Verisma Request App® Receives High Praise from Legal Community

By Barbara Carr, RHIA

On our January 26^th Webinar we learned what disclosure management trends would be forefront for the upcoming year. Verisma’s Director of Compliance and Privacy, Debbie Lobb and Verisma’s SVP of Operations, Julia Applegate, shared first-hand knowledge and steps being taken operationally to prepare for these challenges and helping health system clients navigate through these changes.

COVID-19 continues to challenge our healthcare operations. The trend of a hybrid workforce and seeing increases in both digital requests for healthcare information along with increasing payor audits will continue to put an increased burden on the Health Information Management Departments disclosure management operations.

In addition to the ongoing COVID-19 challenges, the deadline has passed for comments on the proposed changes to HIPAA and we are all waiting on OCR to let us know if there will be any further changes and revisions based on the comments. While the proposed changes are to modernize the regulations, the new rules present new challenges for organizations to ensure compliance. For now, I believe it is important for all of us to prepare for these changes and educate our organizations. How will organizations ensure compliance? Will additional staffing be required? How will you train your organization on the changes? On the Webinar we explored what each of these changes mean to your HIM Department operations and how having the right vendor partner and technology can help you manage the changes and ensure compliance.

Debbie Lobb, Verisma’s Director of Compliance and Privacy reviewed the upcoming changes as well as the rationale behind the changes. The overall goal of the upcoming HIPAA changes is to move further toward a more patient centered process and delivering PHI efficiently and accurately to the requestor.  Julia Applegate, SVP of Operations at Verisma, reviewed the operational challenges related to the proposed changes as well as demonstrated how having the right technology can help HIM Departments meet these challenges and remain compliant.

Proposed HIPAA changes and the challenges that were discussed:

Reduction in turnaround time from 30 days to 15 days

The clock starts when the request is received by the organization. The request must be fulfilled, with all authorized information to the requestor within 15 days.

Julia explained that the challenge to this requirement is many. Information being requested can be stored in multiple locations. Sometimes requests can float throughout several departments before reaching the release of information professional’s desk to be processed. Sometimes records with statutorily protected PHI require an additional level of review before being released, based on health system protocols.

Providing on-line access through your website, such as the Verisma Request App®, to request and receive records can reduce many of these challenges and ensure fast and accurate receipt and delivery of the records. In addition, Verisma Spotlight™ reports (our rule-based workflow engine) automatically alert you and your team when sensitive or high-risk requests are entered into the system. This too can cut down on any delays in processing the requests.

Patients Right to Access PHI in-person and allow taking of notes and/or photographs of their PHI

Both Julia and Debbie explained that this will require an additional layer of staff needed to queue up the electronic record, a secure/private area for the review and the presence of a HIM person will need to there in person throughout the onsite review. Many times, the record is not all neatly in one place on the system for review and this may require either signing onto different systems, printing, or actual paper chart or microfilm review. None of this is ideal.

Julia noted that one way to solve the in-person review is to make it easy to request and retrieve the records for the patient. Currently at Verisma, we partner with our clients to integrate with their patient portals and allow the patient to easily request records not available in the portal and once the records are retrieved, we then push the records back into the portal. If an organization does not have a well-functioning portal that can handle this, we then provide direct access for the patient through our Verisma Request App®.

Improved Information Sharing

Allowing for good faith disclosures to avert a threat to health or safety. The definition of healthcare operations has been broadened to cover care coordination and case management. This will ensure a pathway for individuals to direct sharing of ePHI amongst covered entities. An individual will be permitted to direct a covered entity to send their ePHI to a personal health application if requested by the individual.

