Abstract

BackgroundA goal of effective electronic health record provider documentation platforms is to provide an efficient, concise, and comprehensive notation system that will effectively reflect the clinical course, including the diagnoses, treatments, and interventions.ObjectiveThe aim is to fully redesign and standardize the provider documentation process, seeking improvement in documentation based on ongoing All Patient Refined Diagnosis Related Group–based coding records, while maintaining noninferiority comparing provider satisfaction to our existing documentation process. We estimated the fiscal impact of improved documentation based on changes in expected hospital payments.MethodsEmploying a multidisciplinary collaborative approach, we created an integrated clinical platform that captures data entry from the obstetrical suite, delivery room, neonatal intensive care unit (NICU) nursing and respiratory therapy staff. It provided the sole source for hospital provider documentation in the form of a history and physical exam, daily progress notes, and discharge summary. Health maintenance information, follow-up appointments, and running contemporaneous updated hospital course information have selected shared entry and common viewing by the NICU team. The interventions were to (1) improve provider awareness of appropriate documentation through a provider education handout and follow-up group discussion and (2) fully redesign and standardize the provider documentation process building from the native Epic-based software. The measures were (1) hospital coding department review of all NICU admissions and 3M All Patient Refined Diagnosis Related Group–based calculations of severity of illness, risk of mortality, and case mix index scores; (2) balancing measure: provider time utilization case study and survey; and (3) average expected hospital payment based on acuity-based clinical logic algorithm and payer mix.ResultsWe compared preintervention (October 2015-October 2016) to postintervention (November 2016-May 2017) time periods and saw: (1) significant improvement in All Patient Refined Diagnosis Related Group–derived severity of illness, risk of mortality, and case mix index (monthly average severity of illness scores increased by 11.1%, P=.008; monthly average risk of mortality scores increased by 13.5%, P=.007; and monthly average case mix index scores increased by 7.7%, P=.009); (2) time study showed increased time to complete history and physical and progress notes and decreased time to complete discharge summary (history and physical exam: time allocation increased by 47%, P=.05; progress note: time allocation increased by 91%, P<.001; discharge summary: time allocation decreased by 41%, P=.03); (3) survey of all providers: overall there was positive provider perception of the new documentation process based on a survey of the provider group; (4) significantly increased hospital average expected payments: comparing the preintervention and postintervention study periods, there was a US $14,020 per month per patient increase in average expected payment for hospital charges (P<.001). There was no difference in payer mix during this time period.ConclusionsA problem-based NICU documentation electronic health record more effectively improves documentation without dissatisfaction by the participating providers and improves hospital estimations of All Patient Refined Diagnosis Related Group–based revenue.

Highlights

  • This interim final rule amends the sections within 45 CFR part 160 that relate to the authority of the Secretary of the Health and Human Services (HHS) to impose civil money penalties on entities that violate the HIPAA rules adopted under subtitle F of title II of HIPAA

  • SUMMARY: The Secretary of the Department of Health and Human Services (HHS) adopts this interim final rule to conform the enforcement regulations promulgated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to the effective statutory revisions made pursuant to the Health Information Technology for Economic and Clinical Health Act, which was enacted as part of the American Recovery and Reinvestment Act of 2009 (ARRA)

  • This interim final rule amends HIPAA’s enforcement regulations, as they relate to the imposition of civil money penalties, to incorporate the HITECH Act’s categories of violations, tiered ranges of civil money penalty amounts, and revised limitations on the Secretary’s authority to impose civil money penalties for established violations of HIPAA’s Administrative Simplification rules (HIPAA rules)

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Summary

45 CFR Part 160

SUMMARY: The Secretary of the Department of Health and Human Services (HHS) adopts this interim final rule to conform the enforcement regulations promulgated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to the effective statutory revisions made pursuant to the Health Information Technology for Economic and Clinical Health Act (the HITECH Act), which was enacted as part of the American Recovery and Reinvestment Act of 2009 (ARRA) This interim final rule amends HIPAA’s enforcement regulations, as they relate to the imposition of civil money penalties, to incorporate the HITECH Act’s categories of violations, tiered ranges of civil money penalty amounts, and revised limitations on the Secretary’s authority to impose civil money penalties for established violations of HIPAA’s Administrative Simplification rules (HIPAA rules).

Instructions for Submission of Public Comments
Inspection of Public Comments
Background
Statutory Background
Regulatory Background
Approach to the Interim Final Rule
Provisions in the Interim Final Rule
Subpart D—Imposition of Civil Money Penalties
Request for Comments
Paperwork Reduction Act
Executive Order 12866
Other Analyses
47 CFR Part 73
Full Text
Published version (Free)

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