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PHI Disclosure Management Blog | MRO

Five Takeaways from the 28th National HIPAA Summit

March 21, 2019
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
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Categories: PHI Disclosure Management Blog | MRO

 

 

 

 

 

 

 

 

The month of March holds important projections for the healthcare industry—especially for those involved in privacy, security and patient access to health information. It is when the annual National HIPAA Summit is held every year in Washington, D.C., and this year was no exception.

The 28th National HIPAA Summit was held March 4 – 6 at the Grand Hyatt Washington. Thousands of healthcare professionals gathered to discuss current challenges, future goals and expert predictions for our industry. This year’s event focused on the changing landscape of healthcare privacy, security, HIPAA and Protected Health Information (PHI). Here are my five top takeaways from the National HIPAA Summit 2019.

  1. Beacons of Change: GDPR and CCPA

Passage of both the European General Data Protection Rule (GDPR) and the California Consumer Protection Act (CCPA) is paving the way for stricter standards and expansion of HIPAA. GDPR and CCPA serve as the new measuring sticks for 2019 privacy conversations in healthcare. With this shift come increased compliance risks for providers and business associates (BAs), alongside greater privacy right of action for individuals. For example, presenters at the HIPAA Summit suggested that all stakeholders should be governed by revised guidelines including those currently carved out of the HIPAA rule.

  1. Uptick in Audits

Speakers also suggested there will be an increase in third-party audits to assure a culture of compliance within organizations and BAs. Audits currently conducted reveal four ongoing concerns in healthcare privacy and security:

  1. Lack of BA agreements
  2. Incomplete or inaccurate risk analysis
  3. Impermissible disclosure of PHI
  4. Recurring compliance issue—gaps from risk register not closed

Significant attention remains focused on network servers compromised by hackers and malware. However, smaller breach incidents where patterns are identified but no mitigation efforts occurred will also be investigated.

  1. New Approach to BA Assessments

With regard to BA assessments, generic risk assessments completed by BAs at the request of covered entities (CEs) have become obsolete. A new approach suggests that BAs provide information specific to three aspects of risk:

  1. Describe delivery of the BA’s services
  2. Identify the BA’s risk components
  3. Detail how the BA works to close privacy and security gaps

In addition, HIPAA Summit attendees reiterated that best-practice criteria for vetting BAs include compliance with HITRUST and SOC 2 certification.

  1. Push for Greater Patient Access to Health Information

From HIMSS to the HIPAA Summit in 2019, the healthcare industry is squarely focused on the patient. Patient engagement, patient satisfaction and patient access to health information are top goals for most healthcare provider organizations in the year ahead. Similar to a call for better patient access, heard during a December 2018 congressional briefing, summit presenters pushed for specific improvements for the healthcare consumer:

  • Harmonize information across all states for easier patient access
  • Give the patient (or directed requester) information from the designated record set (DRS)
  • Ensure right of access to the requester (patient and/or their representative)—a primary audit focus with penalties associated with any type of information blocking or hindrance to obtaining health information

Unless providers have contacted the patient and the patient states otherwise, requests for information should be processed by the CE in accordance with existing guidance. Proper alignment of processes to policy helps mitigate breach risk when processing patient-directed requests (PDRs) for information. For example, a specific individual must be named to receive information.

Greater patient access to information is an important step to improve patient satisfaction and create positive patient experiences. In fact, it is one of three key results highlighted in a recent blog post about MRO’s partnership with Saint Luke’s Health System.

  1. Interoperability Promotes Data Sharing, Streamlines the Business of Healthcare

My final takeaway from the HIPAA Summit 2019 was renewed emphasis on interoperability in an effort to streamline the business of healthcare—especially data sharing between providers and payers. Both the OCR and ONC have announced initiatives around interoperability. Two areas in particular were discussed.

Electronic claims. An electronic claims attachments rule was passed in 2012, but has not been widely adopted or enforced. Enforcement of electronic remittance advice (ERA) will reduce paperwork between providers and clearinghouses, with the potential to save $8 billion annually. Facilities will be reviewed for compliance via the “optimization program” versus process audits.

Health plans. Getting data back to health plans is vital to success under value-based reimbursement. Our patients are health plan members. We all have the same purpose—to improve the health of those we serve. Direct exchange of information between CE, provider and plan support this goal while streamlining processes across all stakeholders. The ability for patients to also contribute electronic health data for better patient care coordination is the industry’s audacious goal.

