Anti-Cloning Campaign: One Individual at a Time RCPA Conference October 6, 2015

Transcription

1 NHS Human Services and Magellan Behavioral Health of Pennsylvania present: Anti-Cloning Campaign: One Individual at a Time RCPA Conference October 6, 2015

2 Presented By: Magellan Karli Schilling, MA, Compliance Auditor Patty Marth, Compliance Auditor NHS Human Services Debra Luther, Ph.D., CCE, Senior Director John Ciavardone, CCE, Senior Vice President

3 Learning Objectives PART I (Magellan) Review the purposes of documentation Review Regulatory references Review the definition and history of Electronic Health Records Discuss the pros and cons of Electronic Health Records PART II (NHS) Implementation of an Electronic Health Record Identify and discuss barriers and solutions Identify and discuss staff training Identify and discuss auditing practices Identify and discuss policies & procedures agencies can implement to protect against cloning Discuss the use of algorithms

4 Learning Objectives PART III (Magellan) Learn about the Managed Care Organization s role Discuss the nuances of auditing Electronic Medical Records Review Audit Trends and Risk/ Consequences Recommendations for Program Compliance PART IV (NHS & Magellan) Open Discussion o Barriers and Challenges o Other Best Practices related to Compliance and EMR o Lessons Learned

5 Part I: Auditing Electronic Medical Records The Managed Care Organization s Perspective

6 Purposes of Documentation Legal record Continuity of Care Plan the course of treatment Monitor healthcare over time Quality Assurance Research and education Ensures compliance with regulatory requirements Supports claims 6

7 Important Regulatory References Chapter 55 PA Code Medical Assistance Bulletins and Policy Clarifications MCO specific guidelines and requirements 42 CFR Part 455: Program Integrity Requirements for Medicaid 7

8 Electronic Health Records (EHR) An electronic health record (EHR), or electronic medical record (EMR), refers to the systematized collection of electronically-stored health information, in a digital format, about an individual patient or a population. 8

9 History Lesson Electronic Health Records (EHR) first appeared in the 1960 s Same goals as today Emergence of Ambulatory Care IOM Report To Err is Human: Building a Safer Health System 2009 passage of Health Information Technology for Economic and Clinical Health Act (HITECH) Incentive Program 2013 Statistics: o 941 manufacturers o 1,700 unique products 9

10 Electronic Health Records (EHR) EHRs replace traditional paper medical records with computerized recordkeeping to document and store patient health information. EHRs may include patient demographics, progress notes, medication logs, medical history, and clinical test results from any health care encounter. 10

11 PROs and CONs of EHR Advantages Quality of Care Legibility Efficiency Accuracy Standardization More Timely Information Reduced Loss of Paperwork Research Continuously Updated Other Capabilities Disadvantages Quality of Care Cost Privacy Issues Workflow changes Temporary loss of productivity Other Technological Issues Software quality and usability deficiencies Cut-and-paste/ cloning techniques 11

12 Quality of Care Debate Do EHR s augment or diminish Quality of Care? 12

13 Part II: NHS s Anti-Cloning Campaign

14 EHR Implementation Barriers: Multiple States and Payers Large Volume of staff Connectivity Solutions: Document modification Tiered roll out IT Support Site based assessments 14

15 Clinical Documentation and Technology The Downside

16 The NHS Anti-Cloning Campaign Multifaceted Approach Etiology - identification of risk Training Policy & Print Media EHR modifications Audits & Algorithms 16

17 The NHS Anti-Cloning Campaign Risk Identification QI Audit Process Investigation process to identify scope 17

18 18 It s all in how you look at things

19 19

20 20

21 The NHS Anti-Cloning Campaign Training Anti-Cloning 101 Anti-Cloning

22 Anti-Cloning Policy and Print Media Defining the issue Concretizing consequences Print Media 22

23 23

24 Observations Mood Communication: Verbal/Non-Verbal Insight Interactions Affect Appearance: Physical, Hygiene, Dress Mental Status Exam Engagement Strengths 24

25 Exercise: Describe what you see 25

26 EHR Modifications Anti-Cloning Acknowledgement Disabled Cut and Paste Functionality (Jquery) Limited use of Pull Forward functionality 26

27 Audits & Algorithms Audit Process Enhancements Side by Side comparison of notes across days and within days of service Review of several weeks/months of notes simultaneously Group Services Audits Algorithm Development Working towards a program to review strings of texts for duplicate content 27

28 Percent Charts Without Duplicate Content Impact of Anti-Cloning Campaign - EHR % 91.13% 92.75% 93.75% % % 97.00% % % % % 83.25% Variance due to auditor Oct '12 Nov '12 Dec '12 Jan '13 Feb '13 March '13 April '13 May '13 June '13 July '13 Aug '13 Sept '13 28

29 Percent of Charts Without Duplicate Content 100% Impact of Anti-Cloning Campaign- Paper Based Documents 90% 96% 95% 92% 96% 92% 80% 84% 83% 70% 60% 63% 66% 50% 40% 41% 47% 52% Variance due to auditor 30% 20% 10% 0% 29

30 30

31 Part III: Auditing Electronic Medical Records The Managed Care Organization s Perspective

32 Managed Care Organization Oversight/ Auditing Why do we Audit? i. To ensure a consistent approach to treatment between providers, Magellan and our County partners ii. Proactive Patient Safety activity iii. To measure adherence to standards set by CMS, Pennsylvania DHS and Magellan s national and local teams How do we Audit? i. On-site Review ii. Treatment Record Reviews iii. Integrated Audits 32

33 Auditing The Differences between Paper Files and EHR Clues identified when reviewing paper files Clues identified when reviewing EHRs Differences in Handwriting Copy and Paste Missing Signatures Electronic Signatures Altered Documentation Over-Documentation Changes in Date of Service No proof of authorship 33

34 Audit Trends- EHR Records Cut-and-Paste/ Cloning Signatures Stamps pre-date end time of the session Signature Stamps conflict with another session or activity Empty Data Fields Missing Notes Pre-populated Code Definitions that don t correlate to provider s contract or applicable regulations 34

35 Implications for Providers using EHR User Guide Usage Policies EHR Vendor Training Audit Logs 35

36 Risk/ Consequences Increased Exposure Corrective Action Identified Overpayment/ Retractions Extrapolation Referrals to Oversight Agencies- BPI, OMHSAS, etc. Referrals to Law Enforcement Exclusion from future participation in federal health care programs (Medicaid, Medicare) 36

37 Recommendations for Monitoring Program Compliance 1. Accessibility to the Requirements 2. Documentation of the Requirements 3. Policies and Procedures 4. Tools to monitor Compliance 5. Audit Plan 6. Measurements of Effectiveness 7. Mechanisms to Correct and Report Non-Compliance 37

38 Part IV: Open Discussion

39 Key Points/ Takeaways Provider s Presentation Don t over-customize your EHR Ensure timely roll out ID risks prior to roll out and train staff to avoid them Give staff the tools to be successful Harness the capacity of your EHR to capture risks MCO s Presentation Know and understand the regulations and other requirements for documentation Recognize both the strengths and limitations of implementing an EHR Acknowledge and address how your EHR system may affect Quality of Care Impact of EHR on Compliance EHR Essential items Know the risks and operate an effective Compliance Program 39

40 THANK YOU!