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Noel,
I don't know of anything that requires financial and medical
info to be separated (or merged). I believe that the regs are silent on
this issue. Both types of information are PHI. They would both
be part of the Designated Record Set for the practice.
If the records are electronic rather than paper, then
role-based access controls should be able to limit who has access to what.
You probably don't have that option with paper records, and keeping multiple
paper folders regarding the same patient sounds like an invitation to chaos to
me.
As Ted commented, the same document (such as a copy of the
insurance card) may be necessary for both Treatment purposes such as
pre-authorization, and Financial purposes (such as getting paid). Also
consider that getting the proper Diagnosis Code on a claim is a necessary
merging of the two types of information.
IMHO, not only is the separtion not mandated, it is also next
to impossible. If workflow separates them, it will probably require
duplication of the information in both places.
The opinions expressed here are my own and not necessarily the opinion of
LCMH.
Douglas M. Webb Computer System Engineer Little Company of Mary
Hospital & Health Care Centers [EMAIL PROTECTED]
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----- Original Message -----
Sent: Monday, March 24, 2003 08:48
PM
Subject: Separating financial and
clinical data
I had someone ask me a question the other day that I hadn't
heard before and
it got me curious as to whether other people had
confronted this issue and
what their outcome was.
This person said
they were told by someone that HIPAA requires that providers
keep
patient's medical records separate from their financial records. Most
providers I deal with have the bulk of their financial data in whatever
software package they are using to file their claims. The clinical
notes are
kept in paper charts, however quite often they keep a copy of
the patient's
insurance card in the chart and that specifically was the
"financial record"
that they were concerned about being in the same place
as the "medical
record".
My immediate reaction was that there is no
specific requirement to do this in
the Privacy rule but I then started to
think about what could possibly be the
basis of such a statement?
The only thing I could come up with was the
requirements under the minimum
necessary standard to identify who need access
to what types of PHI, and
to then make reasonable efforts to limit access
accordingly. Upon
further thought I can see how someone might take the
position that a
persons's insurance card or other insurance information
should not be
necessary for the clinical staff to treat the patient.
Similarly,
the front office and billing personnel do not need any more
clinical data
than what appears on the superbill so they should not have
access to the
entire chart. Perhaps this is where the conclusion that
insurance
information cannot be kept in patient charts comes from? Has
anyone
else heard this opinion or possibly come to the same conclusion on
their
own?
In small office settings, quite often I have clients that are
taking the
position that everyone in the office needs access to everything
because of
the degree of job sharing and multi-tasking that goes on.
However (playing
devil's advocate for a moment) just because you might
need access to a piece
of PHI when you are asked to cover a job for a sick
co-worker, does that
justify you always having access to that PHI
including when you are
performing tasks that do not require that piece of
PHI? I have not
encountered one physician's office that uses paper
charts where the chart
does not start out in the hands of the people at
the check-in window. Do
they really need access to the complete
chart (medical history, docotor's
notes, lab results, etc.) to check in a
patient?
The more I think about it the more I can understand how
someone might arrive
at this position but talk about an impediment to work
flow! Do we now need
one set of charts for financial data that is
not in software systems (e.g.
copies of insurance cards) and a separate
set of charts for clinical data?
Someone please show me a convincing
out!
Noel Chang
Noel Chang
Integral Practice
Solutions
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Open WebMail Project (http://openwebmail.org)
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