Attorneys Mike Overly and Chanley T. Howell of Foley & Lardner LLP discuss the ways in which personal mobile devices will influence healthcare delivery
Physicians' use of personal mobile devices to treat patients could improve efficiency and reduce cost to providers, but also could pose liability and security risks, attorneys with Foley & Lardner LLP said Jan. 23 during a webinar hosted by the law firm.
Speaking at Foley's webinar on “Emerging Issues in Health Information Technology,” attorneys Mike Overly and Chanley T. Howell, partners at Foley & Lardner, identified how new mobile device trends could both benefit and hurt health care organizations.
On the benefit side of the trend, use of personal devices, such as smart phones, iPads, and other mobile devices, allows physicians to be in communication 24/7 with patients and other physicians, and enables “tremendous” cost savings, Howell, with the firm's Jacksonville, Fla., office, said.
For some hospitals or physician practices, allowing the use of personal mobile devices also can give the organization a competitive business advantage, Howell added.
According to Howell, this growing “bring your own device” (BYOD) trend should be addressed by health care organizations immediately by drafting policies that are easy for employees to understand and anticipating issues that could arise in the future.
Liability Risks
Despite the benefits, liability risks associated with employee use of personal mobile devices are increasingly becoming an issue that needs to be addressed by new health care organization policies, Overly, with the firm's Los Angeles office, said.
According to Overly, the BYOD trend could create liability risks due to:
• personal devices mixing business and personal data;
• risks to information security in personal devices;
• software licensing issues;
• risks associated with shared use of a device with nonemployees; and
• potential risks of an employee disposing of the device inappropriately.
Additionally, mobile device applications used in health care settings that are created by international companies also could pose risks to physicians and consumers, because international data use agreements are different than domestic data use agreements, Overly said.
January 30, 2012
Monday, January 30, 2012
amednews: AMA offers online CME to help with health IT
The Web-based tutorials will educate physicians about analyzing workflow in their offices before they buy any systems.
Pamela Lewis Dolan, Jan. 30, 2012.
The American Medical Association has released three online tutorials aimed at helping physicians implement health information technology into their practices.
The tutorials include videos, downloadable tools and best practices for health IT in a physician practice. They are being offered when many doctors are looking at technology for the first time because of federal incentive programs aimed at increasing physician adoption and use of health IT tools.
Each seven- to 10-minute tutorial is focused on understanding workflow and what changes to expect with new technologies.
The three tutorials offered are:
Pamela Lewis Dolan, Jan. 30, 2012.
The American Medical Association has released three online tutorials aimed at helping physicians implement health information technology into their practices.
The tutorials include videos, downloadable tools and best practices for health IT in a physician practice. They are being offered when many doctors are looking at technology for the first time because of federal incentive programs aimed at increasing physician adoption and use of health IT tools.
Each seven- to 10-minute tutorial is focused on understanding workflow and what changes to expect with new technologies.
The three tutorials offered are:
- E-prescribing. This series will explain the benefits of electronic prescribing and the quality, safety and efficacy compared with paper prescribing. The series identifies opportunities to improve medication management and efficiencies through e-prescribing.
- Pre-visit planning. This tutorial will help physicians implement technology that provides full patient information before a visit. Benefits, including reduced waiting times and improved efficiencies, will be explained.
- Point-of-care documentation. This will guide doctors in making decisions about the hardware used during an office exam. It also will explain the information that should be collected during an exam, as well as the format used to document it.
The AMA said the tutorials will explain the best ways to implement new technology.
"Physician practices may need to redesign and reorganize their office routines so that they can successfully and efficiently adopt health IT," said AMA President Peter W. Carmel, MD.
The CME-accredited tutorials are free. They are an addition to the AMA's library of CME-accredited tutorials, including those launched in May 2011 aimed at helping physicians earn incentives for e-prescribing and meaningful use of EMRs.
