Scrambling to comply with the new Privacy Rule changes – particularly the 15-day response deadline?
If you’ve set up an information-blocking and –sharing oversight team, as I wrote about in October, you’re already halfway to a solution.
Such a team comprises representatives from all departments involved in recording, handling, processing, and sharing Personal Health Information (PHI). Under the guidance of a project manager, they’ll include Compliance, HIM, IT, Registration, Legal, plus Medical, Nursing and Clinical department leaders.
Whether you have a team in place or need to establish one, here’s what they can do to get you ready:
- Check response time – Determine how big a potential problem you might have, by checking your HIM records to see how many days your current response time is. If your health organization is like most others, though, there’ll be bottlenecks. You’ll need to go through your workflow to find where they are and how to fix them. One typical bottleneck is departments or practices that keep printed, rather than electronic, records. One workaround for that is scanning all the new printed files into patients’ Electronic Health Records (EHRs). Another potential bottleneck is departments – Physical Therapy, for example – that use different software. Printing, then scanning, then uploading into each PT patient’s EHR is one workaround, but maybe IT can come up with a simpler one.
- Involve leadership – Department heads, practice administrators, physician champions, and chief medical officers – all should be involved in planning and invited to help make decisions as appropriate. This ensures your rollout reflects day-to-day realities. It also ensures you have leadership involvement when it’s time to train staff and follow up to be sure they follow new processes consistently.
- Educate staff – Train your staff on new processes, including the what, how, and why. The leaders you involved in the process can help carry this message.
- Negotiate contracts – You’ll need to renegotiate contracts with independent providers and other business associates. That’s where Legal comes in.
It would also help for you to have advance notice and practical regulatory analysis of just what the new regulations require you to do, along with requirements, tasks, and deadlines, in clear business English, showing you how to do it.
Taken together, these steps can help you avoid time-consuming investigations, costly settlements, and monitoring while making your operations more efficient.