HIPAA Compliance Problems

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In this assignment you will summarize the HIPA issue in the case study. Form a team of stakeholders that can address the issues, describe policies and procedures, and analyze the flowchart. The specifics for the assignment are attached along with the case study and the flowchart template.

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HIM 440 Gateway Healthcare Systems Case Study St. Catherine’s Medical Center recently announced it will be merging with St. Luke’s Hospital and Hickman Community Hospital to form Gateway Healthcare Systems, all located within the same metropolitan area in the Midwest. You have just been hired as the healthcare system’s HIM director overseeing all three hospitals. Each facility’s department manager or supervisor will report to you. Hospital Profiles St Catherine’s Medical Center HIM Department Mission: Grounded in the Catholic mission of service, we strive to provide accurate patient health information services to all patients with care, concern, and dignity. HIM Department Vision: Provide patients with their health information with sensitivity and respect to their privacy. Profile: St. Catherine’s is affiliated with the Catholic faith and includes an active convent on its campus. It is an 850-bed acute care level-one trauma facility located in the suburbs. The staff and patients come from a variety of ethnic backgrounds and are linguistically diverse. About 60% of St. Catherine’s staff is Catholic, but the hospital abides by legal hiring practices and insists that all employees are treated with respect, including those who fall outside the tenets of Catholicism. In fact, the HIM department has two staff members with hearing impairment who work in the coding section. They have been investigating ways to offer more opportunities to potential employees with physical needs, but with the high volume of reading and direct customer service provided to patients, it has been difficult to accommodate. St. Catherine’s has a reputation of providing quality care to all patients and will not turn away a patient based on ability to pay. It is located in one of the wealthier suburbs of the city and has a strong record of employment retention, even though the average salary level is lower than those of its competitors. St. Catherine’s implemented a new EHR last year and continues to work out new policies and procedures for the new system. Its dictation system was implemented seven years ago. The productivity level has been critically low since implementing the new system. Due to recent budget cuts, St. Catherine’s cannot offer overtime to staff. The HIM department has many long-term employees that do not have formal health information education or credentials. The current coding productivity level is, on average, two inpatient charts per hour per coder, and 10 outpatients (including ED patients) per hour per coder. The coding quality consistently exceeds 95%, per the internal coding auditor. Coding productivity standards were established six years ago using ICD-9 standards, at four inpatient charts per hour. The productivity standards remain at four inpatient charts per hour, despite complaints from coders that the standards are unreasonable. St. Catherine’s last TJC site visit was in October of last year. Overall, the hospital fared well on inspection; however, the HIM department was cited for not having a time stamp on orders in the EHR. (For more information, review regulations RC.01.01.01, EP19 in The Joint Commission E-dition Manual). There have been complaints in the department that some staff do not abide by the break schedule, and some take longer lunches than allowed. Management has not addressed this with staff for fear of losing some of their most knowledgeable and credentialed staff. It has been reported that some of the seasoned coders who have been on staff for more than 25 years are still using the manual coding book rather than the encoder that was implemented five years ago, stating that this saves them valuable time; however, the more recently hired coders are using the encoder system. St Luke’s Hospital HIM Department Mission: To provide providers, residents, and staff with timely access to patient health information for purposes of treatment, research, and reimbursement. HIM Department Vision: Promoting research through state-of-the-art health information management and technology. Profile: St. Luke’s, established in 1942 as a Methodist hospital but no longer a faith-based facility, is a very busy, 400-bed inner-city teaching hospital that provides critical care services to many patients without healthcare coverage. It services the most diverse patient population in the city in terms of ethnicity, religion, class, ability, sexuality, and age; however, its staff diversity is low except in the area of age diversity. The youngest employee is 19 years old and the oldest is 72. St. Luke’s has experienced a high volume of staff turnover during the past three years and does not currently have a HIM manager or director on staff. While it does have credentialed HIM staff, it has difficulty keeping them on board for more than two years. St. Luke’s is using a first-generation EHR that was implemented seven years ago and has difficulty communicating with the other systems in the department and organization. Because of the issues with interoperability, the lab sends down daily batches of paper lab reports that are scanned into the EHR. The encoder was just implemented last year; however, only one coder was thoroughly trained on the new encoder, and she resigned over a year ago. Coding staff frequently use the manual coding books because they cannot seem to find the accurate codes with the encoder. They spend a great deal of time looking up codes in the coding book, then going to the paper binders with the coding clinics to ensure that they are assigning the correct codes. Coding productivity standards were revised after the implementation of ICD-10. Current productivity