Operationally, as Julia mentioned in the Webinar, not much would probably change with the current process of allowing “good faith” type of disclosures. Julia presented some operational challenges with these new proposed changes to information sharing. Again, one challenge is multiple sources for the information being requested, records that require special attention, per HIM policy for additional review around sensitive information. Some records being requested aren’t stored in a manner that will allow them to be uploaded to personal health applications. Keeping track of the requests pending review for good faith disclosures or records to be uploaded to personal health application present a challenge to ensure they are reviewed and processed timely, especially given that the turnaround time will be changing to 15 days. Some of the ways to meet these challenges are to have a centralized process, if possible, of ingesting requests from various sources such as fax, snail mail, email, hand delivery and more, and have it all gone into one system for one group of qualified people to account for each request and process for distribution. Having the technology to provide reports and alerts on pending urgent requests and those reaching the timely processing limit. Create protocols specifically detailing, where to go for what records is very important and should be clearly available to all ROI staff processing requests.

Reduced ID Verification Requirements

The proposed changes also reduce the ID verification requirement. For instance, a covered entity cannot require that a patient show up in person and present their ID. Other means of verification can be two factor identification for digital requests. Each covered entity will need to determine their procedures around ID Verification should this change go into effect. They should work with a ROI vendor that has the technology to assist them with this.

Posting Fee Schedules and Notice of Privacy Practices (NPP)

Covered entities will be required to post fee schedules on their websites for PHI access and disclosures. In addition, an estimate of the fees for providing an individual with a copy of their own PHI and if applicable when ePHI may be provided without charge. Some healthcare organizations already post this on their websites. If yours does not, now is the time to work with your IT Department to prepare to post the fees. A patient acknowledgement of receipt of the NPP will no longer be required, which will eliminate the administrative burden of having to require a signature of the patient’s receipt be kept on file.  However, the following changes to the NPP will be required:

• Changes to the header to provide instructions to the individual how to access their medical records
• Information on how to file a HIPAA compliant
• Right to receive a copy of the NPP
• Right to discuss the NPP with a designated person
• Provide information regarding the designated contact person. Is the designated person on-site and include their phone number and e-mail address?

Information Blocking

Debbie reviewed information blocking as it relates to HIM and release of information. While most of the information blocking regulation is technical in nature and relates to technical barriers such as hardware and software, there are administrative barriers such as fees, forms, policies, and authorizations that HIM should be aware of and be prepared to address.

If a request is not fulfilled for a requestor when it would be allowed under HIPAA, that is considered information blocking. Having stricter security for access than what is required by HIPAA would be considered information blocking.  Requiring more information than is needed to fulfill a request would be considered information blocking.

HIM leaders should be reviewing their policies and procedures as well as their authorizations and ID requirements to ensure they are incompliance with the information blocking rules.

Julia strongly recommends reviewing the rejection letter policies to ensure your best practices align with the new rules. Rejecting requests for reasons such as electronic signatures, original signatures, stricter rules around expiration dates, requests for any and all, etc. may represent information blocking concerns.

Continued Disclosure Management Trends Aside from HIPAA and Information Blocking

Digital requests are expected to continue to increase. Having the technology to intake these requests and manage them in a timely and accurate manner is of utmost importance. Working to centralize those requests to a group of individuals for managing, processing, and accountability is something to strive for in ensuring you can meet these demands. This is where it is vitally important to have the right vendor partner who has the technology to support your organization.

Hybrid workforces and staffing challenges will be a continuing trend.  Verisma has workforce training and support centers located throughout the country with a main distribution center located in Syracuse, NY. Verisma can also supply on-site support as well. Again, having the right vendor who can be flexible and work with you to meet your needs will help your organization through these continuing workforce challenges.

In conclusion, it is not too soon to prepare your department and your organization for these proposed changes and ongoing disclosure management trends. Prepare your organization by educating your administration, legal, risk, and other department leaders on the proposed changes and what they will mean for your organization. Review your current policies, procedures, and authorizations and make the changes now.  Seek out technology that can help you and work closely with an ROI vendor who can support you to achieve your goals. HIM leaders should be the ones to lead the way to their organization’s compliance and success!

By Barbara Carr, RHIA

Hospitals are facing a severe labor shortage of both skilled and unskilled workers.  COVID stress and burnout, on top of retirement of the baby boomers, as well as the new vaccine mandates have all contributed to the shortage of labor. 