ADDITIONAL INFORMATION:
CME-accredited tutorials on health information technology from the American Medical Association (www.ama-cmeonline.com/health_it_workflow)
Tuesday, January 10, 2012
Let NAMSS Help you Reach your Goal To Become Your Own Advocate in 2012
MSPs perform an integral role in keeping health care organizations running smoothly and ensuring the highest-quality patient care. All too often, however, MSPs do not have access to the types of development courses that will help them progress in their careers. Designed for MSPs at every stage of their career, NAMSS’ newest classroom course, Becoming Your Own Advocate, is a comprehensive interactive program designed to help you increase your professional credibility and achieve your goals within your organization. Visit our website for more information on this live offering on January 27 and 28 2012 in Las Vegas, Nevada at the Aria Resort and Casino.
For more information visit our website: http://www.namss.org/Education/CEOpportunities/InPersonCourses/BecomingYourOwnAdvocate/tabid/361/Default.aspx
For more information visit our website: http://www.namss.org/Education/CEOpportunities/InPersonCourses/BecomingYourOwnAdvocate/tabid/361/Default.aspx
Monday, January 9, 2012
Credentialing for Multiple Accrediting Bodies: Help is Here!!!
Do you perform credentialing for entities with more than one accrediting body and need help in keeping all the various accreditation standards straight? We hope that this upcoming webinar series with NAMSS and Stanford University Medical Center’s Debra Green will help you. Visit our website for more information:
http://www.namss.org/MemberCenter/NAMSSStore/tabid/70/pid/315/Comparative-Differences-of-Regulatory-Standards-Webinar-Bundle-w-NAMSS-Membership-Glossary.aspx
To further complement this webinar series, NAMSS also offers “The NAMSS Comparison of Accreditation Standards” which provides you with “plain-language” interpretations of the credentialing standards in a side by side format for easy comparison of The Joint Commission, NCQA, Healthcare Facilities Accreditation Program, DNV, URAC, the Accreditation Association for Ambulatory Health Care, as well as the Medicare Conditions of Participation. Visit our website for more information on this handy reference:
http://www.namss.org/MemberCenter/NAMSSStore/tabid/70/pid/300/2012-NAMSS-Comparison-of-Accreditation-Standards.aspx
http://www.namss.org/MemberCenter/NAMSSStore/tabid/70/pid/315/Comparative-Differences-of-Regulatory-Standards-Webinar-Bundle-w-NAMSS-Membership-Glossary.aspx
To further complement this webinar series, NAMSS also offers “The NAMSS Comparison of Accreditation Standards” which provides you with “plain-language” interpretations of the credentialing standards in a side by side format for easy comparison of The Joint Commission, NCQA, Healthcare Facilities Accreditation Program, DNV, URAC, the Accreditation Association for Ambulatory Health Care, as well as the Medicare Conditions of Participation. Visit our website for more information on this handy reference:
http://www.namss.org/MemberCenter/NAMSSStore/tabid/70/pid/300/2012-NAMSS-Comparison-of-Accreditation-Standards.aspx
Update on The Joint Commission's Sentinel Event Alert on Health Care Worker Fatigue
The Joint Commission has issued a sentinel-event alert saying drowsy health professionals are likelier to be involved in adverse events than their well-rested counterparts. The commission advised the more than 6,500 hospitals and other health care organizations it accredits to take steps to mitigate the risks of such fatigue
Nine ways to give rest to the weary health care worker
In a December 2011 sentinel-event alert, the Joint Commission offered advice to help health care organizations prevent fatigue-related adverse events:
Source: "Sentinel Event Alert Issue 48: Health care worker fatigue and patient safety," The Joint Commission, Dec. 14, 2011 http://www.jointcommission.org/sea_issue_48/
Nine ways to give rest to the weary health care worker
In a December 2011 sentinel-event alert, the Joint Commission offered advice to help health care organizations prevent fatigue-related adverse events:
- Review policies to ensure that they address extended work shifts and hours.
- Assess hand-off procedures to ensure that they protect patients adequately.
- Invite staff to take part in designing work schedules to minimize potential
for fatigue. - Offer tips to fight fatigue, such as doing things that involve physical action, talking with other people, taking short naps and drinking coffee only when tired.