HIPAA was first signed into law in 1996. Today, 22 years and 28 HIPAA summits later, I still learn and advance in concert with healthcare industry changes. Keeping abreast of predictions, such as those listed above, ensures every healthcare professional gains the knowledge they need to deliver high-quality care while protecting privacy, security and patient access to health information.

MRO is committed to keeping our clients and the HIM industry up to date on the latest happenings. To receive updates from MRO when we release new blog posts, complete the form below. You can also learn more in our upcoming PHI disclosure management webinar series, which kicks off April 10, 2019 with a session focused on payer requests for medical records, including audits and reviews.

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Four PHI Disclosure Management Webinars to Catch in 2019

March 14, 2019
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
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Categories: Compliance, PHI Disclosure Management Blog | MRO, Privacy and Security

 

 

 

 

 

 

 

 

As we move into 2019, it is important for healthcare professionals to stay up to date on the latest trends and best practices for managing Protected Health Information (PHI) disclosure across healthcare enterprises.

In MRO’s upcoming 2019 “Best Practices in PHI Disclosure Management” webinar series, the latest trends and best practices for organizations to consider will be covered. There are four parts to this webinar series, and each session is pre-approved by AHIMA for one (1) CEU in the privacy and security domain.

Below are the four session topics in our webinar series, which MRO’s subject matter experts will go into more detail. To register, click here.

Webinar Watch List: Payer Audits, Compliance, Cybersecurity and Patient-Directed Requests

1) The Rising Tide of Payer Requests for Medical Records: How to Shore Up Your Defense
Payer requests for medical records are challenging, time-consuming undertakings for healthcare organizations, typically requiring the release of hundreds or thousands of patient records. MRO’s payer relations expert Greg Ford, Senior Director of Requester Relations and Receivables Administration, will share tips and best practices to shore up your defenses against the rising tide of payer requests for medical records.

2) Enterprise-Wide Disclosure Management: Closing the Compliance Gaps
Privacy and security within a healthcare enterprise are top of mind in an era of regulatory reform and breach. With risks including financial penalties, lawsuits, and reputational damage, healthcare organizations are seeking ways to mitigate risk and ensure proper disclosure of PHI by implementing new technology and HIPAA-compliant policies and procedures. In this webinar, I will cover the benefits of implementing an enterprise-wide PHI disclosure management strategy to close compliance gaps.

3) Cybersecurity in Health IT: Trends and Tips for Safeguarding PHI
In an era of evolving cybersecurity threats, healthcare leaders are challenged to be vigilant in their efforts to minimize risk and implement new, robust safeguards to protect the privacy and security of patient data. MRO’s security expert Anthony Murray, CISSP, Vice President of Information Technology and ISSO, and I will provide best practices for safeguarding PHI across your healthcare enterprise.

4) Clearing the Confusion: Attorney Misuse of Patient-Directed Record Requests and How to Cope
The OCR’s 2016 guidance on patient access was meant to remove roadblocks for patients and their personal representatives when requesting medical records or PHI. However, instead of adding clarification for healthcare providers, the 2016 guidance opened the door for third-party requesters and attorneys to inappropriately request medical records under the guise of patient-directed requests, resulting in rising challenges for healthcare providers. MRO’s legal expert Danielle Wesley, Esq., Vice President and General Counsel, and I will provide clarity on the topic and cover strategies and tactics for combatting the related issues.

Register today for our first webinar, on the topic The Rising Tide of Payer Requests for Medical Records: How to Shore Up Your Defense.

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How Saint Luke’s Health System Enhanced Release of Information Workflows and Improved the Customer Experience

February 07, 2019
Don Hardwick
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Categories: PHI Disclosure Management Blog | MRO, Release of Information, Success Stories

Saint Luke’s Health System (SLHS) includes 16 hospitals, home care, hospice, behavioral health services, and physician practices across Missouri and Kansas. The health system receives 49,200 Release of Information (ROI) requests annually. As SLHS continues to expand, their HIM management team, led by Sharon Korzdorfer, Health Information Management (HIM) Director, is committed to delivering the highest quality health information services to its patients, who may request information concerning care provided by SLHS.