American economic growth is highly dependent on the quality and quantity of workers. According to recent Forbes article, “Currently, the United States is facing a severe skilled and unskilled worker shortage that has long and short-term economic implications. In addition to the 9.3 million job openings, various economic indicators strongly support the idea that there aren’t enough workers in the United States:  The number of people voluntarily leaving their jobs rose by 164,000 to 942,000 in June 2021.” 

Labor shortages impact both the skilled and unskilled workers’ categories. Clinicians fall into the skilled worker category. While there is an acute shortage of clinicians, skilled workers with “middle skills” requiring more experience than just a high school diploma yet less than a four-year college degree are also contributing to the labor shortage. Middle skills requiring a better-than average understanding of the tools they need to do their job, technical knowledge, problem solving skills, and the healthcare landscape are in short supply. Now COVID vaccine requirements have added to the staffing issue that health care institutions need to address to keep operating. 

During our December 14^th Webinar, “Managing and Maintaining Productivity During a Time of Labor Shortages” we heard from experts at Verisma on how they leveraged Verisma’s technology to help several hospitals’ Health Information Management (HIM) and Patient Financial Services (PFS)/Business Office Departments that experienced labor shortages related to processing requests for records.  PFS departments were faced with the need to keep payments coming in and any backlog in processing claims requests was going to cause a delay in payments. HIM departments dealing with labor shortages and lack of on-site staff were faced with quickly accumulating backlogs that needed to be addressed. Technology and creative out-of-the box thinking were urgently needed to address both types of challenges.

The PFS/Business Office Departments staff were working remote and experiencing labor shortages all at the same time.  The Verisma Release Manager® (VRM) platform, along with Verisma Inbox™ were deployed to allow the remote staff to enter and track claims processing requests for records, respond to denials, as well as ADR Requests. The PFS/Business Office Department was provided access so they could see the status of their requests. Confirmation of records receipt by the payors was available to them and an important tool they could then use when on the phone with a payor. In addition, they had the use of Verisma Analytics™ so they could see volume and turnaround time statistics. Prior to implementation of this tool they were just processing record requests without knowing exactly what was received by the payors and without volume information.

In another real-world example, COVID and then subsequent labor shortages in the HIM department required a solution to handle walk-in requestors.  The remaining HIM staff on site needed to take care of STAT requests and process the incoming mail requests and staff was also hesitant regarding in-person engagement with requestors. The time the existing staff on-site spent on walk-ins was taking away from processing of the paper requests received via the mail and thus a solution was needed.

The Verisma Request App® was installed on the hospital’s website along with the authorization for patients to complete with all the required information of what was being requested.  Patients were able to upload a copy of their driver’s license for verification. Flyers and announcements went out within the healthcare system regarding the new app that was available for patient requests.  Patients walking into HIM were given information for the app as well as access to a kiosk with a PC to complete their request. The request would be sent directly into VRM for processing. This freed up the on-site staff for other duties that were needed to be performed.

Another scenario addressed a health system experiencing a large backlog of requests due to high volumes and staffing shortages. Verisma Inbox™ was implemented where requests from multiple locations were centralized into one location and uploaded by bar code sheets into VRM. Requests were reviewed for duplicates and then sent for processing and distribution by Verisma staff. This relieved the HIM staff of having to process the workload for these requests and allocated time to other priorities.

All the scenarios discussed required thinking outside of the box and creatively using technology to tackle the ever-growing volume of requests coming into the hospital. 

The panelist concluded with a discussion on how to retain talented staff. Ideas such as joining daily staff huddles, keeping work/life balances in mind for your staff, competitive salaries, and showing appreciation for staff were top of mind. Letting staff know they are appreciated and celebrating their achievements goes a long way!

The Healthcare labor shortage is not going away anytime soon. Investing in technology that promotes higher staff satisfaction, reduces turnover, and increases retention is a true investment in higher quality healthcare and organizational longevity. Training and technology can improve a worker’s overall experience as well as reducing the feelings of stress and burnout.   Partner with local educational facilities, find ways to use the technology you already have in place and think outside the box to create new more efficient processes. Looking for a vendor partner that has the technology capability you are looking for and is willing to work with you to achieve your goals, is vitally important to mitigate labor shortages during these times of uncertainty.