ROI Release of Information Understanding the Process Segments ROI+ a new revenue opportunity for Providers 1
Most Providers believe the following myths: They validate the legitimacy of every Requestor and every request Mail and Fax delivery meet HIPAA compliance standards Being HIPAA compliant mitigates legal risk Red Flag (Identity theft) compliance will not land on their doorstep EHR/EMR systems have a fully functional ROI fulfillment component They are realizing the full ROI revenue opportunity There is no more efficient method to conduct ROI fulfillment above and beyond what they are doing today ROI fees will remain stable They understand the dynamics of true edelivery 2
The Ugly Truth 1.) Data stored in multiple systems -- Many patients visit numerous specialists at different medical facilities within a single health system, which forces HIM professionals to access multiple systems to retrieve a patient's full medical history upon request. 2.) Systems are not designed for easy printing -- EHRs are set up so medical personnel can easily view a patient's health record, but are not necessarily designed for printing/transmitting the information. As a result, it is imperative that a trained professional has expertise in reproducing a record that is useful for the requestor, while also complying with HIPAA and other regulations. 3.) Older records in alternative formats -- More and more records are kept electronically but, if an HIM professional is required to accumulate a patient's medical history over a significant amount of time, he or she may encounter microfilm or paper records, which can be stored in multiple locations or off site. The co-existence of paper and electronic formats increases the margin of error when processing requests, necessitating a welltrained ROI specialist to track down multiple sources of information. As a result of limitations imposed by the federal and some state governments, outsourcing companies are having difficulties staying afloat, which could ultimately make more hospitals bear the expense and risk of servicing requests for health records. ROI specialists' responsibilities go above and beyond simply clicking a button and making photocopies; each individual must closely monitor the complexities mentioned in this article and additional ones when releasing a health record. It is essential that certified, knowledgeable professionals are in place to conduct these ROI requests. If state legislators continue down the path of restricting fees on health records, all health care providers will face the inevitable financial burden. 3
Found money is money that is available but not yet discovered! ROI is truly Found Money!!! 4
85% of Providers cannot produce the following ROI metrics! Description Salary Other Cost Labor (3 FTE's) $82,723 Total Labor Cost $82,723 General Administrative Expense (G&A) $0 Mailing, FedEx and Fax Costs $2,551 Facilities Cost (Floor Space, Utilities& Telephone) $500 Equipment Depreciation & Maintenance (Scanners, Fax, Copiers) $0 Supplies Cost (Paper and Ink) $0 ROI Basic Subscription Cost $30,000 ROI Basic Fulfillment Cost $57,195 ROI Premium Inv & AR Subscription Cost $6,000 ROI Premium Inv & AR Fulfillment Cost $7,626 Total ROI Overhead Costs $186,595 Deposits Past 12 Months (Medical Record Copy Fee) $224,251 Profit Margin $37,656 Revenue per ROI Event $14.70 Margin per ROI Event $2.47 16.79% Function Annual Volume RELEASE OF INFORMATION Requests (includes walk-ins, telephone calls, faxes, and mail) 2,700 Texas Rehab Commission 5,212 Workers Comp 291 Patient/Personal 262 Subpoenas & Court Orders 5,138 External audit requests (Medicare, Medicaid, etc.) 1,649 Subtotal 15,252 5
Understanding the full ROI Process Step #1 Step #2 Step #3 Step #4 Step #5 Step #6 Step #7 Step #8 Step #9 Validate Requester Collect Content Aggregate Content Package & Deliver Content Create Invoice Send Fulfillment Notification Collect ROI Fees Authenticate Receipt of Content Track ROI Content Activity Confirm that the Requestor a legitimate entity OnSite OffSite Paper Charts Digital Images ` EMR/EHR) Paper Digital Images ` Data (EMR/EHR) Prepare for Delivery Pursuant to fee structure set forth in State Statues Confirms Fulfillment Satisfaction Collect before sending content. Manage open unpaid events including all revenue/fee reports Who received ROI content on Requestor side and When? Who is looking at ROI content? Step categories: HIPAA & Red Flag Compliance Oversight Operational Collection & Fulfillment Activity Managed Revenue Billing& Collection 6