- Educate staff about sleep hygiene and the effects of fatigue on patient safety.
- Offer opportunities for staff to express concerns about fatigue.
- Use a system of independent second checks for critical tasks and complex patients.
- Consider fatigue as a potential contributing factor when reviewing all adverse events.
- Ensure that the nap room is cool, dark, quiet and comfortable; provide eye masks and ear plugs; and let workers turn off pagers between shifts.
Source: "Sentinel Event Alert Issue 48: Health care worker fatigue and patient safety," The Joint Commission, Dec. 14, 2011 http://www.jointcommission.org/sea_issue_48/
Tuesday, January 3, 2012
NAMSS' Comments on CMS' CoPs Proposal
December 22, 2011
Centers for Medicare & Medicaid Services Department of Health and Human Services
Attention: CMS-3244-PRIN 0938-AQ89
Medicare and Medicaid Programs; Reform of Hospital and Critical Access Hospital Conditions of Participation
To Whom It May Concern:
The National Association Medical Staff Services (NAMSS) represents medical services
professionals who, together with the organized medical staffs, manage credentialing and privileging of licensed independent health care providers in hospitals and health care plans across the country. NAMSS supports policies and practices that promote safe credentialing and privileging, and are also efficient and cost-effective. CMS-3244-P proposal is in line with the way in which the majority of medical staffs currently operate, especially with regard to the authority that medical staffs have in evaluating and recommending clinical privileges for non-medical staff members.
NAMSS appreciates many components of the proposed rule, particularly its efforts to
defer to state scope of practice statutes and provide individual hospitals with more
flexibility for purposes of credentialing and staff structure. As with current practice for many institutions, this update distinguishes between the authority of a hospital’s medical staff and its human resources department. CMS further clarifies this categorization by recognizing instances in which practitioners do not fit the traditional categories.
NAMSS response to Medical Staff (482.22)
1) NAMSS commends the progress that CMS continues to make in providing
hospitals the opportunity to grant privileges to non-medical staff practitioners – in
accordance with specific state scope of practice laws. This proposal would
benefit hospitals in rural, poor, and underserved areas. It would also facilitate
hospitals’ use of telehealth services.
2) NAMSS appreciates CMS’ move to defer to hospitals in credentialing and
managing advanced practice registered nurses (APRNs) by allowing hospitals to
categorize APRNs as either medical staff or general hospital staff. NAMSS also
supports the provision enabling hospitals to privilege practitioners without
making them members of the organized medical staff and to establish categories
that define staff and non-staff practitioners. This would help hospitals address
workplace shortages, provide more flexibility to critical access hospitals, small
hospitals, and hospitals in poor urban areas. It would also enable states to better
address primary care provider shortages.
3) Although one single governing body in a multi-hospital system does provide for
economies of scale, and is a reality in some systems, it is important to reaffirm the
ability of the local sub-boards to enact policies and handle issues that directly
contribute to sound patient care decision making, thus avoiding potential harmful
delays due to distance and corporate bureaucracy.
4) NAMSS appreciates that CMS addresses the potential patient care concern of
medical staffs by proposing that physicians and non-physicians will all be
required to comply with standing medical staff regulations. As many hospitals
currently operate, the proposal complies with current hospital and medical staff
regulations. These clarifications, in addition to the Joint Commission’s language
on conflict resolution, reaffirm CMS’ commitment to the important roles that
physicians and the organized medical staff have in staffing responsibilities, which
ensure safe patient care.
Simplifying the credentialing process would greatly assist medical staff professionals in improving practitioner quality and transparency while alleviating unnecessary steps. NAMSS commends CMS for taking steps to eliminate redundancies in current credentialing practice and looks forward to working together to improve health care delivery.
