5
www.podiatrym.com JANUARY 2015 | PODIATRY MANAGEMENT 71 patients, educational apps, or patient access to medical information to con- nect with patients and empower them to become more proactive in their own care. What technology lets you do is actually show the patient a picture, for example a lesion, and follow up by sending information from a program to the patient electronically so he or she can read about it later at home. It is a continuum from an episodic visit to a patient being able to access the infor- mation anytime and anywhere after the visit. The ability to aggregate and forward medical information to pa- tients in seconds can assist coordina- tion of care with patients and usually produces a good outcome for both the doctor and patients. Physicians must get used to the fact that since patients have more access than ever to infor- mation from all areas of medicine, the relationship between physicians and patients has changed and will continue to evolve. Physicians and their staff must be prepared for this evolution. However, changes in technology do not give one a break from reflect- Reprinted with Permission from The Journal of Medical Practice Man- agement, Mar/Apr 2014, pgs 286-289, copyright 2014 Greenbranch Pub- lishing, LLC, (800) 933-3711, www. greenbranch.com C utting costs and gaining effi- ciency should be your major priorities. Your goal should be to work smarter by im- proving efficiency and inno- vating existing processes in your prac- tices. With your staff, set 5 to 10 goals, and review them quarterly to make sure you are moving in the right direction. This article will provide you with a road- map on how to achieve your goals by examining your operations to improve efficiency and evaluating your revenue cycle to increase your cash flow. Using Technology to Connect with Your Patients: The Changing Consumer Sector Seeing a patient has become in- creasingly digitally focused, and so you must keep apprised of technical inno- vations that go hand-in-hand with im- proving office efficiency and innovating existing processes. This sounds easier than it is, because it means re-evaluat- ing your workflow, processes, and staff responsibilities. Healthcare is changing, and you cannot stand on the sidelines. You have to have “skin in the game” and take a proactive stance by becom- ing actively involved. The links in your electronic health records (EHRs) among registra- tion, medical records, and billing must be one of your key focuses. There is a great deal of information flowing instantly from the front office to the physician, to the back office, and then to the billing area. Looking forward, efforts should be made to make this transition as paperless as possible. The next step is integrating a consumer application, such as the ZocDoc ap- pointment application, with your EHR system. While the integration of tech- nology has grown in recent years, the focus now is on the patient-consumer sector. While Facebook and Twitter get most of the media attention, the re- lationship between the patient and the physician now serves as a vehicle to level the playing field between them. If you prescribe a medication to a patient, most probably by the time the patient leaves the exam room, he or she has already pulled up some- thing on the Web about it. Now is the time to use technology, whether it’s electronic communication with your These tips will ensure a smoother-running practice. Challenges and Opportunities Facing Physicians BY DEBRA CASCARDO, MA Don’t offer too many options before a caller can reach a person. Continued on page 72 Meaningful Use Ancillary Services Online Reviews ACOs HIPAA Compliance ICD-10 ROADMAP 2015 Obamacare New Technologies ICD-10 D MAP Receivables HIPAA Compliance Patient Portals

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1 HIPAA ... · be to work smarter by im-proving efficiency and inno-vating existing processes in your prac-tices. With your staff,

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Page 1: PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1 HIPAA ... · be to work smarter by im-proving efficiency and inno-vating existing processes in your prac-tices. With your staff,

www.podiatrym.com JANUARY 2015 | PODIATRY MANAGEMENT

71patients, educational apps, or patient access to medical information to con-nect with patients and empower them to become more proactive in their own care. What technology lets you do is actually show the patient a picture, for example a lesion, and follow up by sending information from a program to the patient electronically so he or she can read about it later at home. It is a continuum from an episodic visit to a patient being able to access the infor-

mation anytime and anywhere after the visit. The ability to aggregate and forward medical information to pa-tients in seconds can assist coordina-tion of care with patients and usually produces a good outcome for both the doctor and patients. Physicians must get used to the fact that since patients have more access than ever to infor-mation from all areas of medicine, the relationship between physicians and patients has changed and will continue to evolve. Physicians and their staff must be prepared for this evolution. However, changes in technology do not give one a break from reflect-

Reprinted with Permission from The Journal of Medical Practice Man-agement, Mar/Apr 2014, pgs 286-289, copyright 2014 Greenbranch Pub-lishing, LLC, (800) 933-3711, www.greenbranch.com

Cutting costs and gaining effi-ciency should be your major priorities. Your goal should be to work smarter by im-proving efficiency and inno-

vating existing processes in your prac-tices. With your staff, set 5 to 10 goals, and review them quarterly to make sure you are moving in the right direction. This article will provide you with a road-map on how to achieve your goals by examining your operations to improve efficiency and evaluating your revenue cycle to increase your cash flow.