Step #1 Validate Requester 1. Verify that the Requestor is a valid entity Validate the Requestor is entitled to receive requested information Requestor must specify person(s) to receive information 2. Check the request document for the following information Original signature of the patient/legal representative (NO COPIES OR FAXES WILL BE ACCEPTED!) Must specify information/date(s) of service being requested Purpose for ROI request Identifying information about the patient (name, date of birth, etc.) Must be dated after the date(s) of service being requested Must have an expiration date, otherwise it will expire 90 days from original signature If a legal representative signs for the release of information, we must have a copy of the legal paperwork that shows the representative does indeed have a right to sign for release of PHI Must state that it is revocable to the extent that action has already be taken. 7
Step #2 Collect Content 1. Logistics of locating requested Patient content Paper Files Onsite Offsite box storage (may be outsourced to a box storage vendor) Microfilm Digital Images Onsite/Offsite Lab reports Onsite/Offsite EHR/EMR content Screen Prints Printed or Tiff/PDF Output 8
Step #3 Aggregate Content 1. Scanning Related to Paper and Microfilm Files Requires a duplex scanner Tiff or PDF output capabilities 2. EMR & EHR Content Must have authorized access Can discreet content be located with query tools Is a screen scrape required? What format is screen scrape output in (paper or digital) Must certain content be redacted? 3. Content Aggregation Can all content from all locations be stored in a common format? Paper Digital Can all content be formatted for edelivery? 9
Step #4 Package & Deliver 1. Packaging Paper Digital (Tiff or PDF) CD (Imaging content) Hybrid combination of above 2. Delivery - no activity tracking - not compliant Mail - must have a signed receipt for proof of delivery Fax - requires digital fax on requestors side for receipt acknowledgement edelivery (email) - must meet exacting rules to insure correct delivery acknowledgement Secure Web Portal - the most HIPAA compliant delivery option 10
Step #5 Create Invoice 1. Most ROI fulfillment must be paid for prior to delivery Is ROI invoicing tied directly to the institutional accounting system? Is there an ROI centric accounts receivable tracking capability in place? Can the requestor view outstanding invoices online? Are the correct ROI fee structures used and understood? Where is ROI invoicing facilitated? Online from accounting system Separate stand alone package By hand Using an ROI software package 2. Is there an ROI cost center reporting capability in place? Number of ROI requests by category (Insurance, Legal, Disability, Provider ) Revenue breakout by requestor Revenue breakout by patient Revenue breakout by fee structure type Revenue breakout by date ROI cost center reports FTE direct overhead Fulfillment timeframe metrics Trapped AR billable analytics 11
Step #6 Send Fulfillment Notice 1. What is a Fulfillment notification? Confirms the request has been processed States the responsibility of the Requestor (compliance obligations) Informs the Requestor of the payment amount due Provides instructions for logging into the ROI-Plus web portal ROI+ logon URL address Requestor account number and PIN number combination for access registration process How to view and pay for processed requests Establishes legal protection for the Provider 12
Step #7 Collect ROI Fees 1. Result of maintaining a detailed AR open ROI invoice system Invoicing without a strong collection process is unproductive Key to managing real revenue recognition ROI-Plus provides the only ROI online bill presentment/payment feature Provide flexible payment options Check ACH Credit Card Pay on monthly statement (Insurance companies). 13
Step #8 Authenticate Receipt of Content 1. Receipt verification is critical to meeting compliance standards Who received the ROI fulfillment content Time and date they received the content 2. Tied to forms of ROI content delivery format Mail, Fax, and CD do not meet authentication requirements No EMR/EHR systems has a receipt authentication feature ROI+ web portal registration feature provides the only authentication capability 14
Step #9 Track ROI Content Activity 1. The only way to meet full HIPAA compliance!! ROI-Plus is the only system on the market with full ROI activity logging Transfers proof of delivery to the Requestor side Keeps a log of all access and viewing activity on Requestor side in perpetuity Enables Requestor to monitor activity of its staff to enforce compliance on their side Provider controls and sets all access and content privileges Establishes proof of fulfillment and payment timeframes 15