Sincerely,
Kate Conklin, BS, CPMSM, CPCS, CPHQ
President
http://www.namss.org/Portals/0/Advocacy/CMS%20Comments%20Letter.pdf
Centers for Medicare & Medicaid Services Department of Health and Human Services
Attention: CMS-3244-PRIN 0938-AQ89
Medicare and Medicaid Programs; Reform of Hospital and Critical Access Hospital Conditions of Participation
To Whom It May Concern:
The National Association Medical Staff Services (NAMSS) represents medical services
professionals who, together with the organized medical staffs, manage credentialing and privileging of licensed independent health care providers in hospitals and health care plans across the country. NAMSS supports policies and practices that promote safe credentialing and privileging, and are also efficient and cost-effective. CMS-3244-P proposal is in line with the way in which the majority of medical staffs currently operate, especially with regard to the authority that medical staffs have in evaluating and recommending clinical privileges for non-medical staff members.
NAMSS appreciates many components of the proposed rule, particularly its efforts to
defer to state scope of practice statutes and provide individual hospitals with more
flexibility for purposes of credentialing and staff structure. As with current practice for many institutions, this update distinguishes between the authority of a hospital’s medical staff and its human resources department. CMS further clarifies this categorization by recognizing instances in which practitioners do not fit the traditional categories.
NAMSS response to Medical Staff (482.22)
1) NAMSS commends the progress that CMS continues to make in providing
hospitals the opportunity to grant privileges to non-medical staff practitioners – in
accordance with specific state scope of practice laws. This proposal would
benefit hospitals in rural, poor, and underserved areas. It would also facilitate
hospitals’ use of telehealth services.
2) NAMSS appreciates CMS’ move to defer to hospitals in credentialing and
managing advanced practice registered nurses (APRNs) by allowing hospitals to
categorize APRNs as either medical staff or general hospital staff. NAMSS also
supports the provision enabling hospitals to privilege practitioners without
making them members of the organized medical staff and to establish categories
that define staff and non-staff practitioners. This would help hospitals address
workplace shortages, provide more flexibility to critical access hospitals, small
hospitals, and hospitals in poor urban areas. It would also enable states to better
address primary care provider shortages.
3) Although one single governing body in a multi-hospital system does provide for
economies of scale, and is a reality in some systems, it is important to reaffirm the
ability of the local sub-boards to enact policies and handle issues that directly
contribute to sound patient care decision making, thus avoiding potential harmful
delays due to distance and corporate bureaucracy.
4) NAMSS appreciates that CMS addresses the potential patient care concern of
medical staffs by proposing that physicians and non-physicians will all be
required to comply with standing medical staff regulations. As many hospitals
currently operate, the proposal complies with current hospital and medical staff
regulations. These clarifications, in addition to the Joint Commission’s language
on conflict resolution, reaffirm CMS’ commitment to the important roles that
physicians and the organized medical staff have in staffing responsibilities, which
ensure safe patient care.
Simplifying the credentialing process would greatly assist medical staff professionals in improving practitioner quality and transparency while alleviating unnecessary steps. NAMSS commends CMS for taking steps to eliminate redundancies in current credentialing practice and looks forward to working together to improve health care delivery.
Sincerely,
Kate Conklin, BS, CPMSM, CPCS, CPHQ
President
http://www.namss.org/Portals/0/Advocacy/CMS%20Comments%20Letter.pdf
Thursday, December 22, 2011
NPDB-HIPDB News: Enhancements Simplify Multiple Data Bank Processes
Enhancements Simplify Multiple Data Bank Processes
On January 23, 2012, the Data Bank will introduce a number of enhancements aimed at streamlining processes for many Data Bank reporters and queriers, including State Licensing and Certification Agencies and Data Bank Administrators who are responsible for registering their organizations. The changes, summarized below, have the potential to benefit a large segment of the Data Bank community.
Report Forwarding to State Boards
One of the main new features coming to the Data Bank in January will eliminate the need for reporters to mail a copy of Data Bank reports to their relevant State Licensing Board. Reporters of Medical Malpractice Payments, Clinical Privilege, and Professional Society actions must print and mail a copy of the report to the appropriate State agency. Now, the Data Bank will make it easier for reporting organizations to comply with this requirement by enabling them to transmit reports electronically to State Licensing Boards that opt to participate in the new feature.
