went down, but provider and patient volumes coming back strong


Today’s Environment


• Audits and Reviews• Medicare Risk Adjustment (MRA) reviews – not suspended

• Medicare Risk Adjustment Data Validation (RADV) audits – suspended

• CMS Audits (Gov’t Audits) – Restarted August 3rd

• HEDIS (Medicare plans) - Suspended

• HEDIS (Commercial & Medicaid plans) – no new requests

• Commercial Risk Adjustment (CRA) reviews – not suspended


Today’s Environment

Receiving Requests

• Secure Drop Box

• Mail

Onsite Options

• Fax

• Email

• Portals

Virtual/Electronic Options


Receiving

Requests

Delivering Requests

• Fax

• Email

• Portals

• Electronic submission (i.e. esMD, SFTP, ERE)

Virtual/Electronic Options

• Scheduled appointments

• Minimal contact

Onsite Options


Delivering

Requests

Education and Training

• Instruction Sheet

• Contact information for immediate assistance

Patients/Requesters

• Policy and Procedure• Quick Tips

• Short Trainings

• Contact information for immediate assistance

Employees


Telecommuting Checklist


Transitioning to a Remote Workforce

• Policy and Procedure • Home Workspace Requirements

• Devices and Connectivity

• Use and Disclosure of PHI

• Reporting Incidents

• Work Days/Hours

• Expenses

• Help

• Sanctions

• Remote Access and Confidentiality Agreement

• Risk Assessment

• Education and Training


Remote Workforce Checklist

❑ Private workspace❑ Smart homes (i.e. Alexa, Google Home, Nest, Ring, nanny cams)

❑ Devices (Personal vs. Organization Owned)❑ Inventory and audit

❑ Secured (i.e. anti-virus protection, firewall, encryption)

❑ Updates and maintenance

❑ Functional secure connectivity ❑ Network access (i.e. VPN, VDI-Virtual Desktop Infrastructure)

❑ Internet Connection (i.e. WiFi, Ethernet)

❑ Proper authentication

❑ Effective communication solutions


Management and Thought Leadership


Pandemic Response Management

• Know your environment

• Monitor and track cases including exposures and potential exposures

• Understand organization policy and protocols • Response times

• Action items

• Workforce exposure protocol

• Reporting (to whom)

• Communication (internal and external)

• Sanitization schedules

• Contamination control

• Education and Training• https://www.cdc.gov/coronavirus/2019-ncov/downloads/Essential-Critical-Workers_Dos-

and-Donts.pdf


https://www.cdc.gov/coronavirus/2019-ncov/downloads/Essential-Critical-Workers_Dos-and-Donts.pdf

Think Outside the Box

• Benchmarks/Key Performance Indicators (KPIs)

• Productivity

• Expectation/Accountability

• Policies and Procedures

• Onsite schedules

• Regular Meetings/Touchbases• Virtual meetings with video


Tips and Takeaways


7 Things to Remember

1. HIPAA STILL APPLIES! It’s relaxed, not gone.

2. Review/analyze current workflows/benchmarks and adjust as needed

3. Create/review/update new policies and procedures as needed.

4. Educate and train (staff and patients).

5. Implement CDC recommended hygiene guidelines into new workflows and the workforce environment.

6. Communicate!

7. Stay current!


Thank You!

Angela Rose, MHA, RHIA, CHPS, FAHIMAVice President, Implementation Services and Corporate Policy

MRO Corporation [email protected]

Office: 610-994-7500 x324Twitter: @adrose1014

LinkedIn: https://www.linkedin.com/in/angeladrose7/

Rita Bowen, MA, RHIA, CHPS, CHPC, SSGBVice President, Privacy, Compliance, HIM Policy

MRO Corporation [email protected]

Office: 610-994-7500 x526LinkedIn: https://www.linkedin.com/in/rita-bowen-

74206012/


mailto:[email protected]

https://www.linkedin.com/in/angeladrose7/

mailto:[email protected]

https://www.linkedin.com/in/rita-bowen-74206012/

Questions?


