2013 NPMA Fall Conference Value Through Professional Asset Management Special Considerations and Best Practices for Hospital & Medical Equipment Bob Mahaney,

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Special Considerations and Best Practices for Hospital & Medical

Equipment

Bob Mahaney, CPPS

November 14, 2013


Who is in the room?

New member this year?

First NPMA educational event?


Who else is in the room?

Type of business?

• University/University Hospital• Contract Property/Federal• State/Local Government• Private


Regulatory Drivers for Hospital Assets

GAAP – Generally Accepted Accounting Principles

Medicare – Center for Medicare & Medicaid Services (CMS)

AHA - American Hospital Association

HIPAA – Health Insurance Portability and Accountability Act


GAAP

Generally Accepted Accounting Principles

• Primary guidance

Asset Capitalization Financial Reporting


Medicare - One

Medicare Cost Reporting (MCR)

• Annual report of statistical and financial data

Used to determine the federal governments liability for care provided to Medicare beneficiaries

Provides CMS with data used to set payment rates


Medicare - Two

Sets Requirements for Capitalization

• Capitalization Threshold $5,000 – across the board

Does not consider type of asset for threshold

If it lasts more than two years, it must be capital


Medicare - Three

Sets Requirements for Depreciation

• AHA Estimated Useful Lives of Depreciable Hospital Assets

Separates fixed assets from moveable equipment

May impact your tagging requirements


HIPAA

High Level View

• Privacy Rule

• Security Rule

• Breach Notification Rule


HIPAA – Privacy Rule

Privacy Rule

• Maintaining the privacy of patient information Protection of patient data

Not truly asset related

Use screensavers and don’t discuss patient information without a need to know


HIPAA – Security Rule

“implement policies and procedures that govern the receipt and removal of

hardware and electronic media that contain electronic protected health

information into and out of a facility, and the movement of these items

within a facility.” 45 C.F.R. §164.310(d)(1)


HIPAA – Breach Notification Rule

Breach - ‘‘breach’’ as the ‘‘unauthorized’’ acquisition,

access, use, or disclosure of protected health

information. Treated as a “discovery”

• Date when known or should have been known


Mitigation After the Breach

Must demonstrate actions being taken to avoid future breaches

If not, the government may offer suggestions based on NIST’s Recommended Security Control for Federal Information Systems and Organizations

• Could be much more burdensome to meet


National Institute of Standards and Technology

NIST Control -“develop, document, and maintain[ ] an inventory of information

system components that (a) accurately reflects the current system; (b) is

consistent with the authorization boundary of the information system; (c) is at

the level of granularity deemed necessary for tracking and reporting. . .and (e)

is available for review and audit by designated organizational officials.” NIST

SP 800-53 Rev. 3, Recommended Security Controls for Federal Information

Systems (2009) at Control CM-8


Offsite Authorization Before Breach

Employee acknowledges that he/she may be financially liable for the loss of or damage to item(s) listed above if the loss or damage results from negligence, intentional act, or failure to exercise reasonable care, safeguards, maintenance, and service (Tex. Gov’t. Code Ann. Sec. 403.275 & 403.276). M. D. Anderson will enforce this restitution requirement in a manner that complies with the Fair labor Standards Act.


Offsite Authorization After Breach

I acknowledge that I may be financially liable for the loss of or damage to the device(s) listed above if the loss or damage results from negligence, intentional act, or failure to exercise reasonable care, safeguards, maintenance, and service (TEX. GOV’T. CODE ANN. §§403.275 & 403.276). MD Anderson will enforce this restitution requirement in a manner that complies with the FAIR LABOR STANDARDS ACT. I have read, understand, and agree to abide by all Information Security and privacy policies concerning the use of MD Anderson computing assets and safeguarding protected health information (PHI). I have read MD Anderson’s Information Resources Acceptable Use Agreement and User Acknowledgement, and I understand that Confidential and Restricted Confidential information, including and especially PHI, must remain on MD Anderson owned or leased devices and is subject to MD Anderson security controls. I attest that if any information on this Agreement changes in any material way (e.g., from Internal Use to Confidential or Restricted Confidential), I will promptly complete a new Agreement.


HIPAA – Final Comments

Review your asset policies and procedures

• Are you tracking just assets or data devices also?

• Are you using one system or multiple systems?

• Can you identify data devices at the req/PO level?


X Ray Producing Devices

CT Scanner

Mammography Units

Ultrasound Systems


CT Scanner – Basic Components

Basic Components

• Gantry

• Console (typically located in an adjacent room)

• Electronics


CT Scanner - Image


CT Scanner – Site ID

Site ID Characteristics

• Never changes

• Referenced on the FDA Master Device Equipment Record

• Referenced on all maintenance and vendor work

• Referenced on all upgrades to original asset


CT Scanner – Site ID

Forklift Upgrade

• Site ID does not change

• Major upgrade to components

• Magnet is not replaced


CT Scanner – Asset Record

Parent and Child

• Parent - Gantry

Child - Console

Child - Electronics


CT Scanner – Future Upgrades

Partial disposal and add new child

Keeps the Site ID until final disposition of asset

Can use standard useful life for new child

Offers better tracking of cost and depreciation


Surgical Instruments

Track in asset management system or expense

Budget guidelines are important to AM. Get involved

Surgical kits – easy target for capital/expense games

Guideline Example - A set or case of surgical instruments estimated at $5,000 or greater are a valid capital equipment request provided that at least one item in the set has a minimum unit cost of $5,000.


Inventory Tracking Improvements

Medical equipment requiring maintenance or calibration

• Obtain maintenance and calibration records from department responsible for providing this service.

Have them scan asset tags when they scan serial #

Best of both worlds: tag scan for inventory and serial # validation for tag on asset record



Hospital Beds

• Cleaned after each use

Make scanning the asset tag part of their routine

Tag scans can be used to support their documentation and give you a inventory hit



Equipment carts with laptops

• Have maintenance/calibration team scan the asset tags


Making Tracking Improvements

Identify departments that routinely touch assets

Meet with them frequently

Find a benefit for them to scan and use the asset tag

Bring a scanner• Bring enough to go around

Follow up….follow up….follow up


The Wrap

GAAP and Medicare

• Consistent application of institutional accounting policies

• Don’t violate you own policies for any accommodation It will be selected from a random sample Never fails to be selected


The Wrap

More Medicare

• Be prepared to support differences in capital thresholds

• Be able to defend useful life assigned to assets

• Decide how much, if any, building service equipment will be tagged and tracked separately from the building


The Wrap

HIPAA

• Don’t have a breach

• Review all asset and data device tracking policies

• Get a seat at the table


Questions

Remember – Bring something you learned

back to your workplace.

Documents

2013 NPMA Fall Conference Value Through Professional Asset Management Special Considerations and Best Practices for Hospital & Medical Equipment Bob Mahaney,