Providers and their vendors and subcontractors have only a few more weeks to comply before the Office for Civil Rights (OCR) begins enforcement of the Omnibus Rule, beginning Sept. 23, 2013. I have summarized the major areas of change below:
The Omnibus Rule expands the defnintion of business associate and holds the business associate to the same standards as the covered entity for HIPAA Compliance. The addition of business associates under the Omnibus rule could catch some companies and providers unaware and unprepared. Some business associates did not feel they needed to comply with HIPAA in the past, but now they do and the new law makes this very clear. The new law also specifically holds business associates and their subcontractors liable for compliance. Business Associate Agreements must be updated with specific new provisions and must be completed through the entire chain of trust.
The Rule eliminates the "significant risk of harm" as the threshold for breach notification. The new standard assumes the breach is reportable unless an extensive risk-assessment is done that determines there is LOW probability that the PHI has been compromised.
The Omnibus Rule imposes stricter limits on marketing and communications of PHI when money is involved. The new law specifically prohibits the sale of PHI untless the individual specifically authorizes it.
Enforcement has also been increased with civil monetary penalties up to $1.5 million of all violation of an identical HIPAA requirement in a year. The Rule also eliminates the shield covered entities had from civil penalties based on the conduct of their business associates when certain conditions were met. The Rule also requires HHS to investigate HIPAA violations that appear to involve willful neglect. Previously, HHS has discretion in making that decision.
Oh, and did I mention that HHS hired enforcement officers last spring and are performing more audits and investigations. In addition, in the last few weeks a civil case found that Walgreen's is liable for the breach of PHI based on one of their employees not following company policy and releasing information to a person that did not have a need to know.
If you have not already taken steps to comply with HIPAA--both the original and the new--do so NOW! The cost of compliance is WAY cheaper than the alternative!!
It seems that the CAQH CORE Operating rules are the best kept secret in the medical payer world. Many insurance companies and TPAs we talk to on a daily basis are not aware of these new rules. All HIPAA covered entities have to be compliant with these rules by1/01/2013to remain in compliance with HIPAA.
So, what are these new rules and what is the impact? Well, for some reason there isn’t a real easy way to get the requirements in straight forward English, but the basic gist is around ensuring eligibility/benefit (ANSI270/271) and claim status (ANSI276/277) information is easily accessible, quickly provided to requestors, and provide more information then what is currently provided electronically. These new rules are trying to make eligibility and claim status requests more useful for providers so they’ll begin using them more often as a best practice.
There are two ways to become compliant:
- Build a solution that satisfies all of these requirements (click blue underlined text).
- Make HDM do all the work and utilize our solution.
The below article is a reprint from the newest edition of the Nebraska Physical Therapy Association (NPTA) quarterly newsletter. We thought it might help other Qwik+FILE users are well. Enjoy!
Client no shows and cancellations are no fun. You don’t get to do the work you love. The patient doesn’t get the help they need. It can put the whole day off and it costs the business money.
The median salary for a Physical Therapist is around $75,000, which equates to around $36 per hour. If there are 10 no shows per week, that equates to $360 per week, $1,440 per month, and $17,280 per year. This is no small issue.
However, we are in a good position. There are those who have come before us that have had this same problem and have lived to tell about it. Below are the 5 steps that every Physical Therapist should take to decrease the odds of cancellations and no shows:
- The simple reminder. The simple reminder can take many forms, but it has to happen. The more tactics you use from the below list the better your results are going to be:
- Send a postcard a few weeks before the appointment. Better yet, have the client fill out their own postcard before they leave their current appointment with their address and appointment date and time. This tactic was shown to reduce missed appointments by 18%.
- Call the patient 3 days before the appointment. The North Carolina Surgery Center conducted a study that showed that nurses who call patients 3 days prior to a scheduled surgery decreased the cancellation rate by 53%.
- Email or text message the patient the day before and/or day of the appointment. This can be made pretty simple using new technology that is available. At appointmentsms.com, you could remind your client for less than $0.07. Not a bad return on investment.
- Session quality is high. Besides forgetting, one major reason for no shows is that the client wasn’t pleased with the last visit, and they didn’t want to cause any friction by discussing the situation. They just aren’t going to show up next time. Ensure you are probing and then listening to your client’s needs and wants. Then build a plan together to provide the best experience possible for them.