In 2018, Korzdorfer realized that in order to respond to a rise in monthly ROI request volumes compliantly and efficiently, they needed advanced technology and services. After evaluating multiple vendors, SLHS selected MRO to handle Protected Health Information (PHI) disclosure management across the enterprise. Their decision was based on several factors, including MRO’s dedication to clients, patients and other third-party requesters, layers of support from responsive teams of experts, and the ability to leverage technology to improve workflow. MRO’s reputation as a true partner to providers was also a key factor.

“Reputation goes a long way,” said Korzdorfer. “Sales teams can sell anything, but what I have heard consistently from my HIM peers is that MRO always comes to the table prepared to meet and exceed expectations.”

Enhanced Release of Information Workflows: Leveraging MRO’s Technology

SLHS implemented MRO’s flagship Release of Information platform, ROI Online®, along with MROeLink®, a bidirectional interface between the ROI solution and the health system’s Epic EHR.

The MROeLink tool automates manual steps for working in both an ROI system and the Epic EHR. Eliminating manual processes reduces the time needed to process requests and minimizes human error. SLHS leadership knew a system integration method would be a vital component in improving efficiencies and accuracy.

In addition to enhancing the ROI workflow through MROeLink, MRO introduced ways to further improve productivity and service quality, including implementing new processes for responding to the rising tide of payer audits and reviews, such as HEDIS and Medicare Risk Adjustment, by shifting requester relations and correspondence to MRO’s National Service Center.

Improved Customer Experience

As a result of improved workflows, technology integrations, and moving requester relations to MRO’s service center, SLHS reports reduced requester complaints, reflecting improvements in the patient and requester experience.

The Results

Through a partnership with MRO, SLHS saw impressive results, including improvements to turnaround times for ambulatory requests, continued high accuracy levels and an improved customer experience for patients and other requesters of PHI.

Korzdorfer said, “Throughout my experience with the company—from sales, through implementation and training, to the current operational partnership—MRO’s industry experts have been accessible, responsive, communicative and eager to help. It is so refreshing that MRO cares.”

To learn more, download MRO’s Saint Luke’s Health System Case Study by completing the form below.

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An Enterprise-Wide Approach to PHI Disclosure Management: Closing the Gaps in Compliance

January 03, 2019
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
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Categories: Compliance, PHI Disclosure Management Blog | MRO


In an era of regulatory reform and breach, privacy and security compliance is top of mind for health systems. Healthcare leaders are seeking ways to mitigate risk—including financial penalties, lawsuits, and reputational damage—by improving Protected Health Information (PHI) disclosure management processes. Many are embracing the benefits of taking an enterprise-wide approach and standardizing technology, policies and procedures across points of disclosure within their health systems.

In the December 2018 issue of HCCA’s Compliance Today publication, I authored “Enterprise-wide PHI disclosure management: Closing the compliance gaps,” which covered the following four topics.

Increased Focus on Small Healthcare Breaches

Small breaches affecting fewer than 500 patients at a time have become more frequent than the large cyberattacks we see publicized in the news. A cause of these breaches is improper disclosure of PHI during the Release of Information (ROI) process. With increased frequency and impact on patient privacy, small breaches are getting more attention from the OCR.

Small breaches can be just as costly as large ones in terms of penalties and reputational damage. The risks involved with multiple disclosure points and the lack of standardized processes make PHI disclosure difficult to direct and track, making breaches more likely. An enterprise-wide approach to PHI disclosure management is the recommended solution to the challenges faced by healthcare organizations.

PHI Disclosure Across the Enterprise

Although HIM departments still hold primary responsibility for handling PHI disclosures, other areas— including radiology, business offices, and physician practices— increasingly receive requests to release PHI. The issues around this trend pose risks that can lead to privacy breaches. Here’s why:

  • ROI is not a core responsibility of non-HIM staff—and it is not their top priority.
  • Other departments lack sufficient knowledge of rules and regulations governing the compliant release of patient information.
  • Specialized training and multi-tiered Quality Assurance are required to properly disclose PHI.