The automatic report forwarding option requires dual authorization-first by State Boards that must elect to participate, and subsequently by reporters at the time they submit each report. Electronic forwarding will not occur unless both sides agree to the exchange. To take advantage of this feature, each State Board that opts for report forwarding will verify the health care practitioner types they license or certify and agree to receive the reports electronically. Refer to the new State Board Profile page in Figure 1. Reporting organizations will choose to electronically forward their reports to the relevant agency on a report-by-report basis. Electronic report forwarding facilitates compliance with the law, and reporters who take advantage of it no longer need to remember to print and mail paper reports to State Boards.
In cases where a State Board declines to participate, or if a reporting organization prefers not to use the new feature for submitting a report, reporters remain responsible for sending a copy of the Report Verification Document to the appropriate State Board. The new service will be available initially through the Integrated Querying and Reporting System (IQRS). All State Boards will have a new State Board Profile button on the Administrator Options page, where they may enroll in the service, withdraw their agreement to participate, or modify their profile at any time.
Figure 1 State Boards must select the practitioner categories they license or certify when they first set up their profiles. This measure is designed to prevent inadvertent disclosures to the wrong licensing agency.
Please refer to the link below to access Figure 1
After a report is forwarded electronically, both the reporter and the Board will receive a Notice of Action via email and Data Bank correspondence, notifying them that a report was filed. Another email will notify the reporter when the report is viewed, or if a State Board fails to view a report within 7 days. Figure 2 depicts in more detail how the report forwarding process works. Several mechanisms will help track activity among electronically forwarded reports: The Historical Report Selection page may be used to find reports that have been electronically transmitted to State Boards; and the monthly Data Bank summary email for both reporters and State Boards will include information about the number of reports forwarded electronically and whether the reports were viewed. Use of this convenient report forwarding feature will require less manual work and enable the sending and receiving of required reports more quickly.
Figure 2. State Boards and reporting organizations may elect to use the new report forwarding feature. The process is outlined above.
Please refer to the link below to access Figure 2
Registration Enhancements
Another important enhancement taking place in January is a more intuitive entity registration process. This enhancement will simplify an entity's determination of its statutory authority by having the entity answer a few straightforward questions about its organization. As organizations re-register, they also will be able to select additional primary functions to more accurately describe their organizations.
Professional School Report Fields
The professional school report field will be expanded to include schools for chiropractors as well as the existing physician occupations.
Eliminate Mailing of Paper Reports
The Data Bank will begin transitioning toward more reliance on online report change notices instead of sending paper copies by mail. Since 2008, organizations have received report change notices via paper as well as electronically. Most organizations view these notices electronically but have not explicitly opted out of the paper copy, so the January enhancement will complete the transition to on-line report viewing. Organizations that have never reviewed a report change notice online will be given instructions on how to do so and over time they, too, will transition to electronic viewing. Report subjects who currently receive a paper Subject Notification Document will receive instructions on how to view the report online through the Report Response Service. This will not only help protect personally identifiable information by reducing the amount of sensitive information that is sent by mail service, but it also will reduce the amount of paper we print by about 50 percent. Be sure to take advantage of these new features as they become available on January 23rd.
Health Care Reform Law Will Streamline Data Bank Operations
Last year's health care reform law, the Patient Protection and Affordable Care Act of 2010, included a provision to streamline Data Bank operations. Section 6403 of the Affordable Care Act was designed to eliminate duplicative data reporting and access requirements between the National Practitioner Data Bank (NPDB) and the Healthcare Integrity and Protection Data Bank (HIPDB). The statute requires the Secretary of the U.S. Department of Health and Human Services (HHS) to establish a transition period to transfer all data in the HIPDB to the NPDB and, once completed, to cease HIPDB operations. Information previously collected and disclosed through the HIPDB will then be collected and disclosed through the NPDB. The statute's intent is to transition HIPDB operations to the NPDB while maintaining reporting and querying requirements. HHS is drafting a Notice of Proposed Rulemaking to implement Section 6403 and anticipates its publication in the Federal Register in the near future.
