MRO recently kicked off the 2020 webinar series, focusing on best practices related to industry trends and challenges, leadership development and regulatory changes that affect the secure and compliant exchange of protected health information (PHI). My colleague Angela Rose and I recently presented the first webinar of the series, Optimizing and Maintaining Operations and Workflows: HIM Life in a COVID World. During this presentation, we explored the new normal for health information management (HIM) professionals during the ongoing pandemic.
Current Health Information Management Environment
Since the beginning of COVID-19, many things have changed in the healthcare environment. More people are working from home, telehealth visits have skyrocketed, and there has been increased demand on hospitals and health systems. Moreover, shortages of supplies and resources, as well as exhausted and limited staff, have put the healthcare industry to the test.
We have also seen many laws and restrictions put into place, or changed altogether, resulting in the need to stay up to date with the latest changes. For instance, many organizations need to review what disclosures are permitted when releasing PHI during a pandemic. Some of those permitted disclosures include the following:
- To provide treatment
- To notify a public health authority to prevent or control spread of disease
- To alert first responders at risk of infection
- To prevent/lessen the threat to the health and safety of a person or the public
- To assist a law enforcement official or correctional institution – Only when the PHI is needed for: providing healthcare to the individual or protecting the health and safety of other individuals present including the person transferring the individual, the law enforcement on site, and the administration at the site
- When required by law
Recently, the HHS released statements regarding the release of PHI to the media, as well as contacting former COVID-19 patients about blood and plasma donations. There has been absolutely no change to the rule that PHI cannot be disclosed to the media, including film footage where patients’ faces are blurred or masked. However, the HHS did release a statement that contacting a patient about blood and plasma donations is permitted under HIPAA as a population-based healthcare operations activity, provided it does not constitute marketing. I recently wrote a blog post about that topic, which you can read here.
Telehealth – Changing Environment
In February 2020, prior to the COVID-19 outbreak, only 0.1% of Medicare primary visits were via telehealth. Fast forward to April 2020, and telehealth accounted for 43.5% of those visits. Another survey of about 300 practitioners, including primary care and specialists, indicated that prior to the pandemic, only 9% of patient interactions were via telehealth. That number jumped to 51% during quarantine, and increased across many specialties including psychiatry, gastroenterology and neurology. In July 2020, the HHS published a comprehensive study on Medicare beneficiary use of telehealth visits, including early data from the start of the pandemic.
Looking forward, there will be a permanent place for telehealth. As patients use telehealth, which is easy and convenient, it will become increasingly difficult to take that option away. Therefore, policies and procedures must be put into place to appropriately account for telehealth. Business associate agreements should be reevaluated as part of that process. Many thought leaders in the healthcare industry predict the need for a new executive position within hospitals and health systems—Chief Telehealth Officer.
Release of Information
We are now about six months into the pandemic, and half of the walk-in windows at hospitals are closed. While some had reopened, many closed again. As a result, many alternative workflows are still in place. To receive record requests, facilities are using secure onsite drop boxes and mail as well as virtual electronic options including fax, email and portals. For delivering requests, options include minimal-contact, in-person appointments and virtual electronic options—fax, email, portals and electronic submission such as esMD, SFTP and ERE.
While most workforces are still temporarily operating remotely, many will remain that way permanently. Ensuring your teams are ready means having policies and procedures for the following areas:
- Home workspace requirements
- Devices and connectivity
- Use and disclosure of PHI
- Reporting incidents
- Work days/hours
Readiness also requires proper education and training. For instance, there has been a major uptick in fraudulent emails, phone calls and even text messages. Organizations must make sure that all employees know what fraud looks like, and how they can maintain a safe working environment while at home. In fact, my colleagues Angela Rose and Anthony Murray will be presenting Security in a Virtual Environment: Protecting Your Workforce at Home on October 21, 2020.
If you are looking to be a thought leader within your organization during the pandemic, there are important factors to keep in mind. Know your environment by understanding your organization’s policies and protocols including response times, action items, workforce exposure protocols, sanitization schedules and contamination controls. Knowing how to communicate both internally and externally regarding these procedures is also essential to becoming a thought leader.
Another important piece is thinking outside the box to achieve success. Adjust KPIs and benchmarks based on realistic, attainable goals. Look at your KPIs pre-pandemic, measure what is going on now and then re-identify appropriate benchmarks. Also be sure to hold regular meetings and touch base with your workforce. To make your meetings more interactive, include video so you can connect with your teams more personally, and make sure they’re engaged and productive during the calls.
Above all, communicate and stay current on what’s going on in the industry. Continue to attend webinars and learn more from other thought leaders in your field. Here at MRO, we will continue to provide thought leadership and educational sessions to keep you up to date on current events.