Northwestern Human Services and Magellan Behavioral Health of

NHS Human Services and Magellan Behavioral Health of
Pennsylvania present:
Anti-Cloning Campaign:
One Individual at a Time
RCPA Conference
October 6, 2015
Presented By:
Magellan
Karli Schilling, MA, Compliance Auditor
Patty Marth, Compliance Auditor
NHS Human Services
Debra Luther, Ph.D., CCE, Senior Director
John Ciavardone, CCE, Senior Vice President
Learning Objectives
PART I (Magellan)
• Review the purposes of documentation
• Review Regulatory references
• Review the definition and history of Electronic Health Records
• Discuss the pros and cons of Electronic Health Records
PART II (NHS)
• Implementation of an Electronic Health Record
• Identify and discuss barriers and solutions
• Identify and discuss staff training
• Identify and discuss auditing practices
• Identify and discuss policies & procedures agencies can implement to protect against
cloning
• Discuss the use of algorithms
Learning Objectives
PART III (Magellan)
• Learn about the Managed Care Organization’s role
• Discuss the nuances of auditing Electronic Medical Records
• Review Audit Trends and Risk/ Consequences
• Recommendations for Program Compliance
PART IV (NHS & Magellan)
• Open Discussion
o
o
o
Barriers and Challenges
Other Best Practices related to Compliance and EMR
Lessons Learned
Part I:
Auditing Electronic
Medical Records
The Managed Care Organization’s Perspective
Purposes of Documentation
 Legal record
 Continuity of Care
 Plan the course of treatment
 Monitor healthcare over time
Quality Assurance
 Research and education
 Ensures compliance with regulatory requirements
 Supports claims
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Important Regulatory References
 Chapter 55 PA Code § 1101.51
 Medical Assistance Bulletins and Policy Clarifications
 MCO specific guidelines and requirements
 42 CFR Part 455: Program Integrity Requirements for
Medicaid
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Electronic Health Records (EHR)
An electronic health record (EHR), or
electronic medical record (EMR), refers
to the systematized collection of
electronically-stored health information,
in a digital format, about an individual
patient or a population.
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History Lesson
 Electronic Health Records (EHR) first appeared in the 1960’s
 Same goals as today
 Emergence of Ambulatory Care
 IOM Report “To Err is Human: Building a Safer Health System”
 2009 passage of Health Information Technology for Economic
and Clinical Health Act (HITECH)
 Incentive Program
 2013 Statistics:
o 941 manufacturers
o 1,700 unique products
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Electronic Health Records (EHR)
EHRs replace traditional paper medical records
with computerized recordkeeping to document
and store patient health information.
EHRs may include patient demographics, progress
notes, medication logs, medical history, and clinical
test results from any health care encounter.
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PROs and CONs of EHR
Advantages
 Quality of Care
 Legibility
 Efficiency
 Accuracy
 Standardization
 More Timely Information
 Reduced Loss of Paperwork
 Research
 Continuously Updated
 Other Capabilities
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Disadvantages
 Quality of Care
 Cost
 Privacy Issues
 Workflow changes
 Temporary loss of productivity
 Other Technological Issues
 Software quality and usability
deficiencies
 Cut-and-paste/ cloning techniques
Quality of Care Debate
Do EHR‘s augment or diminish
Quality of Care?
