Ronald Hirsch, MD, FACP, CHCQM, CHRI, vice president of the Regulations and Education Group at R1 Physician Advisory Services in Chicago shares several options.
A version of this article was first published November 25, 2020, by HCPro's Revenue Cycle Advisor, a sibling publication to HealthLeaders.
Q: The 2021 Inpatient Prospective Payment System (IPPS) final rule requires providers to transmit all records to Quality Improvement Organizations (QIO) electronically. How can organizations make sure that they are in compliance if they’re not already?
A: First, ensure that paper records—including items that are commonly on paper such as the Important Message from Medicare (IM), the Detailed Notice of Discharge (DND), and other non-coverage notices—are entered into the electronic medical record (EMR) so that they are available upon request.
Your facility must enter these documents into the EMR before the record is sent to the QIO, says Ronald Hirsch, MD, FACP, CHCQM, CHRI, vice president of the Regulations and Education Group at R1 Physician Advisory Services in Chicago. Before this change went into place, this process occurred after discharge at many organizations. So, organizations need to rework this process and retain quality controls, even if the requests come in from the QIO outside of normal business hours.
The next hurdle is figuring out exactly what form the medical record should take when it is transmitted. For example, will it be sent as a PDF? Organizations also need to know where those files will be stored and how they will be secured and accessed, says Hirsch.
When it comes to sending the file to the QIO, organizations have several options:
- Use their already-established system for electronic submission of medical documentation.
- Transmit records directly from their EMR using secure messaging. This might require establishing a HIPAA-compliant DirectTrust network pathway between the EMR and the QIO.
- Use the QIO’s website portal to directly upload the records.
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