Creating and conducting an organizationwide risk analysis: Part 2
Editor's note: This is part two of a series about implementing an organizationwide risk analysis. See the May 2016 issue of BOH for part one.
Performing a regular organizationwide risk analysis is a basic HIPAA requirement and also simply good business practice. Beyond checking off an item on the HIPAA compliance list, a risk analysis will help an organization identify and rank security weaknesses, efficiently use resources to address them, and ultimately protect the security and integrity of an organization's data, including PHI, financial, and business operations information. Yet in a world of competing demands and limited resources, a risk analysis may be put off until it's too late. Even if one is completed, security officers may encounter obstacles when trying to act on the results of the risk analysis.
The purpose of a risk analysis is to develop a strategic plan of action that addresses and corrects vulnerabilities, and shouldn't be used to simply create a report on the current state of security, says Kate Borten, CISSP, CISM, HCISPP, founder of The Marblehead Group in Marblehead, Massachusetts. "Only when an organization performs periodic and as-needed risk assessments, and then mitigates significant risks, can the ISO [information security officer] and leadership have the confidence that their security program is functioning and adequate," she says.
A risk analysis is one of several activities that is part of a risk management program, says Rick Ensenbach, CISSP-ISSMP, CISA, CISM, CCSFP, manager of risk advisory and forensic services at Wipfli, LLP, in Eau Claire, Wisconsin. The risk management program is about managing risks to the organization (i.e., business mission, image, reputation, and patient safety and privacy), organizational assets, and workforce. An organization can't mitigate risks it isn't aware of and doesn't understand.
Risks are first identified, then analyzed and evaluated based on what action is needed, Ensenbach says. They also must be monitored on an ongoing basis, a vital step that if missed can undermine an otherwise solid risk management program.
When compared to data from past surveys, HCPro's 2016 HIM director and manager salary survey revealed a harsh truth that many HIM professionals already know: There has been little movement in HIM manager and director salaries over the years.
The FY 2017 IPPS proposed rule released April 27 is replete with modifications and expansions to claims-based quality and cost outcome measures. Although many of these proposed changes are for future fiscal years, ICD-10 codes reported for current discharges will impact the future financial performance for our organizations.
Cost measures
Two new payment measures are proposed as additions to the efficiency and cost reduction domain beginning in FY 2021:
Hospital Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care for Acute Myocardial Infarction
Hospital Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care for Heart Failure
The risk adjustment methodologies used for these measures are similar to those used for risk-adjusted mortality. The payment measure is intended to be paired with the 30-day mortality measures, thereby directly linking payment to quality by the alignment of comparable populations and risk adjustment methodologies to facilitate the assessment of efficiency and value of care.
The baseline period for these measures is July 1, 2012, through June 30, 2015. The performance period for these measures is July 1, 2017, through June 30, 2019. Performance for these new measures will be scored using the methodology used for the Medicare Spending Per Beneficiary measure.
CMS expands on its interest to further integrate quality and cost measures to reflect value, and is seeking public input on potential approaches. Underlying present challenges in reflecting value are noted as follows:
Currently, the HVBP assesses quality and efficiency separately through distinct performance measures in different domains, which as of FY 2018 are equally weighted to create the overall Total Performance Score. The four domains include:
Safety
Efficiency and cost reduction
Clinical care
Personal and community engagement
The current scoring approach can permit a hospital to earn a higher payment adjustment relative to other hospitals by performing well on quality-related domains without performing well in the efficiency and cost reduction domain, or vice versa.
Without a measure or score for value that reflects both quality and costs, the ability to assess value is limited.
My HIM career began like many others?in frank conversation with a high school guidance counselor regarding career direction. I wanted to pursue a career in healthcare, but wasn't interested in direct patient care. Focused exploration led me to discover a degree in health information technology at my local college. Now, 30 years later, I'm celebrating a long and successful HIM career.
This column is devoted to restraint and seclusion documentation; it provides support for, and a tool for, 100% review of patients in restraints and/or seclusion.
The Joint Commission and CMS have a common goal of reducing the use of restraints and seclusion in hospitals. Hospitals have come a long way in meeting this goal, and requirements for improvement (RFI) usually are received because of poor documentation in the medical record. Generally, recommendations result from lack of physician orders, physicians not seeing patients on-site, incomplete orders as to the reason for restraints and/or seclusion, and care plans not including the goal to remove patients from restraints and/or seclusion.
Often during surveys, there will be no patients in restraints or seclusion and the surveyors will ask for closed records to review. Once the medical record is closed, little can be done to correct documentation. Therefore, a solid open record review is essential to avoid recommendations.
A process for reviews
Review of open records of patients in restraints and/or seclusion can be performed in several ways. Of utmost importance is the development of a method to identify patients in restraints and seclusion on a daily basis, and to review new and recurring patients until they are discharged. For example:
1.Nurses, clinical documentation specialists, and tracer teams (plus others?) can review medical records each day to ensure documentation compliance
2.If the hospital has an EMR, HIM staff can review open records online to identify discrepancies in documentation and report back to each unit
3.HIM and IT staff can collaborate to develop a method of importing information directly from the EMR to identify documentation errors
Any of these methods should eliminate errors as long as they are corrected as soon as possible before patients are discharged.
Certain phrases just stick with you. The longer you reflect on an idea, the more inspired you are by the ways in which the concept can become relevant to your needs.