Quality Assurance Gaps in Release of Information

Quality and accuracy are important aspects of compliant PHI disclosure. However, since ROI workflows involve a variety of manual steps and are complex, there is room for error. Some startling statistics outlined in the HCCA article include:

  • Approximately 30 percent of all submitted ROI authorizations are initially found to be invalid.
  • With more than 100 possible combinations of errors or omission points across a wide variety of request types, up to 10 percent are processed with errors if the only line of defense is the person onsite logging the request.
  • 5 percent or more of patient data in EMRs have integrity issues, including comingling of patient records.
  • Well-trained ROI specialists will catch most of mixed records. However, with just one level of quality control, 1 in every 200 requests will included comingled records.

As a best practice, ROI authorizations and PHI should be checked for accuracy multiple times by specially trained ROI staff and sophisticated technologies to avoid non-compliant requests and/or comingled records. This can be best achieved if PHI disclosure management processes across a healthcare enterprise are streamlined through HIM.

Enterprise-Wide Approach to PHI Disclosure Management

A centralized, enterprise-wide approach to disclosure management is the optimal solution to the imminent challenges that healthcare professionals face. By standardizing processes throughout an organization and applying best practices under HIM’s expertise across the system, healthcare organizations can ensure a steady enforcement of enterprise disclosure policies, a manageable workflow, Quality Assurance and a consistent experience for patients and requesters of PHI. This approach enables healthcare organizations to have complete confidence in achieving compliance. An enterprise-wide strategy not only protects a patient’s privacy, it also protects the institution against breaches, financial risk, lawsuits, and reputational damage.

For more information on breach prevention and tips to protect your organization download MRO’s eBook “Breach Prevention: Tips and Best Practices to Safeguard your Healthcare Organization”

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HITRUST—What It Is and Why It Matters

December 18, 2018
Anthony Murray
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Categories: PHI Disclosure Management Blog | MRO, Privacy and Security

What is HITRUST?

Founded in 2007, the Health Information Trust Alliance (HITRUST) evolved in response to the growing privacy and security challenges faced by the healthcare industry. Aligned with its mission to “champion programs that safeguard sensitive information and manage information risk for organizations,” HITRUST provides broad access to common risk and compliance management frameworks.

For example, the HITRUST CSF®, the cybersecurity framework, is a certifiable framework that provides a comprehensive, flexible and efficient approach to regulatory compliance and risk management. Established in 2015, it is a widely recognized security framework focused on the healthcare industry in the U.S. To ensure an inclusive set of baseline security controls, the HITRUST CSF leveraged nationally and internationally acceptable standards including ISO, NIST, PCI and HIPAA. As a result, the framework has been used successfully to demonstrate HIPAA compliance.

HITRUST regularly updates the CSF to incorporate new standards and regulations to make sure the framework remains relevant and current. As new regulations and security risks are introduced, provider organizations and third parties that adhere to the CSF can be well prepared with optimal security based on quarterly updates and annual audit changes.

Why HITRUST Is Important to BA Risk Management

As healthcare organizations face increased risk of privacy and security breach, recognizing the significant role played by their Business Associates (BAs) is critical. Conducting due diligence is essential before the partnership begins, and is part of the provider’s ongoing risk analysis to ensure partners have HIPAA-compliant policies in place to safeguard the privacy and security of protected health information (PHI). In recent years, many provider organizations have incorporated the HITRUST CSF as part of their third-party assurance process—requiring that BAs obtain CSF certification. This is largely due to the increased number of breaches involving third-party vendors.

Healthcare organizations that entrust PHI to a BA must ensure that sensitive information is properly safeguarded. Best practice is for providers to partner with compliant, secure BAs that offer compliance knowledge, guidance and value beyond the standard contracted services. Obtaining CFS certification demonstrates integrity and commitment to privacy and security practices aligned with stringent regulatory requirements and expectations of the healthcare industry.

With those priorities top of mind, MRO announced in May 2018 that its Release of Information platform ROI Online® had earned HITRUST CSF Certified status for information security. HITRUST incorporates a risk-based approach that includes federal and state regulations and standards to help organizations address challenges through a comprehensive framework of prescriptive and scalable security controls.

As healthcare’s most widely adopted security framework, HITRUST provides an industry standard for BA risk management and compliance. Covered entities can look to HITRUST certification for assurance that the foundation for implementing a framework with security controls required to safeguard PHI is already in place.

To learn more about the importance of HITRUST CSF and MRO’s journey to achieve certification, watch our video “MRO’s PHI Disclosure Management Platform ROI Online® Earns HITRUST CSF® Certification.”