Make sure you and your peers are ready to go every day. Your practice shouldn't be over worked or under staffed. Patients will pick up on this. When they are rushed or don't get the treatment they need or deserve, they'll start canceling.
- Deal with the repeat offender. There are always situations that people can’t help and have to reschedule. That comes with the territory. However, a lot of cancellations and no shows come from the same individuals. This has to be dealt with differently. Everyone wants to be flexible for their clients, but sometimes being too accommodating isn’t helping anyone.
You need to ensure these individuals understand that this appointment is important to you and it’s important for them. Handling the all with, “Oh my, is everything okay?” to show empathy and that you were expecting to see them. “[Client Name], I know [PT Name] had this time reserved just for you. Is there anything we can do to help you keep the appointment?” Again, you are showing empathy, trying to help, but showing that this is important. Then finishing up with, “Well, we appreciate you calling to let us know. As you’re aware, [PT Name] schedules in advance and let’s see…their next appointment is [6-8 weeks out].” No matter what. Even if they’re available tomorrow.
That is hard for schedules to do, but it’s hopefully rare that you use this tactic and it helps the client learn that this is important and time has to be made for these appointments.
- Get them excited for their session. Your clients will get excited by the progress they are making and the further progress they will be making. You need to play off this excitement by engaging them even before the session.
Provide your clients with homework. This can take many forms. Have them watch some videos online showing what exercises you’ll be doing next or some testimonials on how an exercise helped someone else. If there aren’t any online videos, make some. All you need is a mobile phone and YouTube account.
Have them make a list of the 5 things they’re going to do once they have achieved their goals. Get them excited and they’ll show up. The homework assignment doesn’t really matter. It’s the engagement we are looking for. The more engagement, the fewer cancellations.
- Have a backup plan. No matter what you do, there are going to be some cancellations. That’s where you’ll need a plan B. That plan B is usually a list of patients that could fill the spot that just opened up. This list will have those patients you haven’t seen in a while, but should. It will also have those you’ve asked directly if they would like to be on this list and that you’ll call them for an appointment when a spot opens up.
No matter what you do, there are going to be cancellations, but by utilizing some best practices, you can reduce your no show and cancellation rate substantially. Most studies show that medical practices with the lowest cancellation rate implement a combination of the above strategies.
Now you know what the best practices are, and sometimes it’s hard to get the motivation to do what you know is right. So, don’t waste time. Get your staff together today and see which of the above tactics you’re going to be using today (or soon).
We at HDM just wanted to say HAPPY HOLIDAYS! We truly enjoy coming to work each day to partner with you in finding a better way.
Please enjoy the below video that some in the Qwik+FILE team put together to help put a smile on your face for the holiday season.
We're looking forward to a great partnership going into 2013!
We strive here at HDM Qwik+FILE to put our customers first. It's why we coined the phrase Provider Centric!™. We also come across other Customer Centric! companies and would like to share those stories with the world as well.
All of my kids love LEGOs (me too) so I was pleased to find out that LEGO is helping us fight the battle to put customers first. The video below was put together by a young boy's mother. The young boy, who suffers from Asperger's syndrome, had his heart set on a box of LEGOs and had saved all of his money for over two years to purchase it.
Unfortunately, the set was discontinued during that time and the boy was crushed. The boy sent a letter to LEGO and they sure did come through for him! Seeing the boy's reaction in the video sure does put a smile on my face and I hope it does for you too.
Dan Peetz is an HDM Qwik File customer as well as the owner and one of the Physical Therapists at Skyline Physical Therapy in Omaha, Nebraska. His practice has been growing well over the years. So, we wanted to pick his brain to know if there were any secrets to this growth that could be shared with the provider community at large. During our conversation we got that plus a whole lot more.
Here are just a few nuggets of wisdom that Dan was able to bestow upon us from his over 30 years of experience in the business:
- Get out into the community. Dan realized early on that you aren’t going to grow your business by just sitting in your office all day. Don’t get him wrong, he loves to practice and still sees many patients a day. However, he also goes to all of the different provider specialty meetings (OT, Chiro, Dentists, etc.) to learn from them and to also ensure they understand the value of physical therapy as well.Dan has tried to follow a very simple rule of thumb to ensure he doesn’t lose track of this wisdom in the hectic day to day tasks. His simple rule is to talk to one provider a day. Educate them about the physical therapy process and the value that is provided.This approach supplies Dan with 80% of his new clients.Where do your clients come from? Referring doctors? Referring clients? Whoever they may be, can you get in front of at least one of them each and every day to teach them something about what you do or a topic they might not know about in your specialty?