Using Technology to Connect with Your Patients: The Changing Consumer Sector Seeing a patient has become in-creasingly digitally focused, and so you must keep apprised of technical inno-vations that go hand-in-hand with im-proving office efficiency and innovating existing processes. This sounds easier than it is, because it means re-evaluat-ing your workflow, processes, and staff responsibilities. Healthcare is changing, and you cannot stand on the sidelines. You have to have “skin in the game” and take a proactive stance by becom-

ing actively involved. The links in your electronic health records (EHRs) among registra-tion, medical records, and billing must be one of your key focuses. There is a great deal of information flowing instantly from the front office to the physician, to the back office, and then to the billing area. Looking forward, efforts should be made to make this transition as paperless as possible. The next step is integrating a consumer

application, such as the ZocDoc ap-pointment application, with your EHR system. While the integration of tech-nology has grown in recent years, the focus now is on the patient-consumer sector. While Facebook and Twitter get most of the media attention, the re-lationship between the patient and the physician now serves as a vehicle to level the playing field between them. If you prescribe a medication to a patient, most probably by the time the patient leaves the exam room, he or she has already pulled up some-thing on the Web about it. Now is the time to use technology, whether it’s electronic communication with your

These tips will ensure a smoother-running practice.

Challenges and Opportunities Facing Physicians

BY DEBRA CASCARDO, MA

Don’t offer too many options before a caller can reach a person.

Continued on page 72

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

GroupPractice

AncillaryServices Online

Reviews

Encroachment

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 5:03 PM Page 1

ROADMAP 2015PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

January 2015

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

PatientPortals

GroupPractice

AncillaryServices

OnlineReviews

Encroachment

Obamacare

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

ROAD MAP2015DPMs will thrive

by meeting today’sspecial challenges

The Most Influential Publication for the Podiatric Profession

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

January 2015

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

PatientPortals

GroupPractice

AncillaryServices

OnlineReviews

Encroachment

Obamacare

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

ROAD MAP2015DPMs will thrive

by meeting today’sspecial challenges

The Most Influential Publication for the Podiatric Profession

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

January 2015

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

PatientPortals

GroupPractice

AncillaryServices

OnlineReviews

Encroachment

Obamacare

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

ROAD MAP2015DPMs will thrive

by meeting today’sspecial challenges

The Most Influential Publication for the Podiatric Profession

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

January 2015

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

PatientPortals

GroupPractice

AncillaryServices

OnlineReviews

Encroachment

Obamacare

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

ROAD MAP2015DPMs will thrive

by meeting today’sspecial challenges

The Most Influential Publication for the Podiatric Profession

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

January 2015

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

PatientPortals

GroupPractice

AncillaryServices

OnlineReviews

Encroachment

Obamacare

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

ROAD MAP2015DPMs will thrive

by meeting today’sspecial challenges

The Most Influential Publication for the Podiatric Profession

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

January 2015

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

PatientPortals

GroupPractice

AncillaryServices

OnlineReviews

Encroachment

Obamacare

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

ROAD MAP2015DPMs will thrive

by meeting today’sspecial challenges

The Most Influential Publication for the Podiatric Profession

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 4:44 PM Page 1

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ROADMAP 2015

bers should not multitask while talking to the caller to ensure they obtain ac-curate information and to convey in-terest in and concern for the caller. Staffers should avoid using medical jargon or abbreviations and instead use non-technical language. HIPAA rules apply to phone calls, so staff should always maintain con-fidentiality during telephone conver-sations, being cautious of what infor-mation is given and aware that other patients may be in earshot of the con-versation. Have all of your staff mem-bers sign a confidentially agreement to protect patient confidentiality in compli-ance with HIPAA. Some suggestions for improving your telephone system are: 1) Create written guidelines on how the staff should answer phones and how to handle difficult patients. 2) Have the receptionist identify the practice by name, give his or her name, and then ask, “How can I help you?” 3) Do not allow calls to be on

ing on and reviewing office procedures and policies with a focus on customer service. Now is the time to reflect on some of your practice’s basic operation-al procedures and see if there is room for improvement and the ability to in-crease your revenue at the same time.