MRO 2020 Webinar Series• HIM Workforce Training: Developing an Engaged Team

• Mariela Twiggs, Senior Director of Motivation and Development

• Wednesday, September 16, 2020 at 2pm EST

• https://info.mrocorp.com/webinar/2020/pt2

• Security in a Virtual Environment: Protecting Your Workforce at Home • Anthony Murray, Chief Information Officer and Angela Rose, Vice President of

Implementation Services and Corporate Policy

• Wednesday, October 21, 2020 at 2pm EST


• Information Blocking Rule: The Impact to HIM • Rita Bowen, Vice President of Privacy, Compliance and HIM Policy

• Wednesday, November 18, 2020 at 2pm EST



https://info.mrocorp.com/webinar/2020/pt2



Resources


COVID-19 Resources

• Office for Civil Rights Coronavirus Homepage https://www.hhs.gov/hipaa/for-professionals/special-topics/hipaa-covid19/index.html

• HHS/OCR Bulletin: HIPAA Privacy and Novel Coronavirus

https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf

• COVID-19 & HIPAA Bulletin: Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency

https://www.hhs.gov/sites/default/files/hipaa-and-covid-19-limited-hipaa-waiver-bulletin-508.pdf

• HHS/OCR Bulletin: Civil Rights, HIPAA< and the Coronavirus Disease 2019 (COVID-19)

https://www.hhs.gov/sites/default/files/ocr-bulletin-3-28-20.pdf?language=es


HHS/OCR and HIPAA

https://www.hhs.gov/hipaa/for-professionals/special-topics/hipaa-covid19/index.html

https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf

https://www.hhs.gov/sites/default/files/hipaa-and-covid-19-limited-hipaa-waiver-bulletin-508.pdf

https://www.hhs.gov/sites/default/files/ocr-bulletin-3-28-20.pdf?language=es

COVID-19 Resources

• COVID-19 and HIPAA: Disclosures to law enforcement, paramedics, other first responders and public health authorities https://www.hhs.gov/sites/default/files/covid-19-hipaa-and-first-responders-508.pdf

• Notification of Enforcement Discretion to Allow Uses and Disclosures of PHI by Business Associates for Public Health and Health Oversight Activities During COVID-19 Nationwide Public Health Emergencyhttps://www.hhs.gov/sites/default/files/notification-enforcement-discretion-hipaa.pdf

• OCR Guidance on Media Access to PHI about Individuals in their Facilities https://www.hhs.gov/sites/default/files/guidance-on-media-and-film-crews-access-to-phi.pdf

• OCR Guidance on Providers Contacting Former COVID-19 Patients about Blood and Plasma

Donations

https://www.hhs.gov/sites/default/files/guidance-on-hipaa-and-contacting-former-covid-19-patients-

about-blood-and-plasma-donation.pdf


HHS/OCR

https://www.hhs.gov/sites/default/files/covid-19-hipaa-and-first-responders-508.pdf

https://www.hhs.gov/sites/default/files/notification-enforcement-discretion-hipaa.pdf

https://www.hhs.gov/sites/default/files/guidance-on-media-and-film-crews-access-to-phi.pdf

https://www.hhs.gov/sites/default/files/guidance-on-hipaa-and-contacting-former-covid-19-patients-about-blood-and-plasma-donation.pdf

https://www.hhs.gov/sites/default/files/guidance-on-hipaa-and-contacting-former-covid-19-patients-about-blood-and-plasma-donation.pdf

COVID-19 Resources

• COVID-19 and HIPAA: Disclosures to law enforcement, paramedics, other first responders and public health authorities


• Notification of Enforcement Discretion to Allow Uses and Disclosures of PHI by Business Associates for

Public Health and Health Oversight Activities During COVID-19 Nationwide Public Health Emergency


• CMS Flexibilities to Fight COVID-19 – What Providers Need to Know About Medical Record Requests

https://www.cms.gov/files/document/covid-ma-and-part-d.pdf

• CMS to Resume Medicare Audits August 3

https://www.vgm.com/webres/File/usrehab/FINAL%20Provider%20Burden%20FAQs%2007_06_20(1).pdf