- Focus on the patient and their needs and wants. If you want the client to come back again and again, they have to be the reason you are there every day. Dan doesn’t try to nickel and dime his customers. Dan’s philosophy is to teach his clients so they are able to take care of themselves. There’s no need to have a client come in every week to do some simple exercises they could do at home.Patients appreciate this and have supplied Dan with 20% of his new clients through word of mouth.Do you truly know what your patient’s needs and wants are? If you do know, are you truly supplying the best experience possible? I believe we all know what we need to do here, but it’s just hard sometimes to actually do it. Dan is showing that this pays off.
- The best specialists are generalists. Dan understands that everything is connected. During our conversation he let me know, “I can make your jaw hurt by placing a rock in your shoe.” Thankfully he didn’t do that, but the point stuck with me. Our body is connected and to specialize in shoulders or hands or optometry, you’d better understand how the different parts of your body and brain can influence that part of the body.Being able to understand how a person’s body and brain impact his clients is just another way that Dan instills trust with his clients that keep them coming back again and again.
Dan has grown his practice well over the years. He hasn’t done it with marketing gimmicks or setting up one time transactional relationships with his clients. Dan’s practice has grown due to his focus on educating the community and instilling trust with everyone he works with. I hope you can take something away from his words of wisdom. I now I sure did.
This world moves fast. Everyone is so busy and they have to be the most productive and efficient person they can be just to keep up. We are living our lives at breakneck speeds.
I'm always reminded of this more often during the holidays. In the world of being married, having divorced parents, and trying to be a good son, you have multiple holiday festivities you have to make it to on the same day.
How it usually goes is you arrive, you stuff yourself for 40 minutes, listen to everyone's 3 minute elevator pitch on the current happenings in their life, round up the kids, get them all bundled up, and then head to the next destination where you'll do it all over again. You'll do this exact same routine 4 times in one day. The holidays are a whirlwind for me and a constant reminder that it's a busy world full of busy people
In this world it seems reasonable that companies can best help their customers by providing the fastest service possible. Companies also like this focus on speed because it's easily measurable and you can point to something concrete and manageable. Most companies follow this path. Kaiser Permanente rewarded call center service representatives with a bonus based in part on their ability to spend an average of less than 3 minutes, 45 seconds on the phone with a patient.
At HDM we strive every day to find a better way. To do that sometimes it helps to take a closely held belief, turn it on its head, and see what happens. Is faster really better for the customer? From our experience, we would argue "no". If you're looking to build a long lasting partnership with your clients and not just a one time transaction, you must slow down.
There is a reason Qwik+File's average customer service call time is 20 minutes. Clients don't want to be rushed. They want their needs to be met, whether those needs involve a transaction, a request for information, a problem to be recognized and addressed, or just some plain, old-fashioned hand holding. Taking the necessary time to truly help your clients is well worth the time invested in each conversation. That's what has led to a first call resolution rate of near 80% when everyone else in the electronic medical insurance claim clearinghouse industry gets excited about hitting 50%.
This belief and approach isn't just good for our business though. We would argue it's very important for your practice as well. One of the points for your practice is to get your clients to come back to you again and again. One of the best ways to do that is to take the time to listen to what your client's needs and wants are and then delivering on those. You won't learn that important information if you're trying to hurry them out the door.
So, next time you feel like you're being rushed and there just isn't enough time in the day, take a deep breath, make some time to find out about your clients, and ask them about the one thing your practice could have done to make their visit even better. They'll appreciate the time you took with them, you'll have connected with your client, and your relationship and practice will be stronger for it.
Everyone in your industry and everyone in our industry provides some level of customer service. Those are the activities you do every day to meet the customer's basic expectations on the services provided. You and your staff answer the phone nicely, the paperwork is provided on a nice clip board with a pen to use, there is a television to occupy them while they're waiting. Everyone's customer service can then be ranked on a 10 point scale. Some will fall in the 8-10 range, some will fall in the 1-3 range and most will fall in the 4-7 range.