Customer Service 101: Start by Reviewing Your Telephone Policies Start with your telephone system because the inability to master your telephone is one of the worst public re-lations issues you can have. How your practice’s telephone calls are managed is key to customer service, marketing, patient satisfaction, and your relation-ships with vendors and colleagues. It is important that you assess your tele-phone system to make sure you have sufficient incoming lines. Your tele-phone company can perform a “busy study” to determine the need for addi-tional lines. This should be done every

18 to 24 months. The first rule is to promptly an-swer calls with a friendly profession-al greeting. Always ask callers’ per-mission to place them on hold, when necessary. If you use an automated phone tree, the first option should be for emergencies, either referring the caller to 911 or an extension that will be answered by a person immediately. Although it is preferable to have a receptionist answer calls during your practice hours, it is acceptable to tri-age dedicated extensions for lab re-sults, appointments, billing issues, etc. in the original automated message. Just don’t offer too many options be-fore a caller can reach a person. In a medical setting, your staff needs to take basic telephone etiquette a step further. Staff members need to be active listeners by focusing on the speaker and the issue being discussed. Have them take notes during the con-versation and limit interruptions to the caller. Most importantly, staff mem-

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

GroupPractice

AncillaryServices Online

Reviews

Encroachment

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 5:03 PM Page 1

Challenges (from page 71)

Continued on page 73

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ROADMAP 2015

Navigating Financial Difficulties The recession has challenged all of us but especially physicians who have been trying to get by on a shoestring budget. Here are some suggestions when addressing costs and staffing that should be performed annually at a minimum. Before you start slashing your budget, under-stand the details behind the num-bers, which allows you to analyze ex-penses more precisely and compare your expenses with national bench-marks. This will allow you to cut expenses based on educational facts rather than on guesswork. Make sure that your expense list is detailed so that you effectively cut costs. For example, a category listed as supplies tells you nothing. You need a subcategory breakdown of those supplies, such as stationery, computer supplies, paper, medical supplies, etc., so that you can effec-tively determine what to cut. Make

hold for more than two minutes. 4) When returning to a call on hold, verify that you have the correct caller on the line. 5) At a minimum, documentation of a telephone call should include the date and time of the call, the caller’s name, the patient’s problem, and the staff member’s response and initials. A proper ending to a telephone call is as important as a proper greet-ing. Review the information and what actions will be taken with the caller. Ask if there are any other questions. Thank the person for call-ing, and let the caller hang up first.

Educating Your Patients: Do You Clearly Communicate Your Expectations to Your Patients? There is nothing better than hav-ing a website, brochure, and patient portal so that you can educate pa-tients as to what you expect from

them and what they can expect from you. Setting practice guidelines from the outset with your patients can eliminate all sorts of problems with communicating with your patients, staff referrals, etc. Issues to consider include but are not limited to: 1) Do you have a financial policy in place? Is it listed in your brochure and on your Web site? 2) At a minimum, your informa-tion should include the services your provide, including medication refills, fee for service, what insurances you participate with, procedures for res-olution of patient compliance, how emergencies are handled, e-mail po-lices, HIPAA rules and regulations, and your policies for no-shows. 3) Your Web site must include a statement that declares your site is for informational purposes only and not intended to render medical advice, so that you are protected le-gally. I suggest that you have an at-torney review what is on your site.

Challenges (from page 72)

Continued on page 74

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

GroupPractice

AncillaryServices Online

Reviews

Encroachment

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 5:03 PM Page 1

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Preparing for ICD-10 transition will require a series of coordinated efforts between your organization and your technology vendors, such as EHR, practice management sys-tem, and clearinghouse providers. Your technology vendors will play a vital role in ensuring the transition is smooth for your practice; make sure they will be able to provide the support you need before, during, and after the transition. Insist that your vendors have a schedule for updating products and services that

allows adequate time for you to con-duct testing. Implementation of the new ICD-10 codes will have multiple financial ramifications. While it is expected that every technology vendor will do its part for a successful transition, there are many changes on the hori-zon that may impact your organiza-tion and you should ask about them now. Talk with your vendors now to be sure that you can count on them to: • Have fully functional, compli-ant products and services ready in plenty of time to allow for thorough ICD-10 testing; •Help you avoid potential reim-bursement issues and interruptions to workflow; •Letyouknowwhatisexpectedfrom you to ease the transition; • Communicate with you duringthe transition; • Offer training and customersupport; • Determine if your IT systemsneed an upgrade and if it can be done in phases and/or if upgrades are covered by current contracts; and • Determine if your system willneed: –More storage capacity for the increased number of codes; –New servers; –New workstations; and

sure your categories are as detailed as possible by breaking down subcat-egories even further.