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Heard on the Hill: AHIMA and AMIA Call for Better Patient Access to Health Information in Congressional Briefing

December 10, 2018
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
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Categories: PHI Disclosure Management Blog | MRO, Release of Information

AHIMA and AMIA Call for Better Patient Access to Health Information in Congressional Briefing

On Wednesday, December 5, 2018, I visited Capitol Hill with colleagues from AHIMA and the American Medical Informatics Association (AMIA) to address challenges around patient access to health information and to propose ways to modernize HIPAA to better support patient care. As HIM and privacy professionals are aware, the Office for Civil Rights (OCR) released guidance on patient access to health information in February 2016. However, healthcare leaders have been calling for an upgrade to the 22-year-old HIPAA regulation for some time. The recommendations from AHIMA and AMIA were as follows.

Converge HIPAA with Health IT Certification

We recommended creating a new term, Health Data Set (HDS), which would encompass all clinical, biomedical and claims data maintained by the covered entity (CE) or business associate (BA). The data set would be supported through the certification program at the federal Office of the National Coordinator for Health Information Technology (ONCHIT), enabling individuals to view, download or transmit this information electronically to a third party and access this information via API.

We also suggested the revision of the HIPAA Designated Record Set (DRS) and the requirement that Certified Health IT provide the amended DRS to patients electronically while maintaining computability. This revision would give providers and patients greater clarity and predictability regarding what constitutes the DRS.

Extend the HIPAA Individual Right of Access to Non-Covered Entities

In an effort to provide uniformity of health data access, we suggested establishing a uniform health data access policy that would apply not only to CEs and BAs, but also to non-covered entities such as developers of applications/technologies including mHealth and healthcare-based social media.

Encourage Note Sharing with Patients in Real Time

To enhance patient access to health information, we recommended promoting communications efforts such as OpenNotes through Medicare and Medicaid payment programs, such as the Merit-based Incentive Payment System.

Clarify Existing Regulatory Guidance on Third-Party Access to Patient Data

This especially relates to third-party legal requests that seek information without appropriate patient direction and beyond what is part of the DRS. I reported that ROI vendors and providers continue to be challenged with the discernment of third-party versus patient requests for transmittal to a third party. Third-party requesters demand the patient pricing, and the documentation does not always provide assurances that the requester is the patient or that the patient is aware of the request.

Our experience with some high-volume third-party requesters includes their demand for patient pricing and threats of, or actual submission of, OCR complaints. While we are steadfast in our commitment to patients’ privacy, the ongoing dispute by third-party requesters declining to provide reimbursement for healthcare costs in responding to these requests increases the administrative burden on both the health systems and the OCR.

We are asking that the 2016 guidance be updated to specify the original intent that a patient may direct their information to a third party who is specifically “acting on their behalf regarding a healthcare decision.”

MRO is presently working alongside industry experts to construct a white paper that will delve deeper into this topic and provide recommendations. We will share the paper on our blog once it is released.

 

Additional Resources and Media Coverage:

HealthIT Security – AHIMA, AMIA Call for HIPAA Upgrade to Support Patient Access

MedPage Today – Rules Needed for Better Patient Record Access, Say Experts

AHIMA and AMIA – Full Recommendation

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Breach Prevention: Bolstering Quality Assurance in Release of Information Workflows

November 29, 2018
Don Hardwick
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Categories: PHI Disclosure Management Blog | MRO, Release of Information

Health Information Management (HIM) and healthcare compliance professionals will concur that there is heightened awareness of small breaches across the healthcare industry. And though small privacy breaches affecting fewer than 500 patients per incident are not usually publicized as widely as large-scale cyberattacks, the impact can be just as detrimental to healthcare organizations.

A small breach can be as simple as making an error in the Release of Information (ROI) process, involving a patient’s Protected Health Information (PHI) mistakenly sent to the wrong person—or the wrong patient’s PHI sent to the correct requesting party.

When you look at the stats, there is plenty of room for those types of errors. MRO’s research shows there are as many as 40 disclosure points across a single healthcare system. Most of those disclosure points tend to be outside of the HIM department, where individuals not trained in proper PHI disclosure management are handling the release of PHI. This trend of expanding disclosure points is one of the key factors driving breach risk in the Release of Information process.

