Course Portfolio Project on a Written Proposal to Improve A

WRITTEN PROPOSAL1

Course Portfolio Project on a Written Proposal to Improve a

Hospitals Compliance Program

Frank Skwierc

Bryant & Stratton College

ENGL 250 Research and Writing II

Dr. Amy Sloan

February, 27, 2016

ABSTRACT

This portfolio project is designed to demonstrate to Dr. Sloan, the instructor of this course, that I understand the intricacies involved in producing a written proposal on a professionally written basis. My objective is to prove that I can properly address the research questions I submitted using informational literacy skills and to articulate my discoveries in an appropriate format. To accomplish this I will need to analyze, evaluate, and synthesize the research through various documentation by paraphrasing, summarizing, or directly quoting sources. Other requirements that Dr. Sloan asked us to provide in this portfolio project are, a properly written annotated bibliography, and properly cited resources both on a reference page and in text. The proposal itself should comprise of three or four pages directed at a boss or manager pointing out the importance in the research, trends, and individual ideas I wish to express, in an effort to propose changes I feel are necessary to improve the overall stability of the company.

INTRODUCTION

The topic I chose for my portfolio project is, “The Government’s New Electronic Health Record System and How it Creates Controversy with Hospitals and Physicians”. To guide my research I chose two topical questions, the first question is why does the government believe that it is a safe and secure way for hospitals and physicians to exchange information and to control or prevent fraud? The second question is, what are the compliance problems and financial concerns the hospital and physicians are complaining about? Utilizing this information the scenario for my proposal document will be, that I am the hospitals Compliance Officer proposing the needed changes to our compliance program that will fix the needs of the hospital, physicians, nurses and coders. The proposal will be addressed to the Chief Medical Director of the hospital. The subject line for my proposal document will be, “Changing Technology Creates Necessary Changes to Our Compliance Program”. The information I intend to provide in my proposal will be on the past and current problems facing hospitals and physicians adopting the new electronic health care records keeping system.

Mercy General Hospital

MEMORANDUM

To:Mr. Big Wig, Chief Medical Director

From:Frank Skwierc, Compliance Officer <>

Date:February, 29, 2016

Subject:Changing Technology Creates Necessary Changes to Our Compliance Program

Dear Mr. Big Wig, as you requested in the last board of directors meeting, I have gathered the information on the, effectiveness, quality, and safety of the Nations Electronic Health Records keeping system that we adopted back in 2009. My research will prove that the Adoption of this system has, and will in the future, greatly improve the service we offer to our patients and improve our billing and reimbursement. However, my research will also show some of the problems that have plagued our hospital during the implementation of this system. I will address these problems on, effectiveness, quality,and safety, on an individual basis, and propose some ideas the hospital can take to secure the hospitals financial stability, uphold the high standards of patient care, and to maintaincompliance under the law.

Back in 2009, one of the main concerns the hospital faced with adopting the nations electronic health records keeping system, was the cost of implementation, and the amount of time involved. This worked out to be a cost of $65 million over a three-year period. At the time of implementation there were no subsidies offered by the government, however, in 2013 we applied for the core subsidy program sponsored by the government. This required the hospital to perform a two-year study on the effectiveness of the EHR system we selected to put in use. We completed that study in 2015 and are now currently receiving a subsidy from the government for $6.1 million a year, which we are entitled to base on the size of our organization. We will receive this subsidy for the next six years. The subsidy will pay for over half of our initial costs.However, the fact still remains that it does cost us $1.2 million a year to operate and maintain the system, butit has increased our reimbursement of Medicare and Medicaid by $3 million a year. The problem we are having is with our third party reimbursement and private physicians that have not yet adopted the EHR system. This creates a problem that is threefold (Healthit.gov, 2016).

While the system we use is designed to eliminate the use of hardcopy records, and provide our physicians with the information they need about our patients in a more efficient and time-saving manner, this is not always the case. The problem lies in the fact that most of our local physicians and clinics, which see these patients, have not yet adopted the EHR system. This means that we still have to obtain hardcopy records, either by courier, or fax, to ensure that the vital information our physicians need to properly diagnose a patient is available to them. Doing this also increases the hospitals expenditure by having to maintain staff members to handle this process (Healthit.gov, 2016).

