How to prepare your HIM resources for an unpredictable future
For the best health information management solution, think outside the box and forget the traditional mentality of coding process and strategy.
The health information management universe has changed. Traditionally, patient volume was predictable and rarely fluctuated, making it easy to design a patient coding team to manage the chart flow. Coding updates were annual and manageable. However, 2020 brought COVID-19, which suddenly caused massive challenges and changes to the revenue cycle.
- Reductions in outpatient encounters caused formidable challenges for managing the patient coding staff during unpredictable patient volumes and service needs.
- Health information management staff that had always worked onsite had to be set up to work from home.
- Best practices that had been in place for years were no longer suitable.
- Rapidly increasing telemedicine encounters created new problems in documentation, coding, billing and denials.
- Many telehealth COVID-19 patient encounters and tests had no existing codes.
- Frequent updates on coding guidance from CMS and AMA had to be adopted and incorporated into the patient coding process. This resulted in accuracy and training issues.
What we learned
Many agree that it took a pandemic to prove the American healthcare system was overdue in updating how and where patient needs are addressed. The same holds true for healthcare revenue cycle departments. Faced with new challenges and obstacles to capturing, documenting and coding accurate data, HIM professionals broke down cross-departmental silos, reinvented workflow processes, forced IT upgrades and realigned staffing priorities.
We now understand that a proactive approach for strategic planning, organizational structure and technical capabilities is critical to address sudden changes. We also learned the value of open communication, collaboration and cross-functional teamwork.
How to prepare
No one knows what the future holds or what the next evolution in healthcare will be. We do know that significant areas of focus include social determinants of health (SDOH), ICD-11, value-based care, regulatory changes, technological advancements, reimbursement shifts, acquisitions, expanded use of telehealth and virtual patient care. How can we ensure our revenue cycle team is better prepared in the event of another sudden disruption or challenge? We need to change our perspective through a critical review of traditional approaches to managing the workflow and staffing of a health information management department. To reach the best solution for your organization, think outside the box and cast away your traditional mentality of the patient coding process and strategy.
Build a cross-functional think tank
Although the revenue cycle is expected to run seamlessly, many departments have not operated as cooperatively as leaders would like. Responding to the multiple challenges of COVID-19 has helped to break down many barriers. Consider building a new multidisciplinary collaborative leadership model to identify upcoming events that could impact the revenue cycle. Assemble a team of stakeholders including HIM, IT, compliance, clinical, PFS and others. As the HIM-sponsored board of directors, this group should meet on a regular basis to discuss current issues and prepare for future challenges.
Create an online resource and training site
Training and education on patient coding changes and updates had always been done quarterly or annually. The pandemic led to weekly changes in coding guidance from CMS and the AMA. Accepted telemedicine codes went from 103 to 238 different codes. Providers were not trained on the information needed in the patient record to properly code telemedicine.
All health information management stakeholders involved in documenting the patient encounter, applying the appropriate codes and creating an accurate bill must be up to date on the latest patient coding guidance. Develop an easily accessible online site that houses all current coding rules, guidelines, updates, training modules and webinars. Send notifications to all appropriate staff when new updates and changes occur, and provide a link to the data. Build in monitoring capabilities to track and identify activity.
Ensure compliance of remote medical coding staff
The most significant change that COVID-19 has expedited is moving non-clinical staff to a remote work environment. Many job functions that health information management leaders were hesitant to transition offsite are now being performed successfully. In the rush to implement remote access to PHI, some HIPAA requirements may have been overlooked. To ensure HIPAA compliance and prevent a breach, healthcare providers should revisit HIPAA guidelines to make sure remote employees comply with all administrative, physical and technical safeguards:
Equipment and confidential information must be secured when the staff are not present. Store any printout being referred to in locked cabinets when not in active use by employee/contractor. Business telephone conversations involving confidential information must not be audible to others present in the home and must be done within a closed-door environment if PHI is referred to or discussed. Documents viewable on your screen cannot be accessible or viewable by others.
Do not share your account or your password with others. All activities associated with your assigned user account are your responsibility. Circumventing or otherwise bypassing existing security measures is forbidden.
The most thorough method of assuring compliance is to implement a new security risk assessment (SRA) focused on remote access protocols for employees working with PHI. The OIG guidance recommends that a new SRA be conducted whenever a significant change occurs in how PHI is viewed, transmitted or accessed. This will require a comprehensive, internal compliance review involving internal staff, third-party compliance contractors and all business associates. Why is such an extensive process worth the effort? After quality of patient care, PHI security is top priority.
Create a more flexible health information management staff
The pandemic brought huge, unexpected shifts in patient volume. After decades of fairly predictable volume by patient type, outpatient services were shut down and seldom-used telehealth visits skyrocketed. No one knew how long this would continue or if it would evolve to a different standard. Best practice is to create a nimble, flexible patient coding solution that can more easily handle sudden, drastic shifts in patient discharges.
- Evaluate your health information management team on each employee’s experience, capabilities and training. Use that analysis to determine cross-training opportunities for each individual. Your goal is to reach a level of cross-training that will allow for sudden increases or decreases in patient volume in each patient type.
- If your staffing strategy leaves gaps in the patient coding capabilities of your contingency plan, collaborate with a proven medical coding company that understands the potential volatility of future events and has the bandwidth and scalability to meet your needs.
- If your contingency staffing strategy leaves some coders without work in their specialty, create a list of potential non-coding initiatives for them to tackle. This could involve using their skills to address new training needs, augment CDI for new documentation initiatives or provide more medical coding audit support on targeted areas.
- If you still have concerns about the ability of some staff members to provide the flexibility you need, now is the time to strengthen your team. Today’s volatile healthcare environment requires all of us to be multi-skilled and adaptive, and your staff is no different.
The future is already here
The over-regulated HIM industry took a lightning-bolt step forward in 2020. Don’t expect it to go back to a slower pace. One of my favorite comments that I heard from a HIM director is, “In two months, we have had nine updates in telemedicine coding and ten updates in COVID-19 coding guidance. I have never seen the government move so fast.”
Regardless of upcoming challenges, we can learn from our recent experiences and ensure that our staff and workflow are up to date, collaborative and flexible. Here’s a guide to assessing and improving your patient coding strategy.