Another risk factor involves gaps in the Quality Assurance (QA) processes. Research shows that roughly 30 percent of all Release of Information authorizations are initially invalid. And if Release of Information workflows lack redundant QA checks, up to 10 percent of those invalid authorizations are processed with errors.

Moreover, 5 percent of patient information in electronic medical records (EMRs) have integrity issues, including comingled patient records. MRO’s research shows that without proper QA measures in place, 1 in 200 records released will contain mixed patient information—which means an organization releasing 100,000 requests annually could potentially release 500 comingled records. That’s 500 potential breaches by way of errors in the Release of Information process.

Filling the Gaps in ROI Workflow to Minimize Breaches

Given the potential risk of breach due to improper PHI disclosure, healthcare leaders should closely review gaps in their PHI disclosure management processes and consider ways to enhance workflows to improve accuracy and quality. Here are some recommendations.

First, deploying an enterprise-wide strategy for PHI disclosure management will standardize policies, procedures and technologies across a health system. As part of that strategy, a streamlined Release of Information workflow helps eliminate inconsistencies, inefficiencies, distractions and errors.

Second, redundant QA checks are vital for PHI disclosure accuracy. Even the most experienced ROI specialists are subject to human error. Multiple layers of QA are needed throughout the lifecycle of an Release of Information request, from receipt through delivery, to ensure accuracy and compliance—and prevent a privacy breach. Best practice is to bolster workflows to ensure multiple teams review both the authorizations and medical records associated with each Release of Information request prior to release.

Providing a “second set of eyes” on all authorizations and PHI before release helps reduce improper disclosures. These additional quality checks should come from a combination of trained ROI specialists and record integrity technology that uses optical character recognition to locate and correct comingled records. For example, MRO offers its patented IdentiScan® record integrity application to ensure PHI disclosure accuracy. This tool scans records for patient identifiers throughout the record set, helping ROI specialists identify and correct mixed patient information prior to release. The right combination of people and technology promotes improved accuracy and minimizes breach risk.

Patent Issued to MRO for IdentiScan Application

Learn more about the benefits of IdentiScan® by watching our video. Complete the form below to request a demo of MRO’s ROI solution, which ensures 99.99% disclosure accuracy.

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Webinar Recap: Healthcare Privacy and Security—Predictions for 2019

November 20, 2018
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
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Categories: PHI Disclosure Management Blog | MRO, Privacy and Security

On November 7, 2018, I joined my colleagues Angela Rose, MHA, RHIA, CHPS, FAHIMA, Vice President of Implementation Services, and Anthony Murray, CISSP, Vice President of Information Technology, to present the fourth and final installment of MRO’s healthcare compliance webinar series. In this webinar titled “Healthcare Privacy and Security—Predictions for 2019,” we highlighted privacy and security trends and predictions to help Health Information Management (HIM) and other healthcare leaders navigate compliance in the coming year.

Patient-Directed Requests

Attorney misinterpretation of patient-directed requests (PDRs) was front and center in 2018 and will continue to require clarification and guidance in 2019. When the validity of a PDR is questionable, the patient should be contacted to clarify and confirm consent. Here are additional strategies for handling attorney requests submitted under the guise of a PDR:

  • Inform your state legislators of this questionable attorney behavior
  • Discuss the issue with HIM peers in your area
  • Hold meetings with your OCR representative to determine the best course of action
  • Question and verify (with the patient) any suspicious PDR

We welcome a dialogue with the Office for Civil Rights (OCR) for clarification of the guidance to ensure requests are made for the purpose of assisting the patient with continuity of care—the original intent of the guidance. At MRO, we use the criteria provided by the guidance. The request must be made by the patient, written in the first person and signed by the patient. It must clearly state who is to receive the information and provide the address of that person.

Global Data Protection Rule (GDPR)

Released in May 2018 in the EU, the GDPR provided information on breach protection and response, which could affect guidance in the U.S. regarding notification timelines, documentation controls and data protection rules. The focus in 2019 will likely increase, prompting healthcare organizations to determine changes needed to strengthen privacy and security programs. Also, be aware of state action that is patterning to this rule.

Increased Information Collection

Technology will continue to advance through 2019—becoming faster and safer. With more apps and sophisticated technology, patients must be able to trust that their data is safe and secure. Here are several considerations:

  • What data will you protect?
  • What policies and procedures need to be reviewed?
  • Do you have a complete inventory of your data?