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Part II: NHS’s Anti-Cloning
Campaign
EHR Implementation
Barriers:
•
•
•
Multiple States and Payers
Large Volume of staff
Connectivity
Solutions:
•
•
•
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Document modification
Tiered roll out
IT Support – Site based assessments
Clinical Documentation and
Technology – The Downside
The NHS Anti-Cloning Campaign
Multifaceted Approach
• Etiology - identification of risk
• Training
• Policy & Print Media
• EHR modifications
• Audits & Algorithms
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The NHS Anti-Cloning Campaign
Risk Identification
• QI Audit Process
• Investigation process to identify scope
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It’s all in how you look at things…
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19
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The NHS Anti-Cloning Campaign
Training
• Anti-Cloning 101
• Anti-Cloning 102
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Anti-Cloning Policy and Print Media
• Defining the issue
• Concretizing consequences
• Print Media
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Observations
• Mood
•
•
•
•
•
•
•
•
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Communication: Verbal/Non-Verbal
Insight
Interactions
Affect
Appearance: Physical, Hygiene, Dress
Mental Status Exam
Engagement
Strengths
Exercise:
Describe what
you see
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EHR Modifications
• Anti-Cloning Acknowledgement
• Disabled ‘Cut and Paste’ Functionality (Jquery)
• Limited use of ‘Pull Forward’ functionality
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Audits & Algorithms
Audit Process Enhancements
• Side by Side comparison of notes across days and within days
of service
• Review of several weeks/months of notes simultaneously
• Group Services Audits
Algorithm Development
• Working towards a program to review strings of texts for
duplicate content
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Impact of Anti-Cloning Campaign - EHR
1
100.00%
Percent Charts Without Duplicate Content
0.9
0.8
95.88%
91.13%
100.00%
97.00%
100.00%
100.00%
100.00%
93.75%
92.75%
83.00%
83.25%
0.7
0.6
0.5
Variance due to auditor
0.4
0.3
0.2
0.1
0
Oct '12 Nov '12 Dec '12 Jan '13 Feb '13 March April '13 May '13 June '13 July '13 Aug '13 Sept '13
'13
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Percent of Charts Without Duplicate Content
Impact of Anti-Cloning Campaign- Paper Based
Documents
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100%
96%
90%
84%
80%
95%
96%
92%
92%
83%
70%
60%
50%
40%
30%
20%
10%
0%
66%
63%
52%
47%
41%
Variance due to auditor
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Part III:
Auditing Electronic
Medical Records
The Managed Care Organization’s Perspective
Managed Care Organization
Oversight/ Auditing
•
Why do we Audit?
i.
To ensure a consistent approach to treatment
between providers, Magellan and our County partners
ii. Proactive Patient Safety activity
iii. To measure adherence to standards set by CMS,
Pennsylvania DHS and Magellan’s national and local
teams
• How do we Audit?
i.
On-site Review
ii. Treatment Record Reviews
iii. Integrated Audits
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Auditing
The Differences between Paper Files and EHR
Clues identified when
reviewing paper files
Differences in
Handwriting
Missing Signatures
Altered Documentation
Changes in Date of Service
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Clues identified when
reviewing EHRs
Copy and Paste
Electronic Signatures
Over-Documentation
No proof of authorship
Audit Trends- EHR Records
 Cut-and-Paste/ Cloning
 Signatures Stamps pre-date end time of the session
 Signature Stamps conflict with another session or activity
 Empty Data Fields
 Missing Notes
 Pre-populated Code Definitions that don’t correlate to
provider’s contract or applicable regulations
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Implications for Providers using EHR
User Guide
Usage Policies
EHR Vendor
Training
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Audit Logs
Risk/ Consequences
 Increased Exposure
 Corrective Action
 Identified Overpayment/ Retractions
 Extrapolation
 Referrals to Oversight Agencies- BPI, OMHSAS, etc.
 Referrals to Law Enforcement
 Exclusion from future participation in federal health
care programs (Medicaid, Medicare)
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Recommendations for
Monitoring Program Compliance
1.
2.
3.
4.
5.
6.
7.
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Accessibility to the Requirements
Documentation of the Requirements
Policies and Procedures
Tools to monitor Compliance
Audit Plan
Measurements of Effectiveness
Mechanisms to Correct and Report Non-Compliance
Part IV:
Open Discussion
Key Points/ Takeaways
Provider’s Presentation
MCO’s Presentation
• Don’t over-customize your EHR
• Ensure timely roll out
• ID risks prior to roll out and train
staff to avoid them
• Give staff the tools to be successful
• Harness the capacity of your EHR to
capture risks
• Know and understand the regulations
and other requirements for
documentation
• Recognize both the strengths and
limitations of implementing an EHR
• Acknowledge and address how your
EHR system may affect Quality of Care
• Impact of EHR on Compliance
• EHR Essential items
• Know the risks and operate an effective
Compliance Program
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THANK YOU!