Security in Review: Exercising Vigilance
Security is a continuous, high-priority activity at the Data Bank, and in recent years we have implemented an exceptional number and variety of improvements. Some security enhancements were highly visible to Data Bank users, while others may not have been generally obvious. Recent initiatives have included encrypting personally identifiable information, masking data, strengthening password protocols, requiring challenge questions, introducing secure messaging, and changing the way entities and users register with the Data Bank by implementing e-authentication.
There are numerous categories of security threats that all information systems must address to safeguard their information assets. In today's technological environment, the Data Bank is susceptible to a variety of threats, including:
- Identity threats leading to fraudulent access.
- Risk of data corruption.
- Improper data disclosure.
- Physical storage safety.
As technology evolves, the risks to information systems become more sophisticated and more numerous. Data Bank security initiatives reflect an ongoing commitment to confront these challenges promptly and thoroughly by following security standards and guidelines prescribed by the National Institute of Standards and Technology (NIST). For the Federal Government especially, adherence to NIST standards is compulsory and provides the foundation for an effective security policy.
NIST may issue any number of recommendations in a given year. As each new standard is published, the Data Bank must determine how best to incorporate these requirements into the framework of its system architecture, while taking into account its own requirements for meeting the needs of Data Bank users. The ongoing reassessment of security is a process that entails a great deal of planning and preparation, and often the renegotiation of priorities. In essence, security is a constant balancing act between risk and usability, with the ultimate goal of ensuring the safety of Data Bank information.
As we begin a new year, the Data Bank urges its users to review their work areas where threats may exist, from safeguarding physical assets at workplaces to restricting access where and when it is needed. As technology advances, the need for security will remain a challenge that requires continuing vigilance. Safe practices result in secure data, and the entire Data Bank community plays an important role in bringing that about.
Reporting Responsibilities for Health Plans
Health plans exercise an enormous influence on the delivery of health care in the United States. By reporting to the Data Bank, health plans help to protect patients from incompetent practitioners and to stop fraudulent health care practices. The Healthcare Integrity and Protection Data Bank (HIPDB) defines a "health plan" as a plan, program, or organization that provides health benefits, whether directly through insurance, through reimbursement, or otherwise. Examples of health plans include health maintenance organizations, third party administrators, and health insurance companies.
Health plans are required to report to the HIPDB and, in some cases, the National Practitioner Data Bank (NPDB). This article provides a brief overview of the dual eligibility requirements for health plans and their associated reporting responsibilities.
HIPDB Reporting Requirements
HIPDB regulations specify two types of final adverse actions that health plans must report: health care-related civil judgments and "other adjudicated actions or decisions." These actions must be reported to the Data Bank within 30 days of the action being taken. Table 1 describes each HIPDB reporting requirement, identifies the type of Data Bank report that a health plan would use to submit information about an action, and provides examples of reportable actions.
NPDB Reporting Requirements
The NPDB definition of a "health care entity" includes organizations that provide health care services and have a formal peer review process to further quality health care. The phrase "provides health care services" means the delivery of health care services through any of a broad array of coverage arrangements or other relationships with practitioners, either by employing them directly or through contractual or other arrangements. The definition, therefore, may include a range of managed care organizations or other types of health plans.
Health care entities are required to report adverse clinical privileges and panel membership actions to the NPDB within 30 days of the action being taken. Table 2 lists the specific NPDB reporting requirements for health plans that are "Health Care Entities." In addition, any entity, including a health plan that makes medical malpractice payments for the benefit of a health care practitioner, must report those payments to the NPDB.
Table 1. HIPDB Reporting Requirements for Health Plans
Please refer to the link below to access Table 1.
On January 23, 2012, the Data Bank will introduce a number of enhancements aimed at streamlining processes for many Data Bank reporters and queriers, including State Licensing and Certification Agencies and Data Bank Administrators who are responsible for registering their organizations. The changes, summarized below, have the potential to benefit a large segment of the Data Bank community.