Digital mobile engagement is center stage—wearable devices, home monitors, patient portals, patient generated health data (PGHD) and ongoing technology innovation. The goal is for patients to have a connected, fluid experience throughout the healthcare journey.

Increased Access to Care

The patient experience has changed over the past several decades—from the focus on where patients receive care to where patients search for and choose to receive care. Increased access to care includes urgent care, virtual care, retail settings and nontraditional players such as Amazon and Google. All use some type of technology involving Protected Health Information (PHI) that must be documented and protected.

Population Health, Data and Analytics

Total consumer health requires awareness of educational needs, especially considering the aging population and proactive management of healthcare. Consumers will benefit from initiatives that promote informed decision-making through awareness of available resources and rights regarding PHI. Those efforts demand emphasis on data collection, protection and analytics to improve population health and ensure compliance.

AHIMA’s Vision for 2019

AHIMA recently released its vision for 2019 as the year of transformation. Based on a back-to-basics strategy, AHIMA will emphasize core strengths and services to move HIM forward:

  • Coding/clinical documentation improvement
  • Advocacy/AHIMA World Congress
  • Privacy and security
  • Operational effectiveness—patient-focused access, quality improvement, artificial intelligence, precision medicine, privacy demands

The top three drivers will be security risks, business needs and evolving industry changes.

Technology and Cybersecurity

In 2019, advancements in technology will remain centered on interoperability and cybersecurity. Interoperability is critical to patient engagement and optimal EHR investment required for proper PHI disclosure management.

Additionally, cybersecurity must be a top priority to ensure effective information security programs. Organizations must clarify policies regarding:

  • Risk assessments versus gap assessments
  • Incident response
  • External support
  • Business Associates
  • Third-party assessments
  • Certifications, audits, standards

The evolution of cybersecurity threats means increasingly sophisticated ransomware and other attacks including cryptojacking and whaling. In case of a technology incident, the best strategy is a layered security model to protect, detect, identify and respond.

To learn more about privacy and security predictions for 2019, fill out the form below to receive a copy of this webinar.

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AHIMA Convention Product World Presentation—PHI Disclosure Efficiency in the Business Office

October 25, 2018
Kim Charland, BA, RHIT, CCS
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Categories: PHI Disclosure Management Blog | MRO, Revenue Cycle Management


During the 2018 Annual AHIMA Convention & Exhibit in Miami, MRO hosted the Product World presentation “A Case Study for PHI Disclosure Efficiency in the Business Office—Yale New Haven Health.” I was fortunate to have the opportunity to co-present the session with Cindy Zak, Executive Director of Corporate Health Information Management, Yale New Haven Health.

In her position, Zak is well aware of the challenges HIM professionals face in response to the rising volume of Release of Information (ROI) requests made to business offices to support payment of claims. Business office personnel can spend up to 40 to 45 percent of their day pulling and attaching medical records, taking them away from their core responsibilities. Mostly billers and collectors, these staff typically lack expertise in ROI and Protected Health Information (PHI) disclosure management. And, whenever medical records are handled, HIPAA concerns must be top priority, such as the minimum necessary requirement. Other industry challenges include:

  • Increased backlogs
  • High-priority requests requiring timely fulfillment
  • Complicated/disparate processes
  • Incomplete and inconsistent data collection and trackability
  • Convoluted issue resolution processes
  • Lack of transparency
  • Strained relations among business office, HIM and payers

Together we explored new PHI disclosure management technologies and workflows for improving collaboration between HIM and the business office when fulfilling additional documentation/claim attachment requests.

Addressing PHI Disclosure Challenges in the Business Office

Yale New Haven Health experienced many of the common industry challenges, especially the need for transparency in HIM and an efficient HIM procedure for billing releases. Because the business office maintained ownership of payer requests, HIM was uninformed, serving as a middleman to process thousands of pages. Averaging 20 cases of paper a week resulted in an additional $3,000 per month expense just in paper costs. And, once records were pulled and copied—often including more than the minimum necessary—the information was sent back to the business office for shipping to payers.