Research studies have shown, that this reluctance to adopt and EHR system by these private physicians and clinics has resulted in similar problems with other hospitals related to our size and the number of patients we see. As a result, once we receive these hardcopies, we still have to manually upload this information into our system so that is available to our physicians. During this time-consuming process, our patients are being denied the proper care they deserve. This also hampers our physician’s ability to see and treat the vast number of inpatients that are admitted to our hospital, because they lack the information needed to properly diagnose the patient. It also creates a problem for our nursing staff, because their time is tied up trying to retrieve medical history records, resulting in less time with patient care (Terry, 2013).

This problem also affects our billing department. While the ability to provide information about a patient’s health record electronically has been adopted by most of the larger insurance companies like, WellPoint, CIGNA, Aetna, Humana, United Healthcare and BlueCross BlueShield, it is the vast majority of the smaller insurance companies that bogged down our billing department. The EHR system has made it more efficient and with less errors to receive the proper reimbursement from the government and major insurance companies, by red flagging information they require for reimbursement before the claim is submitted. However,those smaller insurance companies that do not use the EHR still require a time-consuming paper exchange of records and information needed to process a claim before it can even be submitted (Terry, 2013). As you know, hospitals and physicians are required by law to submit claims in a timely manner, and those claims have to meet the requirements of medical necessity as part of compliance with the law. In the past, this lengthy exchange of information usually resulted in claims not being paid, or denied, simply because the information wasn’t supplied in a timely manner. There was a time, when the claims process was allowed to take up to 90 days and still remain in compliance. However, in 2014, the AHIMA along with the Office of the Inspector General, invoked new regulatory laws reducing that time for compliance to 45 days, in an effort to reduce the number of back-logged claims submitted to the government (AHIMA, 2016).

While these issues are of great concern to our billing department, the use of the EHR system has greatly improve the amount of money we receive for reimbursement. Research shows that other organizations equal in size to ours, also face similar problems with their reimbursement and billing. However, in two separate nationwide studiesperformed over the past decade by the AHIMA on the effectiveness of the EHR system, revealed that 80% of all hospitals, clinics, and physicians utilizing the EHR system have shown an increase of 40% in their overall reimbursement, and a decrease in rejections and denials of 7%. These studies also showed that those hospitals, clinics, and physicians that have not adopted the EHR system have suffered an increase in rejections and denials of 5% and a loss of 15% in overallreimbursement. The government still estimates that within 30% of the nation’s hospitals, 40% of all clinical organizations and 60% of all private physicians have not yet adopted the EHR system (AHIMA, 2016). Some of the top reasons given by these businesses for not voluntarily complying, is the cost of implementation, maintaining the system, hiring, training costs to operate the system, and the costs of maintaining security of the system, etc., etc. (Healthit.gov, 2016).

It should be clear to you by now that it is these external problems with physicians, organizations, and insurance companies, whom for whatever reason, decided not to implement an EHR program, which is causing the internal troubles with our system, and not the system itself. While researching these problems, I came across several organizations similar to ours that made the mistake of spending hundreds of thousands of dollars for consultation and upgrades to their system, only to have the same problems along with additional ones. However, I did find several hospitals that recognized this as an internal compliance problem that needed to be solved. I have found that every organization is different when finding solutions to their problems, however, their solutions may not necessarily work for us. But, I have come up with a fewsolutions that will utilize personnel that we already have and keep the cost of these changes down to a minimum (Healthit.gov, 2016) (Lim, 2015).

The first compliance change I recommend has to do with the records, physicians, and nurses obtaining the records they need without impeding the records department from uploading the information into the system. As you know, by law, all paper generated copies of a patient records must remain completelyintact at all times, and often, a physician is only concerned with one part of this complete record, and our nurses losing patient time being sent on an errand to retrieve the entire hardcopy record so that the physician can retrieve the data he needs (Hamid, 2013) (Terry, 2013). To remedy this problem, I propose we adjust hospital compliance to include a Liaison Officer in charge of records. The physicians can contact this Liaison Officer by phone requesting the data they need. The Officer can then assign an individual to locate and upload the appropriate information for the physician, so that it can be viewed on his laptop. This way the records department can continue loading the hardcopy record into our EHR system without interruption. It will also remove the need for members of our nursing staff to leave patients to seek out records that are often viewed for only a moment and then left on the department floor for hours before being returned to the records department (Healthit.gov, 2016).