HHS/OCR and CMS



https://www.cms.gov/files/document/covid-ma-and-part-d.pdf

https://www.vgm.com/webres/File/us-rehab/FINAL%20Provider%20Burden%20FAQs%2007_06_20(1).pdf

COVID-19 Resources

• FAQs on Telehealth and HIPAA During the COVID-19 Nationwide Public Health Emergency: https://www.hhs.gov/sites/default/files/telehealth-faqs-508.pdf

• Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergencyhttps://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

• New! HHS Telehealth Online Resource Center: http://www.telehealth.hhs.gov/

• HealthIT.gov has technical assistance on telehealth: https://www.healthit.gov/telehealth

• House Telehealth Leaders Move to Cement Regulatory Changes for Virtual Care

https://www.fiercehealthcare.com/tech/house-telehealth-leaders-move-to-cement-regulatory-changes-for-virtual-care

• CMS Telemedicine Billing Decision Tree: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

• Telehealth and the HIM Professional’s Rolehttps://www.healthcareittoday.com/2020/07/30/telehealth-and-the-him-professionals-role-relaxing-of-rules-for-telehealth-services-due-to-covid-19-requires-strong-leadership/


Telehealth Resources

https://www.hhs.gov/sites/default/files/telehealth-faqs-508.pdf

https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

http://www.telehealth.hhs.gov/

https://www.healthit.gov/telehealth

https://www.fiercehealthcare.com/tech/house-telehealth-leaders-move-to-cement-regulatory-changes-for-virtual-care

https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

https://www.healthcareittoday.com/2020/07/30/telehealth-and-the-him-professionals-role-relaxing-of-rules-for-telehealth-services-due-to-covid-19-requires-strong-leadership/

COVID-19 Resources

• CDC Coronavirus Homepagehttps://www.cdc.gov/coronavirus/2019-ncov/index.html

• COVID-19 Policy Tracker (information broken out by state)https://www.multistate.us/pages/covid-19-policy-tracker

• Cybersecurity & Infrastructure Security Agency (CISA)

https://www.cisa.gov/coronavirus

• FBI Coronavirus Homepage - Urges Vigilance During COVID-19 Pandemic https://www.fbi.gov/coronavirus

• HealthIT.gov has technical assistance on telehealth https://www.healthit.gov/telehealth


General Resources

https://www.cdc.gov/coronavirus/2019-ncov/index.html

https://www.multistate.us/pages/covid-19-policy-tracker

https://www.cisa.gov/coronavirus

https://www.fbi.gov/coronavirus

https://www.healthit.gov/telehealth

OCR HIPAA Resources

• HIPAA and Public Health https://www.hhs.gov/hipaa/for-professionals/special-topics/public-health/index.html

• HIPAA Privacy Rule

https://www.hhs.gov/hipaa/for-professionals/privacy/index.html

• Guidance on BAAs, including sample BAA provisions

https://www.hhs.gov/hipaa/for-professionals/covered-entities/sample-

business-associate-agreement-provisions/index.html.

• HIPAA Security Rule safeguards https://www.hhs.gov/hipaa/for-professionals/security/guidance/index.html

• HIPAA for Professionals

https://www.hhs.gov/hipaa/for-professionals/


https://www.hhs.gov/hipaa/for-professionals/special-topics/public-health/index.html

https://www.hhs.gov/hipaa/for-professionals/privacy/index.html

https://www.hhs.gov/hipaa/for-professionals/security/guidance/index.html

https://www.hhs.gov/hipaa/for-professionals/

Other Resources

• SAMHSA Title 42 CFR Part 2

https://www.govinfo.gov/content/pkg/FR-2020-07-15/pdf/2020-14675.pdf

• MRO Information Blocking Webinar Series

https://info.mrocorp.com/webinar/info-blocking

• Business Continuity of PHI Disclosure Management During COVID-19

https://mrocorp.com/business-continuity-of-phi-disclosure-management-during-covid-19/


https://www.govinfo.gov/content/pkg/FR-2020-07-15/pdf/2020-14675.pdf

https://info.mrocorp.com/webinar/info-blocking

https://mrocorp.com/business-continuity-of-phi-disclosure-management-during-covid-19/

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