Paper doesn’t get the publicity these days, but maintaining current and legacy paper-based health records continues to be important to day-to-day HIM operations. Understanding how to file, retrieve, and maintain paper records—especially across multiple locations, such as offsite storage—remains a core function in many departments.

Most HIM departments file by terminal digits, which is the only way to keep files expanding at an even rate. In a terminal digit filing system the last two, three, or four digits of the file number are treated as a single number. Since all numbers in the file are sorted by their ending digits, each section contains approximately the same number of folders, so the file shelves are divided for easy expansion.

A new, free toolkit from AHIMA offers best practices in terminal digit filing. Managers can use the kit to train new or existing staff by having employees review the kit and complete the exercises.

One step to help the industry make the transition to ICD-10-CM/PCS will be temporarily suspending updates to the code set as the October 2013 deadline gets closer.

Freezing both the current ICD-9-CM and the new ICD-10-CM/PCS code sets will save organizations further cost and complexity by enabling them to focus on the system change without simultaneously managing code updates. The Centers for Medicare and Medicaid Services has been receiving recommendations on whether to freeze the code sets and, if so, for how long.

In a recently released statement, AHIMA recommends that:

• The final ICD-9-CM update should be FY 2012 (beginning October 2011, in conjunction with the federal government’s fiscal year).
• No updates should be made to ICD-10-CM/PCS for FY 2013 or FY 2014 (i.e., beginning October 2012).
• Updates to ICD-10-CM/PCS should resume in FY 2015 (October 2014). (more…)

Organizations can find further guidance on developing electronic signature policies in the online version of the November–December practice brief “Electronic Signature, Attestation, and Authorship (Updated).”

The online version includes five separate appendixes, linked at the end of the brief:

• Appendix A excerpts portions of the HL7 EHR-System Records Management and Evidentiary Support Functional Profile Standard, which can be used to develop proposals for selecting an EHR system or as a checklist to evaluate current applications for basic record management functionality.
• Appendix B lists the various e-signature laws, regulations, and acts that organizations can refer to in developing and implementing e-signature functionality and policy.
• Appendix C outlines a sample e-signature model policy template, including important legal and compliance recommendations.
• Appendix D provides a glossary of terms that organizations can use in their e-signature policies.
• Appendix E provides practice guidance on making amendments, corrections, and deletions in transcribed reports.

Managing e-signatures is complex, but doing it correctly is critical  in supporting an organization’s legal health record. Successfully implementing and using e-signatures requires proper attention to individual system functionality, regulatory requirements, and organizational policy.

The Federal Trade Commission has announced a new delay for the Red Flags Rule. Enforcement will now begin June 1, 2010.

The delay, announced October 30, comes at the request of Congressional members, the FTC said. The rule was scheduled to go into effect November 1.

The announcement comes a week after the House of Representatives passed an amendment to the rule that would exclude certain businesses, including small healthcare, accounting, and legal practices. The House bill is currently in the Senate.

On the day FTC announced the delay, the US District Court for the District of Columbia ruled that the FTC may not apply the Red Flags Rule to attorneys.

This is the fourth delay for the rule, which was originally scheduled to take effect November 1, 2008. Industry groups, including healthcare providers and lawyers, have pushed for an exclusion, while others have complained that the rule lacked sufficient detail and guidance. The FTC has since been adding information and guidance online.

Keeping the organization’s master patient index clean leads some HIM departments all the way back to patient registration, where they collaborate to prevent errors before care starts. Accurate registration helps keep patient data complete and clean as it moves throughout the organization.

Long-term trouble can start during a brief check-in. A rushed or incomplete search of the organization’s MPI can cause clinical registrars to create duplicate patient records or even select the wrong record.

Faulty information entered at check-in streams straight through the system, risking treatment errors and leading to eventual billing problems. Entities that participate in health information exchange will export bad information into their networks.

Error-ridden MPIs also hamper an organization’s ability to understand its patient population and its own performance, both for internal and external reporting. Patient information spread across multiple records can distort measures of patient severity and overall risk of mortality. And correcting errors consumes time.

HIM departments often are the hub of identifying and mitigating registration errors. HIM staff sift through the MPI, merging duplicate records and  separating out information that has been overlaid into the wrong patient account. (more…)

The cover story in the November-December Journal examines how healthcare organizations can plan to resolve the anticipated influx of disputed information in EHRs and PHRs. Other features outline downtime planning for health IT systems and the project to transition MS-DRGs to ICD-10-CM/PCS.

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The oft-delayed Red Flags Rule, scheduled to take effect November 1, may be in for a major change. A bill that passed the US House October 20 and arrived in the Senate the next day would exempt, among others, healthcare practices with 20 or fewer employees from meeting the law’s requirements.

The amendment is intended to relieve the administrative burden on small businesses.

The Red Flags Rule, part of the Fair and Accurate Credit Transaction Act of 2003, requires “creditors” and financial institutions to develop and implement written identity theft prevention programs. As described in the rule, creditors are organizations that maintain consumer accounts that receive multiple payments or payments made in installments.

In full, HR 3763 amends the Fair Credit Reporting Act to exclude “any health care practice, accounting practice, or legal practice with 20 or fewer employees.” It also excludes any other business that the Federal Trade Commission, which oversees the rule, determines:

• knows all its customers or clients individually;
• only performs services in or around the residences of its customers; or 
• has not experienced incidents of identity theft, and identity theft is rare for businesses of that type. (more…)

California Governor Arnold Schwarzenegger vetoed a state legislature bill on October 11 that would have specified content requirements for privacy breach notifications.

California law requires businesses and state agencies that have unencrypted personal information lost, stolen, or improperly accessed from their databases to notify affected consumers. However, the law does not specify what information the notification letters must contain.

Senate bill 20 would have ensured businesses include key information in their notices, such as the type of personal information breached, a description of the incident, the date it took place, and who to contact for more information.

The bill was vetoed, Schwarzenegger wrote in his explanation, because there is no evidence of a problem with the information businesses are currently providing consumers. (more…)

Organizations looking to begin the transition to ICD-10-CM/PCS can find project management resources in the October practice brief “Transitioning ICD-10-CM/PCS Data Management Processes.” Web-only resources include:

• Sample project communication plan
• Sample project plan
• Sample project progress report
• Sample issues log

The online version also includes a list of communication aids that organizations may use in the transition to ICD-10-CM/PCS and a contact form for the major stakeholders leading the ICD-10-CM/PCS implementation.

As the practice brief notes, planning for the transition to ICD-10-CM/PCS is a multifaceted effort. Defining the organization’s data management plan will facilitate a smooth transition to ICD-10-CM/PCS and optimize its greater specificity.

Like the rest of us, MS-DRGs have to transition to ICD-10-CM/PCS. Their conversion is off to a good start, with a preliminary version already available.

The conversion project offered an early test of the General Equivalence Mappings and provides organizations with a process for converting their own applications to ICD-10-CM/PCS.

Rhonda Butler and Janice Bonazelli, senior clinical analysts at 3M Health Information Systems, offer an overview of the conversion in this early look into the upcoming November/December issue of the Journal.