Re-examine Your Staffing Does everyone have a job de-scription? Is everyone cross-trained? Is it better to employ two part-time workers instead of one full-time person so that you reduce benefits and have expanded coverage hours? These are some of the questions that you should be addressing at least once a year with your partners. The answers to these questions depend on your locations, specialty, and af-filiations and are very personal. How-ever, the overall goal is to reduce your operating expenses by at least 5% to 10%. Don’t go too lean when it comes to technology, tools, and training because it can cost you in overtime, computer service contracts, and poor customer service.

Re-examine Your Vendor Agreements Are you getting the best deal pos-sible? Many vendors will renegotiate their agreements and explore other options to ensure your continued business. You should take advantage of their mindset. Are you buying in bulk so that you get significant dis-counts?

Evaluate Your General Operating Costs When was the last time your practice conducted an energy audit, telephone audit, or inventory review? When was the last time you asked for and received feedback from your staff on how to reduce costs? Have a contest with your staff that the person who comes up with the best cost-effective strategy gets a $100 bonus at the end of the month, and keep it going. You will be surprised how entrepreneurial staff members become if they have “skin in the game.”

Perform a Front-End Coverage Verification Audit Make sure that you conduct pre-appointment insurance reviews on all your patients, by calling payers to

verify patient responsibility amounts and collecting those amounts before the patients see the doctor.

Review Fee Schedules and Payments by Managed Care Companies, and Your Contracts with Them Traditional fee-for-service pay-ment is moving toward a payment structure that compensates based on outcomes. Know what your out-comes are per carrier, as many vari-ations will be brought to this ev-

er-changing healthcare arena. At no time should you forget that you must remain cost-conscious, be efficient in delivering medical ser-vices, and be reasonably compensat-ed for what you do.

ICD-10 Transitional Stage Implementation: How It Affects Your Office Productivity There is no turning back now, but many practices have a lot to do to get ready for ICD-10. Expect the unexpected. ICD-10 will impact prac-tices through lost time, cash-flow in-terruptions, and the cost of IT up-grades. Thoughtful planning can help a practice through the transition and estimate costs to allow for budgeting of both time and money. Expect coders who have been working with ICD-9 codes for de-cades to be a little slower and per-haps less accurate when faced with the new ICD-10 codes. However, there are some steps a practice can take now to minimize productivi-ty slowdowns during the transition from ICD-9 to ICD-10. As an auditor, it has been my impression that most practices and providers can map their 20 most fre-quently used ICD-9 codes to their corresponding ICD-10 codes, and focus their ICD-10 training on those codes with the biggest revenue reper-cussions.

Practices will be fined for not having proper protocols and policies in place to prevent a

possible “future” wrongful disclosure.

Challenges (from page 73)

Continued on page 76

PODIATRY

MANAGEM

ENT•

HOW

TOUSE

SMARTPHO

NETECHNO

LOGY

TODO

CUMENT

YOUR

NURSINGHO

ME

CARE•

AUGUST2014

Also Inside:

Forensic PodiatryRediscovering

Compounding PharmaciesTherapeutic Shoe Update

POD

IATRYM

AN

AG

EMEN

T•

ROA

DM

AP

2015•

JAN

UARY

2015

NewTechnologies

MeaningfulUse

Malpractice

EBMParity

GroupPractice

AncillaryServices Online

Reviews

Encroachment

Receivables

ACOsHIPAA

Compliance

PQRS

ICD-10

PERIODICALS DELIVER PROMPTLYDELIVER TO

www.podiatrym.com

PodMcoverJan15:CoverA/M09 12/15/14 5:03 PM Page 1

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ROADMAP 2015

ciates must be HIPAA-compliant, their compliance is not transferable to your organization. You still need your own comprehensive compliance program. Although your vendors may sign a business associate agreement, you must perform due diligence to ensure that their vision of compliance meets the protocols you have established in your compliance plan. Don’t assume that cloud services are less secure than on-site solutions. If tailored to healthcare clients and HIPAA compliant, the cloud could offer

cost savings and increased efficiency. Having a comprehensive compli-ance plan that restricts user access to PHI is vital. However, ongoing train-ing, monitoring, and enforcement are necessary to ensure there are no se-curity breaches.

