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Department of Pathology

Medical Compliance Services Office of Billing Compliance

Coding, Billing & Documentation

2016

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Why Are We Here?

•To EDUCATE and PROTECT our providers and organization

•To provide you with every tool you need to maximize compliance and get paid what you deserve

•To update you on the latest CMS/OIG activities

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Pathology Diagnosis Coding

Definitive diagnosis should be assigned to the highest degree of specificity, whenever possibleIf the findings are inconclusive – code the Signs and Symptoms which

prompted the servicePreventive services – screenings – document screening nature of the

service

When choosing diagnosis codes for professional billing -

Diagnosis can not be assigned on basis of “rule out”,“possible” or “probable” history or findings

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Medical Necessity

Medical Necessity must be documented in the pathology report Physicians are expected to be familiar with reimbursement policies

When multiple services are rendered on the same day – diagnosis codes must be appropriately linked

FNA fine-needle aspiration

Bronchial brush

Final Dx or Signs and Symptoms (breast cyst)

Final Dx or Signs and Symptoms (Asthma)

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Ordering Physician Must Give Reason for Diagnostic Test

• Neither the law nor Medicare policy says the ordering physician must give you the literal ICD code that corresponds to the reason the specimen is being sent: the narrative diagnosis is sufficient.

• Medicare permits the consultant or laboratory to “translate that narrative [diagnosis] to the appropriate [ICD] diagnosis code.”

• “The narrative does not have to exactly match the description of the [biller’s] submitted [ICD code]” but they must be sufficiently similar to enable the biller to defend that the code “provides the highest degree of accuracy and completeness.”

• Unfortunately, congress didn’t provide for fines, penalties, or sanctions for referring doctors who persistently withhold the requisite diagnostic information from pathologists and labs.

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Neoplasm Coding Conventions

• The ICD conventions for reporting neoplasms are important to pathologists due to frequency of use. • However, most of the instructions in the

Neoplasms chapter of the official guidelines don’t really apply to pathologists and laboratories; instead, they pertain mainly to procedures and services aimed at treating the patient once cancer has been diagnosed, rather than to the exams that lead to that diagnosis.

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Classification of Neoplasms

• ICD distinguishes among neoplasms on the basis of being malignant, benign, of uncertain behavior, or unspecified.

• Malignant tumors are sub-classified according to origin: primary, secondary (metastatic), or in situ.

• Each category is described and in the main, the meaning ascribed to each class is consistent with medical custom as understood by most pathologists.

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ICD-10 Coding “Per Case” or “Per Specimen”

• Coding each specimen is IDEAL - - but not necessary• Establish Medical Necessity• The ICD-10 code appears on the Insurance claim form

Please note the following: NOT required for each specimen/container Often, one code adequately identifies the need for care, AND The first diagnosis code should represent the most important

reason for careReason: Many times only the first diagnosis code per line of service is

referred to by claim processing software

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2016 Code Changes

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SUMMARY REVIEW

• AMA made several changes in the Pathology and Laboratory 80000 series code section of the CPT code set. There were 28 new codes added, 11 deleted codes and 50 revised codes.

• In molecular diagnostics, the scope of the molecular pathology services codes have increased yet again for 2016, with the addition of eight new Tier 1 codes and seven new genomic sequencing procedures (this section is commonly referred to as Next Gen Sequencing in the laboratory) as well as ten multianalyte assay with algorithmic analyses (MAAAs), which are procedures that utilize multiple results derived from assays of various types, including molecular pathology, FISH and non-nucleic acid based assays.

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New OB Panel Code80081 — Obstetric panel (includes HIV testing)This new code is identical to the 80055 code (Obstetric panel) except the HIV testing was added. The added service for this new panel includes HIV-1 antigen(s), with HIV-1 and HIV-2 antibodies, single result (87389).

• This panel must include the following in addition to HIV:• Blood count, complete (CBC), and automated differential WBC count (85025 or 85027

and 85004)• OR

• Blood count, complete (CBC), automated (85027) and appropriate manual differential WBC count (85007 or 85009)

• Hepatitis B surface antigen (HBsAg) (87340)• HIV-1 antigen(s), with HIV-1 and HIV-2 antibodies, single result (87389)

Antibody, rubella (86762)• Syphilis test, non-treponemal antibody; qualitative (e.g., VDRL, RPR, ART) (86592)

Antibody screen, RBC, each serum technique (86850)• Blood typing, ABO (86900)

• AND• Blood typing, Rh (D) (86901)

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SURGICAL PATHOLOGY 1 code revision, 1 code deletion, and 1 code addition —revamps coding for immunofluorescence studies for tissue or cellular specimens. Report immunofluorescence by either direct or indirect methods using two codes —

• Revised code 88346 for “initial single antibody stain procedure,” and • New code +88350 for “each additional single antibody stain

procedure.” Delete 88347 (Immunofluorescent study, each antibody; indirect method.)

The “unit of service” is defined as each additional “single antibody stain procedure” from that designated specimen. It is not solely each additional stain performed, it has to be a separate stain procedure for that given stain, hence the descriptor “single antibody stain procedure.” Also please note in the parenthetical that the AMA specifically states to not report 88346 and 88350 when the stain performed is a multiplex immunofluorescence stain(s)… it directs to the coder to assign the miscellaneous code 88399.