standards are set at two inpatient charts per hour. The coding supervisor is a new graduate with less than a year of inpatient coding experience. She does not get along well with her subordinates, who are older and have much more experience. Coding productivity is being met per the performance expectations established ten years ago; however, coding quality is consistently rated at 85%, per the external auditing firm. Hickman Community Hospital HIM Department Mission: To assure protection of patient health information at all times. HIM Department Vision: Committed to serving the local community’s health information needs and ensuring patient information is secure. Profile: Hickman is a non-faith-based, 90-bed community hospital located in the oldest part of the city. It has historically served a predominantly low-income, Caucasian patient population, which is comprised mostly of Medicare and Medicaid payers. It has recently been seeing a rise in Muslim patients due to a new mosque in the neighborhood. Hickman Community Hospital has provided services to its local community since 1922, and it is the oldest facility of the three merging organizations. This facility has accessibility issues and was deemed noncompliant with ADA guidelines during the last Joint Commission accreditation survey. Since the hospital staff and patient population are primarily of one ethnicity, the hospital has not seen the need to address cultural diversity training, and therefore it was found noncompliant with TJC standards on leadership. The employees of Hickman are like family—they stick together. While Hickman is the lowestpaying hospital in the area, the family culture has contributed to the longevity of its staff. The HIM department does not currently have any AHIMA-credentialed staff members and does not have any coding quality or quantity expectations in place for the part-time staff members responsible for coding the charts. Hickman is still using paper-based records and manual coding books and resources for coding and billing resources. Hickman currently has a ten-day turnaround time from discharge to final bill dropped, and there is currently no specified number of charts that should be completed on an hourly or daily basis by coders. The acting HIM manager has been employed by Hickman for 35 years and is very fond of her staff; she insists they do the best job in town. Her job as acting HIM manager was meant to be temporary while Hickman searched for a credentialed replacement. The one candidate who met all qualifications was determined “not a good fit” by the hiring committee. He was a 32- year-old African American male and a wheelchair user. Currently, the HIM department does not have any diversity in ethnicity or physical ability among staff members. Preliminary Observations During the first month in your new position as HIM director of Gateway Healthcare Systems, you spent a week at each hospital getting to know staff, reviewing policies and procedures, and making general observations. While visiting with staff at St. Catherine’s, you noticed a few staff members were discarding paper forms with patient-identifying information into the trash can underneath their desks, instead of disposing of the forms in the document shredder located in the front office. You also noticed that the “release of information” staff did not log out of their computers when they were away from their desks. At St. Luke’s, you overheard a discussion in the main lobby elevator between two nurses discussing patient Mary Smith’s prognosis. When you arrived in the HIM department, there were stacks of paper forms and old paper records scattered throughout the department with the patient information openly displayed. In the connecting hallway that patients frequently travel through, you found several carts of records that revealed patient-identifying information. At Hickman Hospital, you arrived to find the staff sitting around having coffee while several patients were waiting to be assisted with obtaining copies of their health records. The releaseof-information clerk came running into the office with a paper copy of a record to hand to one of the patients in line, and said, “Here you go, Mrs. Brown; here’s the copy of your record from Dr. Taylor’s office. He’s our best psychiatrist on staff! You’re in good hands!” Once all of the patients had been waited on, the staff began discussing each patient’s requests along with their diagnoses, medical treatment, and prognosis. At this point, you called an urgent staff meeting. Current Facility Staffing Name of Facility Number of FTEs/PTEs St. Catherine’s St. Luke’s Hickman 55 FTEs/15 PTEs 40 FTEs/5 PTEs 3 FTEs/10 PTEs Number of Management Staff 5 10 1 Number of Credentialed Coders 4 10 0 Number of Transcriptionists 6 8 2 Number of ROI Staff 6 1 0 National Performance Measurement Standards   ICD-10 Coding Productivity Study Highlights Emerging Standards New Study Illuminates the Ongoing Road to ICD-10 Productivity and Optimization Number of Support Staff FT/PT 49 16 10 Top Five Diagnoses by Hospital St. Catherine’s Diagnoses Average Length of Stay (ALOS) Average Time to Code in Minutes Chronic Obstructive Pulmonary Disease (COPD) with Major Complication/ Comorbidity (MCC) 10 39 Gastrointestinal (GI) Hemorrhage with Comorbid Condition (CC) 11 45 Pulmonary Edema and Respiratory Failure 9 43 Septicemia or Severe Sepsis without Mechanical Ventilation (MV), 96+ Hours with MCC 17 53 Spinal Stenosis, Lumbar Region with Combined Anterior/Posterior Spinal Fusion with MCC 12 130 St. Luke’s Diagnoses ALOS Average Time to Code in Minutes Intracranial Hemorrhage or Cerebral Infarction with Comorbid Condition (CC) or Tissue Plasminogen Activator (tPA) in 24 hours 6 38 Renal Failure with MCC 8 42 Spinal Stenosis, Lumbar Region with Combined Anterior/Posterior Spinal Fusion with MCC 10 121 Sepsis, Unspecified 18 Organism, Tracheostomy with MV > 96 hours or Principal Diagnosis Excludes (PDX EXC) Face, Mouth & Neck without Major O.R. 65 Septicemia or Severe Sepsis without Mechanical Ventilation (MV), 96+ Hours with MCC 43 13 Hickman Diagnoses ALOS Average Time to Code in Minutes COPD with MCC 8 46 Heart Failure and Shock with MCC 10 55 Normal Newborn 1.5 30 Renal Failure with MCC 10 62 Vaginal Delivery w/o Complicating Diagnoses 2 45 St. Luke’s Hospital – HIM Department Workflow Process for Loose Lab Reports Step 1 Loose Lab Reports Arrive in HIM Department Step 2 Process Loose Lab Reports • Lab clerk places loose lab reports face up in the HIM foyer, M-F • HIM clerk picks up reports on weekends using the wheeled cart for regular mail pick up • Clerk preps and indexes record for scanning • Reports are scanned into each patient’s electronic health record • Clerk disposes loose lab reports in regular trash receptacle each night Step 3 Discard Loose Lab Reports • Third-shift custodian removes trash from department and disposes in regular trash receptacle outside HIM 440 Module Four Assignment I Guidelines and Rubric Overview: Protecting patient privacy and confidentiality is not just about legal compliance; healthcare workers also have an ethical responsibility to their patients. When you are a HIM director, one way that you might arrive at new policies, procedures, and workflow requirements is forming a team to help develop them, thereby empowering those on whom the policies will have the greatest impact. In this assignment, in addition to assessing HIPAA compliance gaps and workflow, you will also consider how to form effective teams. Prompt: Begin by assessing the HIPAA compliance problems identified in the Gateway Healthcare Systems case study. Using the findings of the preliminary observations of each hospital, set up a working group to develop policies, procedures, and new workflow requirements to address the issues. Specifically, the following critical elements must be addressed: I. II. III. IV. Summarize the HIPAA issues identified in the case study. Form a team of stakeholders that should be involved in addressing the issues. Compile a list that identifies the stakeholders by job title, and give your rationale for the inclusion of each member of the team. Describe policies and procedures that must be implemented to address compliance issues identified in the case study. Analyze the flowchart based on St. Luke’s workflow process, and make the revisions necessary to bring the process into HIPAA compliance. Rubric Guidelines for Submission: Your HIPAA compliance recommendation plan should be a 2- to 3-page Microsoft Word document with a flowchart included. References should be in APA format. Critical Elements HIPAA Issue Form a Team Policies and Procedures Proficient (100%) Summarizes the HIPAA issues for all three hospitals contained in the case study Recommends a diverse group of stakeholders to propose and facilitate strategic recommendations to address compliance issues, and provides rationale for recommendations Describes new policies and procedures that need to be implemented to address compliance issues Needs Improvement (75%) Summarizes the HIPAA issues for all three hospitals contained in the case study, but response is inaccurate and/or incomplete Recommends a diverse group of stakeholders to propose and facilitate strategic recommendations to address compliance issues, but recommendations lack clarity or rationale, or are misaligned to the case study Describes new policies and procedures that need to be implemented to address compliance issues, but response lacks clarity, or examples are not relevant Not Evident (0%) Does not summarize the HIPAA issues for all three hospitals contained in the case study Does not recommend a diverse group of stakeholders to propose and facilitate strategic recommendations to address compliance issues Does not describe new policies and procedures that need to be implemented to address compliance issues Value 22 22 22 Workflow Process Articulation of Response Revises flowchart to ensure workflow that addresses compliance issues Submission has no major errors related to citations, grammar, spelling, syntax, or organization Revises flowchart to ensure workflow that addresses compliance issues, but response contains inaccuracies, is incomplete, or lacks connections to the case study Submission has major errors related to citations, grammar, spelling, syntax, or organization that negatively impact readability and articulation of main ideas Does not revise flowchart to ensure workflow that addresses compliance issues 22 Submission has critical errors related to citations, grammar, spelling, syntax, or organization that prevent understanding of ideas Total 12 100%
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Running head: HIPAA COMPLIANCE PROBLEMS

HIPAA Compliance Problems
Institutional Affiliation
Date

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HIPAA COMPLIANCE PROBLEMS

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Introduction

In the current time of excessive information exchange and access, a small breach of
privacy has the potential of creating a national scandal and debate. Matters of individual health
are considered private and confidential, a reason why medical practitioners and healthcare
providers have to be under oath not to disclose patient information. However, hospital records do
count as sensitive patient information that should be protected. Various commissions and
regulations therein have been implemented to ensure that healthcare facilities ensure the privacy
of their patients is exercised. Health information management (HIM) directors are, therefore,
employed to ensure compliance with these regulations through policies and still ensure
accessibility to patient data is flawless to authorised staff (Eramo, 2018).
Summary of Health Insurance Portability and Accountability Act (HIPAA) Issues
Merging of St. Catherine’s, St. Luke’s and Hickman Community Hospital to form
Gateway Healthcare Systems (GHS) highlights this issue due to the lack of an efficient HIM
system in either of the facilities. Therefore, an assessment of each is req...


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