To address the problems our billing department faces, and to ease pressure off the coding staff, I suggest that we change hospital compliance rules to split the billing department into two sub departments. The current department manager will select two individuals to act as department supervisors. One supervisor will be in charge of dealing with all billing and coding issues that relate to the new EHR system. The other supervisor will address billing and coding issues that involve third-party insurance carriers that are not equipped with the EHR system. Each team will work independent from the other. This way no single coder will have to deal with multiple issues involving the two types of billing practices. By allowing our coders to concentrate on a single billing process at a time, it will improve our reimbursement and ensure that proper compliance to the law is met, and within the government’s new regulatory standings (AHIMA, 2016) (Healthit.gov, 2016).

Finally I propose that the records and billing department, in conjunction with the hospitals IT department, do a comprehensive audit that identifies and isolates all the past and current clinics, physicians, and third party insurance carriers that are not using the EHR system. This information can then be incorporated into our EHR monitoring system to alert those departments. This will help the records department improve their response time for gathering information that the physicians and nurses will need for patients admitted to the hospital. It will also aide the billing and coding department in assigning the right team to handle billing process after discharge (Lim, 2015).

I propose these changes to our compliance program will not only to cut operating cost, butincrease the facilities reimbursement. These changes are also necessary to insure that our physicians and nursing staff do not fall out of compliance. Without these changes, a hospital review board may view our operation to be out of compliance, and accuse us of patient neglect due to our failure to remedy the problems concerning the retrieval of patient records. It is myduty as the hospital compliance officer to insure that the integrity of the health care facility is upheld by creating and enforcing a compliance program that all physicians, nurses, and administrative staff must follow,and is in compliance with all the state and federal laws that govern the operation of the health care facility. These compliance guidelines must also include protecting the health, safety, and financial wellbeing of any individual utilizing the services of the health care facility and the working members of the facility (AHIMA, 2016).

I want to thank you for giving me this opportunity to improve our organization. I cannot stress enough how necessary and important these changes to our compliance plan are. I implore you to make out and sign a directive giving me the authority to implement these changes before someone on our staff makes a critical error in judgement.

Copy:Mr. Big Wig, Chief Medical Director.

REFERENCES

Ahima.org,. (2016). AHIMA Home - American Health Information Management

Association.Retrieved 9 February 2016, from

I used this website to retrieve information on the current regulatory compliance lawsfor hospitals, physicians, and clinical facilities.

Adoption and Barriers to Adoption of Electronic Health Records by Nurses in Three

Governmental Hospitals in Eastern Province, Saudi Arabia. (2015). Perspectives in Health Information Management, 1-16 16p

This case study that was performed by AzzaEl.Mahalli, MD, PhD in the eastern provinceof Saudi Arabia. A paper questionnaire was distributed to the nursing staff of three of the largest government hospitals that were all utilizing the same EHR software. The questionnaire required the demographics of the nurses and how much computer training they had or were taught by the hospital. The questionnaire asked the nurses to put into their own words their experiences with chart review, decision support, and ease of entry of data necessary to complete a patient’s health record. This report was done in response to recognize and compare complaints that nurses have with the EHR software both in the United States and other countries around the world

Congdo Retrieved 9 February 2016, from

an-ehr-system-cost-you-0001 n, K. (2009). How Much Will An EHR System Cost You?Healthitoutcomes.com.

Ken Congdon, the editor for a popular magazine called,“Health IT outcomes,” wrote an article about the cost of implementing the EHR system. In this article he points out the enormous price differences involved with this system as it pertained to the size of the health care facility or physician’s office. This article helped me confirm the cost of what it would cost the average 500 bed hospital today to implement the EHR system. From the predicted cost back in 2009, to the predicted cost estimated in 2016, I was able to set an average for the hospital in my report.

Harney, J. (2009). CONVERSION TO ELECTRONIC HEALTH RECORDS AT A LARGE

MEDICAL PRACTICE. Infonomics, 23(6), 16-17.

This case study by John Haney discusses several different clinics that are utilizing the EHR reporting system. Each clinic that was investigated in this study showed increased reimbursement for services rendered, as well as, cutting laboratory and radiology work in half the time. This case study helped reinforce my opinion that the EHR system can not only pay for itself, but improve reimbursement and cut service times in half.

Hamid, F., & Cline, T. W. (2013). Providers' Acceptance Factors and their Perceived Barriers to

Electronic Health Record (EHR) Adoption. Online Journal Of Nursing Informatics,17(3), 1-11 11p.