I'm going to go off and talk a bit on Data Quality Teams and Compliance. I think there is a constant struggle about who owns the data and who is responsible for it. Data Quality teams began to get some attention a few years ago in the US and you are starting to see the trend in the EU. Typically the Data Quality team resided under the IT or operations wing and it was put in place to review data going in and out of systems for completeness and accuracy. It was basically a check to what the day to day operations folks were doing and to catch issues. I'm going to suggest leveraging these teams if they exist to do compliance reviews. Who owns the DQT is always a good question. Being part of IT doesn't really give it independence and I really don't think a compliance team would have a budget for them. Being part of operations makes sense but there is usually a struggle about cost and value they bring to a organization. Smaller companies I really don't see being able to do this. However with EMR,EHR,Billing and PHA data all going into multiple systems you really need some sort of audit process in place. Also you need to think about HIE's and making sure the data gets and audit before it gets into those systems. Unique ID trackers are going to be required... So is your head spinning? Not only are you going to need legal, clinical and regulatory experience on your team but now also IT? I see alot of blended roles here and that leads to confusion on independence and oversight. Is your data analysis on loan to you from IT really trying to make sure IT or Compliance is happy? Who pays the salary and does the review? It's all questions you need to ask.
Friday, September 13, 2013
Wednesday, September 11, 2013
Compliance and Data - The Emerging Alliance
Compliance and Data - The Emerging Alliance
Last year I mentioned a few times the importance of having compliance involved in data collection and analysis. At the HCCA regional conference in Boston this month this came up as a topic several times. In order to provide evidence of compliance for various state and federal programs you need to provide data evidence. How would a compliance officer be able to verify with impartiality that the information is correct? The term data quality compliance analyst came up and I think its worth looking at. Most compliance folks have a clinical or legal background(my background is technical so I must be the extreme minority) and a database is a complete mystery to them. Frankly I would look at anything IT gives you with extreme prejudice. IT doesn't look at things from a compliance standpoint and usually regards most regulatory concerns as a burden and not a requirement. Most Health IT organizations have Data Analysts and these skills do bleed over a bit. However they report to IT and this may be a conflict of interest. You are starting to see the establishment of Data Quality Teams and Data Governance. I would highly suggest talking about establishing these teams or getting involved with them. You need to talk to your CIO on this. You will be surprised he probably knows more than you think about this. IT information security it usually part of the CIO's office and they are getting hit constantly with HIPAA regulations. Talking data compliance and review may spark some serious cross organizational discussions.
Last year I mentioned a few times the importance of having compliance involved in data collection and analysis. At the HCCA regional conference in Boston this month this came up as a topic several times. In order to provide evidence of compliance for various state and federal programs you need to provide data evidence. How would a compliance officer be able to verify with impartiality that the information is correct? The term data quality compliance analyst came up and I think its worth looking at. Most compliance folks have a clinical or legal background(my background is technical so I must be the extreme minority) and a database is a complete mystery to them. Frankly I would look at anything IT gives you with extreme prejudice. IT doesn't look at things from a compliance standpoint and usually regards most regulatory concerns as a burden and not a requirement. Most Health IT organizations have Data Analysts and these skills do bleed over a bit. However they report to IT and this may be a conflict of interest. You are starting to see the establishment of Data Quality Teams and Data Governance. I would highly suggest talking about establishing these teams or getting involved with them. You need to talk to your CIO on this. You will be surprised he probably knows more than you think about this. IT information security it usually part of the CIO's office and they are getting hit constantly with HIPAA regulations. Talking data compliance and review may spark some serious cross organizational discussions.
Monday, September 9, 2013
The demise of Performance Reporting with the NCQA Disease Management Accreditation
Well with life some things just fade away. With NCQA's announcement that that it will not be continuing with DM Performance measures in 2014 that will end the certification for the few companies that achieved this. Well what happen? This program seem to have so much promise and then NCQA began to back off with making DM organization from making it mandatory to not required. It was being cited that it was too hard for companies to implement. However as the changes to supplemental went into effect it became quite clear that these two were related. If member supplied data wasn't valid for HEDIS then it didn't make sense for DM companies to keep collecting because it wasn't considered reliable. It's too bad because I don't think any time was spent studying if companies tracking DM measures had better results for their matching HEDIS measures. Once 2015 hits the last DM performance certification will fade into the sunset.
Thursday, September 5, 2013
Medicaid Programs and Compliance - Random thoughts
Medicaid Programs and Compliance - Random thoughts
I've had a few things come across my lap in the past months and read a few articles on some trends. With the ACA I think it is safe to assume that these populations will grow substantially, this does not mean your job will get any easier. These populations are notorious for medical non-compliance for a variety of reasons(apathy, economic, education, age, disability). Organizations will find that traditional methods will not work with them as proven over the last 20+ years. Organizations will try to tap new methods of outreach to get these members to improve their health. I think you will see a host of new services that have been offered to the commercial populations being offered to medicaid as a way to incentive the members. This does come with some danger as these programs could be potentially abused and defrauded. Another area that will constant dangers is communications with the member. Mail just doesn't reach folks the way it used to. That leaves electronic forms, text, phone and email. All areas that are potential HIPAA concerns. Cell numbers and text address changes constantly as plans are dropped and phones retired. There will be a need for better phone look-up and verification. I can see bottom feeding lawyers targeting Health Plans over HIPAA with this. Email has it own problems unless it a free universal provider like Google and Yahoo as people change email fairly regularly. But remember email is that "secure" either. I hope the compliance officer gets cracking on that computer science degree...
I've had a few things come across my lap in the past months and read a few articles on some trends. With the ACA I think it is safe to assume that these populations will grow substantially, this does not mean your job will get any easier. These populations are notorious for medical non-compliance for a variety of reasons(apathy, economic, education, age, disability). Organizations will find that traditional methods will not work with them as proven over the last 20+ years. Organizations will try to tap new methods of outreach to get these members to improve their health. I think you will see a host of new services that have been offered to the commercial populations being offered to medicaid as a way to incentive the members. This does come with some danger as these programs could be potentially abused and defrauded. Another area that will constant dangers is communications with the member. Mail just doesn't reach folks the way it used to. That leaves electronic forms, text, phone and email. All areas that are potential HIPAA concerns. Cell numbers and text address changes constantly as plans are dropped and phones retired. There will be a need for better phone look-up and verification. I can see bottom feeding lawyers targeting Health Plans over HIPAA with this. Email has it own problems unless it a free universal provider like Google and Yahoo as people change email fairly regularly. But remember email is that "secure" either. I hope the compliance officer gets cracking on that computer science degree...
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