Conclusion As complicated as running a med-ical practice is, you have to remem-ber some of the basics, such as tele-phone skills, and focus on how they affect your practice, image, and bot-tom line. The examples above will help you maintain financial stability without compromising patient care and phy-sician and staff satisfaction. While it is important to concentrate on ICD-10 implementation, increased HIPAA compliance, and the Affordable Care Act, don’t forget to look at the basics in your practice policies and procedures on a regular basis. With the rise in fines and penalties assessed by the regulato-ry bodies, your practice must have in place policies to protect itself from ad-verse compliance risks. Well-prepared practices are those that recognize the obstacles and prepare for them early. Start preparing now. PM

Debra Cascardo is Principal of The Cas-cardo Consulting Group, and a Fellow of the New York Academy of Medicine; phone: 914-358-9553; fax: 914-358-9554; e-mail: [email protected].

–An EHR management system ca-pable of handling ICD-9 and ICD-10 codes.

ICD-10 Implementation Costs Implementation of the new ICD-10 codes will have multiple financial ramifications for your practice. First will be the up-front costs associated with upgrading your IT systems to accommodate the new codes. As men-tioned above, vendor contracts may have to be renegotiated to include ad-ditional hardware, software, training, testing, and customer service. Until coders become familiar with the new systems and codes, there will most likely be lower productivi-ty, which means slower claims turn-around and slower reimbursement. This slower revenue cycle could re-quire temporary lines of credit. The transition phase may also incur costs for overtime or for tem-porary clinical and/or administrative help before, during, and after the transition. Estimate what your proba-ble costs will be so you can accurate-ly budget for them. Make sure that you ask your vendors to establish a comprehensive approach that will deliver compatible products when you need them. Numerous medical associations have an array of training and resources to assist you during your transition period.

HIPAA Compliance 2014 In the summer of 2012, the en-forcement wing of the Department of Health and Human Services (HHS), which is the Office for Civil Rights(OCR), began a pilot campaign ofHIPAA compliance audits (www.hhs.gov/ocr/privacy/hipaa/enforcement/index.html). As of September 23, 2013, that pilot campaign became a full-time, heavily enforced effort with many more facets involved. With the influx of more than 5 million business associates (those doing business with covered entities and privy to protected health informa-tion [PHI]) as of the omnibus changes of September 23, 2013, the federal government is aggressively ramping up its enforcement efforts and its own training. The audits should be sim-

ilar to those used by OSHA. In thepast with HIPAA, practices were fined only for a reported complaint or a blatant wrongful disclosure. Now, it appears practices will be fined for not having proper protocols and policies in place to prevent a possible “future” wrongful disclosure. For the federal government, the enforcement of HIPAA and render-ing of massive fines upon covered entities (healthcare providers, health plans, clearinghouses, and business associates) will generate a cash in-

flux. However, this should not come as a surprise since the government has been saying for years that HIPAA must be fully operational at your practice or business. And remember, ignorance of the law is not an excuse. Make sure you have a designated compliance officer and that you un-derstand the changes in the rules and regulations, which include: 1) The new obligations and li-abilities of business associates and subcontractors; 2) The new breach notification requirements; 3) What happens if PHI is dis-closed through your EHR; 4) Understanding the stronger en-forcement of HIPAA and HITECH vi-olations and imposition of penalties; 5) Recognizing the differenc-es among HIPAA Omnibus Rules,HIPAA Privacy Rules, and HIPAA Security Rules. Many practices are under the assumption that they are compliant with HIPAA, when in reality they are not. There are incorrect compliance assumptions that should alert you to the need for a review of the compli-ance program in your practice or that of your vendors. A vendor’s service or software package that is HIPAA-compliant does not necessarily mean your organiza-tion is HIPAA compliant. Although your vendors and other business asso-

Make sure you have a designated HIPAA compliance officer and that you understand the changes

in the rules and regulations.

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