As an early adopter of MRO’s business office medical record attachment solution, Yale New Haven Health has already achieved positive outcomes:

    • Business office staff is focused on billing and collecting.
    • HIM staff is focused on pulling the requested medical records.
    • Only the portion of the medical record that is requested is being sent.
    • Paper processes have shifted to electronic delivery.
    • Workflows are based on payer specifications.
    • Medical record claims attachments are sent within 24 hours of receipt.
    • Requests are now trackable to promote transparency.

According to Zak, “Our system business office and HIM personnel collaborate more effectively, focusing on their core responsibilities to maximize productivity and efficiency. The new technology and workflows have reduced paper processes, creating significant cost savings and enhancing enterprise-wide compliance.”

As MRO extends its expertise for health information exchange into business office functions that support revenue cycle management, health systems can benefit from improved efficiency, cost savings, reduced financial risk, trackable delivery, and enhanced interdepartmental and payer collaboration.

To learn more about strategies to improve PHI disclosure efficiency in the business office, fill out the form below to receive a copy of AHIMA’s 2018 Product World Presentation

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Heard at AHIMA 2018—Privacy, Cybersecurity and Information Governance Institute and ROI Roundtable

October 11, 2018
Rita Bowen, MA, RHIA, CHPS, CHPC, SSGB
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Categories: PHI Disclosure Management Blog | MRO, Privacy and Security

AHIMA’s 2018 Privacy, Cybersecurity and Information Governance (PCIG) Institute took place September 22-23 at the 2018 AHIMA National Convention & Exhibit in Miami. True to its aim to enhance knowledge regarding current trends and issues, the event focused on protecting patient information across all healthcare settings and business operations—essential to ensuring patients’ trust in our healthcare system. Protected Health Information (PHI) disclosure management is at the heart of building that trust—and Information Governance (IG) is a critical component.

This year’s institute focused on industry adoption of IG, citing AHIMA’s Information Governance Adoption Model (IGAM)™ as a guide to advance IG practices toward achieving Level 5 maturity. Here are the five levels:

1—Unaware, IG concerns not addressed

2—Limited progress, early stage

3—Defined policies and procedures

4—Proactive program throughout operations

5—Fully integrated into overall infrastructure and business processes

Most attendees indicated their organizations were either at Level 2 or somewhere between Levels 2 and 3—making limited progress and beginning to define policies. This feedback means there’s much work to be done within the HIM domain to successfully measure and achieve IG maturity.

PHI Disclosure Management and IG Connection

A common question posed to HIM leaders on this topic is: What is the relationship between PHI disclosure and IG? First of all, proper disclosure of PHI cannot be achieved without adherence to IG principles—particularly privacy and security. AHIMA describes IG as an enterprise-wide framework for managing information throughout its lifecycle—from the inception of a patient’s record to its eventual destruction. An analogy that comes to mind is the story of a person’s life, the stewardship required from birth to death.

From an IG perspective, HIM professionals must know where information originates, where it flows, how it is released, when it dies—and all risk factors along the way. In our experience, one of the most critical areas of risk is the business office. Implementation of a centralized, enterprise-wide approach to PHI disclosure—aligned with IG principles—reduces risk related to ROI practices.

Modern Age of ROI Roundtable

Following the two-day PCIG institute, I joined my colleague Angela Rose, MHA, RHIA, CHPS, FAHIMA, Vice President of Implementation Services for MRO, and other experts to discuss Release of Information (ROI) challenges and best practices during the ROI Networking Roundtable “The Modern Age of ROI—Are You Up to Date?”

The hottest topic that emerged was patient-directed requests. Many in the industry are seeing inappropriate attorney behavior such as having the patient sign a blank form that the attorney then uses to request patient information. When a form is questionable, the patient should be contacted to clarify and confirm consent.

In the audience was Jim Bailey, President of the Association of Health Information Outsourcing Services (AHIOS), who suggested that states come together to address the issue. Here are four recommended strategies:

  • Raise awareness with your legislators
  • Hold conversations with other hospitals in your area
  • Don’t be afraid of meeting with the OCR
  • Exercise the right to question and verify any request

A valid patient-directed request must clearly reflect the patient’s intent—type of information requested, who should receive the information, for what purpose and method of delivery.

HIM Leadership

Overall, the PCIG Institute, ROI Roundtable and many other informative sessions during the AHIMA Convention reaffirmed that HIM professionals play a crucial role in promoting stronger privacy, security and Information Governance. Trust in the healthcare system depends on our leadership.

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