Report Forwarding to State Boards
One of the main new features coming to the Data Bank in January will eliminate the need for reporters to mail a copy of Data Bank reports to their relevant State Licensing Board. Reporters of Medical Malpractice Payments, Clinical Privilege, and Professional Society actions must print and mail a copy of the report to the appropriate State agency. Now, the Data Bank will make it easier for reporting organizations to comply with this requirement by enabling them to transmit reports electronically to State Licensing Boards that opt to participate in the new feature.
The automatic report forwarding option requires dual authorization-first by State Boards that must elect to participate, and subsequently by reporters at the time they submit each report. Electronic forwarding will not occur unless both sides agree to the exchange. To take advantage of this feature, each State Board that opts for report forwarding will verify the health care practitioner types they license or certify and agree to receive the reports electronically. Refer to the new State Board Profile page in Figure 1. Reporting organizations will choose to electronically forward their reports to the relevant agency on a report-by-report basis. Electronic report forwarding facilitates compliance with the law, and reporters who take advantage of it no longer need to remember to print and mail paper reports to State Boards.
In cases where a State Board declines to participate, or if a reporting organization prefers not to use the new feature for submitting a report, reporters remain responsible for sending a copy of the Report Verification Document to the appropriate State Board. The new service will be available initially through the Integrated Querying and Reporting System (IQRS). All State Boards will have a new State Board Profile button on the Administrator Options page, where they may enroll in the service, withdraw their agreement to participate, or modify their profile at any time.
Figure 1 State Boards must select the practitioner categories they license or certify when they first set up their profiles. This measure is designed to prevent inadvertent disclosures to the wrong licensing agency.
Please refer to the link below to access Figure 1
After a report is forwarded electronically, both the reporter and the Board will receive a Notice of Action via email and Data Bank correspondence, notifying them that a report was filed. Another email will notify the reporter when the report is viewed, or if a State Board fails to view a report within 7 days. Figure 2 depicts in more detail how the report forwarding process works. Several mechanisms will help track activity among electronically forwarded reports: The Historical Report Selection page may be used to find reports that have been electronically transmitted to State Boards; and the monthly Data Bank summary email for both reporters and State Boards will include information about the number of reports forwarded electronically and whether the reports were viewed. Use of this convenient report forwarding feature will require less manual work and enable the sending and receiving of required reports more quickly.
Figure 2. State Boards and reporting organizations may elect to use the new report forwarding feature. The process is outlined above.
Please refer to the link below to access Figure 2
Registration Enhancements
Another important enhancement taking place in January is a more intuitive entity registration process. This enhancement will simplify an entity's determination of its statutory authority by having the entity answer a few straightforward questions about its organization. As organizations re-register, they also will be able to select additional primary functions to more accurately describe their organizations.
Professional School Report Fields
The professional school report field will be expanded to include schools for chiropractors as well as the existing physician occupations.
Eliminate Mailing of Paper Reports
The Data Bank will begin transitioning toward more reliance on online report change notices instead of sending paper copies by mail. Since 2008, organizations have received report change notices via paper as well as electronically. Most organizations view these notices electronically but have not explicitly opted out of the paper copy, so the January enhancement will complete the transition to on-line report viewing. Organizations that have never reviewed a report change notice online will be given instructions on how to do so and over time they, too, will transition to electronic viewing. Report subjects who currently receive a paper Subject Notification Document will receive instructions on how to view the report online through the Report Response Service. This will not only help protect personally identifiable information by reducing the amount of sensitive information that is sent by mail service, but it also will reduce the amount of paper we print by about 50 percent. Be sure to take advantage of these new features as they become available on January 23rd.
Health Care Reform Law Will Streamline Data Bank Operations
Last year's health care reform law, the Patient Protection and Affordable Care Act of 2010, included a provision to streamline Data Bank operations. Section 6403 of the Affordable Care Act was designed to eliminate duplicative data reporting and access requirements between the National Practitioner Data Bank (NPDB) and the Healthcare Integrity and Protection Data Bank (HIPDB). The statute requires the Secretary of the U.S. Department of Health and Human Services (HHS) to establish a transition period to transfer all data in the HIPDB to the NPDB and, once completed, to cease HIPDB operations. Information previously collected and disclosed through the HIPDB will then be collected and disclosed through the NPDB. The statute's intent is to transition HIPDB operations to the NPDB while maintaining reporting and querying requirements. HHS is drafting a Notice of Proposed Rulemaking to implement Section 6403 and anticipates its publication in the Federal Register in the near future.
