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Sometimes "good ideas"
bleed from a context where they make sense to other contexts where they don't.
The banking industry is struggling with the distinction between financial
information which is related to payments, does not contain PHI and is
specifically exempt from HIPAA and the remittance advice -- which explains
what the payment is for (medical information) and allows the provider to credit
their client's account -- which does contain PHI and is covered by HIPAA. There
are a number of possible solutions, but each of them has consequences. Depending
on the solution, plans and providers may have to have business associate
agreements with their banks or they may not. That's at least one place where the
distinction makes sense even if we don't yet know what to do about
it.
Hal
----
Hal
Amens
Lyon, Popanz & Forester
Designing and implementing projects that
solve management problems
Publisher of The HIPAA Implementation Newsletter
[EMAIL PROTECTED]
http://lpf.com
310-822-1243 -
Pacific Time fax 630-214-2268 cell
3109-02-0560
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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