However, lots of companies in your industry and in our industry don't realize there is an entirely additional scale that sits directly on top of the Customer Service scale. It's called the Customer Centric scale. That one additional word makes all the difference. Customer Centric is different because it ensures the customer is the center of your world. They are the reason you exist. They aren't there for a one time interaction that is pleasant. They are there for a relationship built for years and decades to come. Customer Centric organizations are the lucky ones who realize there is this additional level of service that can be provided. They get the pleasure of building and experiencing a long-term relationship with their customers.
The Ritz Carlton is a great example of this Customer Centric behavior. Just one story is told this way:
“One family staying at the Ritz-Carlton, Bali, had carried specialized eggs and milk for their son who suffered from food allergies. Upon arrival, they saw that the eggs had broken and the milk had soured. The Ritz-Carlton manager and dining staff searched the town but could not find the appropriate items. But the executive chef at this particular resort remembered a store in Singapore that sold them. He contacted his mother-in-law, and asked that she buy the products and fly to Bali to deliver them, which she agreed to do.”.
Source: Great Customer Service Examples
I'm proud to say that I caught one of our Customer Centric service employees in an example this week as well. HDM's Qwik+File product submits insurance claims electronically for providers. Well, it's hard to do that without a working computer at your office. One of our customers called up and told her they didn't know how to setup their computer to begin submitting claims. So, she drove to their office, put their computer together for them, and ensured everything was up and running.
This is the future. This is how you will stand out from the crowd. To get started on this journey all you have to do is follow these 3 steps:
- List out all of the activities your customers do once they arrive at your location.
- List out all of the ways that activity could be enhanced in the customer's eyes.
- Make it happen.
You aren't trying to just meet the base customer expectations. You're trying to blow them away.
Since Qwik+File serves providers, we call our's Provider Centric!™ We are very happy we get to share this partnership and relationship with you.
Chief Operating Officer
OK, there is no doubt that the CORE Requirements set for implementation are another example of overreaching government regulation. But, what are YOU going to do about it? You can complain and drag your feet to try to protest (in your own small way) against BIG Government or you can embrace the change and find a way to improve your own processes with it.
For those of you ready to turn Oppression into Opportunity, listen up.
The new CORE Requirements require all HIPAA entities to provide ONLINE, REAL TIME eligiblity and claim status transactions. They also expand the detail provided in the eligibility transaction to include benefit information and some patient level accumulator information -- no small feat for some legacy system users!!! So, if you have to go to the trouble of providing this information to assist providers in their cashflow and collection process, what's in for YOU (the payer)?
How about this ----
Use your new tool to reduce the number of calls from providers requesting this information. From our customers, we hear that over 50% of the calls in their call centers are for eligibility, benefits information or claim status. So, once you have the tool --- educate the providers to use the tool instead of the phone. Not an easy task, but with 50% of your customer service costs at stake, clearly a task that may be worth it. Begin by routing provider calls to a message talking about the tool. Include information about the Tool with all your mail going to providers. When providers do call in and talk to a person, have the person reiterate how to use the tool, especially if the call could have been answered through the tool. EDI transactions in healthcare have been around now for more than 20 years and we still have too much paper and too many phone calls and hassles surrounding the process --- on both sides --- payers and providers.
No, it is not easy and it is not ideal, but why not turn Oppression into Opportunity and find a way to create benefits for all parties so this effort is not a another waste of time and money.
2011 was a BIG year for HIPAA -- the increased HIPAA fines & penalties from ARRA passed in February, 2009 finally got levied. Remember ARRA took what was a $25,000 fine and boosted it to $1.5 MILLION!!!
Three of the biggest HIPAA fines and penalties related to:
PHI left on public transportation
Employees snooping into medical records they had no reason to see
Health Plan employees not responding to patient and HHS requests for information.
In fact, over half the breaches reported that affect more than 500 people are related to theft or lost/stolen PHI. In many cases, the "root cause" of this is employees of the firm not following policy or just not paying attention (or both). I said it before and I will say it again, for health care to work, every one in the process must do the "right" thing for the "right" reason. Taking PHI home on your laptop is probably NOT the right thing and certainly leaving it on public transportation or in your trunk is not. Employees need to keep their awareness on the importance of protecting PHI whether it means keeping it safe when it is in your possession or not looking at it if it is not your business. Healthcare workers have long known about the confidentiality of the work that we do, so the idea of keeping PHI confidential is not a new concept. HIPAA raised the bar in setting expectations and, now, with the levying of these fines in 2011, the teeth to ensure that checks and balances are in place, at least in the area of privacy and security of the data.