Security in Review: Exercising Vigilance
Security is a continuous, high-priority activity at the Data Bank, and in recent years we have implemented an exceptional number and variety of improvements. Some security enhancements were highly visible to Data Bank users, while others may not have been generally obvious. Recent initiatives have included encrypting personally identifiable information, masking data, strengthening password protocols, requiring challenge questions, introducing secure messaging, and changing the way entities and users register with the Data Bank by implementing e-authentication.
There are numerous categories of security threats that all information systems must address to safeguard their information assets. In today's technological environment, the Data Bank is susceptible to a variety of threats, including:
- Identity threats leading to fraudulent access.
- Risk of data corruption.
- Improper data disclosure.
- Physical storage safety.
As technology evolves, the risks to information systems become more sophisticated and more numerous. Data Bank security initiatives reflect an ongoing commitment to confront these challenges promptly and thoroughly by following security standards and guidelines prescribed by the National Institute of Standards and Technology (NIST). For the Federal Government especially, adherence to NIST standards is compulsory and provides the foundation for an effective security policy.
NIST may issue any number of recommendations in a given year. As each new standard is published, the Data Bank must determine how best to incorporate these requirements into the framework of its system architecture, while taking into account its own requirements for meeting the needs of Data Bank users. The ongoing reassessment of security is a process that entails a great deal of planning and preparation, and often the renegotiation of priorities. In essence, security is a constant balancing act between risk and usability, with the ultimate goal of ensuring the safety of Data Bank information.
As we begin a new year, the Data Bank urges its users to review their work areas where threats may exist, from safeguarding physical assets at workplaces to restricting access where and when it is needed. As technology advances, the need for security will remain a challenge that requires continuing vigilance. Safe practices result in secure data, and the entire Data Bank community plays an important role in bringing that about.
Reporting Responsibilities for Health Plans
Health plans exercise an enormous influence on the delivery of health care in the United States. By reporting to the Data Bank, health plans help to protect patients from incompetent practitioners and to stop fraudulent health care practices. The Healthcare Integrity and Protection Data Bank (HIPDB) defines a "health plan" as a plan, program, or organization that provides health benefits, whether directly through insurance, through reimbursement, or otherwise. Examples of health plans include health maintenance organizations, third party administrators, and health insurance companies.
Health plans are required to report to the HIPDB and, in some cases, the National Practitioner Data Bank (NPDB). This article provides a brief overview of the dual eligibility requirements for health plans and their associated reporting responsibilities.
HIPDB Reporting Requirements
HIPDB regulations specify two types of final adverse actions that health plans must report: health care-related civil judgments and "other adjudicated actions or decisions." These actions must be reported to the Data Bank within 30 days of the action being taken. Table 1 describes each HIPDB reporting requirement, identifies the type of Data Bank report that a health plan would use to submit information about an action, and provides examples of reportable actions.
NPDB Reporting Requirements
The NPDB definition of a "health care entity" includes organizations that provide health care services and have a formal peer review process to further quality health care. The phrase "provides health care services" means the delivery of health care services through any of a broad array of coverage arrangements or other relationships with practitioners, either by employing them directly or through contractual or other arrangements. The definition, therefore, may include a range of managed care organizations or other types of health plans.
Health care entities are required to report adverse clinical privileges and panel membership actions to the NPDB within 30 days of the action being taken. Table 2 lists the specific NPDB reporting requirements for health plans that are "Health Care Entities." In addition, any entity, including a health plan that makes medical malpractice payments for the benefit of a health care practitioner, must report those payments to the NPDB.
Table 1. HIPDB Reporting Requirements for Health Plans
Please refer to the link below to access Table 1.
http://www.npdb-hipdb.hrsa.gov/news/newsletters/jan2012Newsletter.jsp#User
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