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MOLECULAR PATHOLOGY TIER 1 MOLECULAR PATHOLOGY PROCEDURES

The following are the new codes for 2016 for gene-specific and genomic procedures. • Molecular pathology codes include all analytical services performed

in the test. This includes cell lysis, nucleic acid stabilization, extraction, digestion, amplification, and detection. Any procedures required prior to cell lysis such as microdissection (88380, 88381) are reported separately.

• AMA instructs coders to use 87149-87153, 87470-87801, and 87900-87904 for any molecular testing done for microbial identification. This means molecular testing for infectious agents, such as HPV are NOT reported in the molecular pathology section of the code book. You should look to the Microbiology section for those codes.

• For in situ hybridization, use the 88271-88275 (when interpreted by scientist instead of pathologist) and 88365-88368 when interpreted by a pathologist.

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MOLECULAR PATHOLOGY TIER 1 MOLECULAR PATHOLOGY PROCEDURES

• 81170 ABL1 (ABL proto-oncogene 1, non-receptor tyrosine kinase) (eg, acquired imatinib tyrosine kinase inhibitor resistance), gene analysis, variants in the kinase domain

• 81162 BRCA1, BRCA2 (breast cancer 1 and 2) (eg, hereditary breast and ovarian cancer) gene analysis; full sequence analysis and full duplication/deletion analysis

• Do not report 81162 in conjunction with 81211, 81213, 81214, 81216)• 81218 CEBPA (CCAAT/enhancer binding protein [C/EBP], alpha) (eg, acute myeloid

leukemia), gene analysis, full gene sequence• 81219 CALR (calreticulin) (eg, myeloproliferative disorders), gene analysis, common

variants in exon 9• 81272 KIT (v-kit Hardy-Zukerman 4 feline sarcoma viral oncogene homolog) (eg,

gastrointestinal stromal tumor [GIST], acute myeloid leukemia, melanoma), gene analysis, targeted sequence analysis (eg, exons 8, 11, 13, 17, 18)

• 81273 KIT (v-kit Hardy-Zukerman 4 feline sarcoma viral oncogene homolog) (eg, mastocytosis), gene analysis, D816 variants(s)

• 81276 KRAS (Kirsten rat sarcoma viral oncogene homolog) (eg, carcinoma gene analysis; additional variants(s) (eg, codon 61, codon 146)

• 81311 NRAS (neuroblastoma RAS viral [v-ras] oncogene homolog) (eg, colorectal carcinoma), gene analysis, variants in exon 2 (eg, codons 12 and 13) and exon 3 (eg, codon 61)

• 81314 PDGFRA (platelet-derived growth factor receptor, alpha polypeptide) (eg, gastrointestinal stromal tumor [GIST]), gene analysis, targeted sequence analysis (eg, exons 12, 18)

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Genomic and MAAA Update

• Revised “Genomic Sequencing Procedures and Other Molecular Multianalyte Assays” section.

• Most of the changes involve updating specific listed genes to better align with current protocols. Some of the changes include RNA analysis, “if performed.”

• The more significant changes to the “genomic” section involve adding several new panels, as follows:

• 81412 — Panel for Ashkenazi Jewish genetic disorders such as Bloom syndrome, Canavan disease, cystic fibrosis, and more

• 81432 and 81433 — Panels for disorders related to hereditary breast cancer genetic mutations, such as breast, ovarian, and endometrial cancers

• 81434 — Hereditary retinal panel, for disorders such as retinitis pigmentosa, cone-rod dystrophy, and more

• 81437 and 81438 — Panels for hereditary neuroendocrine tumor disorders such as medullary thyroid and parathyroid carcinomas

• 81442 — Noonan disorder panel, for conditions such as Noonan syndrome, Costello syndrome, and more.

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Manage MAAAs

• 10 new codes for multianalyte assays with algorithmic analyses, or MAAAs. These procedures involve running a panel of tests and using an algorithm to analyze the results (possibly with other patient data) to provide a risk or prognostic “score.” The new tests include:

• biomarkers for rheumatoid arthritis (81490)• 23-gene analysis for coronary artery disease risk (81493)• mRNA markers for colon cancer recurrence (81525)• DNA markers and fecal occult blood test for colon cancer screening (81528)• Tumor cell culture for gynecological cancer chemotherapy-agent

susceptibility (81535 and +81536)• Lung cancer mass spectrometry predictive survival algorithm (81538)• Type and subtype analysis for tumor of unknown origin (81540)• Thyroid cancer gene analysis for benign or suspicious prediction (81545)• Gene expression analysis for heart transplant rejection risk score (81595).

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Update Infectious Organism Codes• Systematic change to codes for infectious agent antigen detection by

immunoassay technique (parent code 87301 through indented code 87430, and parent code 87449 through indented code 87451). The change appears in the common portion of the code descriptors, and simply provides examples of immunoassay technique, such as enzyme immunoassay (EIA), enzyme-linked immunosorbent assay (ELISA), immunochemiluminometric assay (IMCA).

• The change shouldn’t alter how you use these codes

• Minor revisions to influenza virus codes 87502 and +87503 for infectious agent antigen detection by nucleic acid, to include multiplex reverse transcription “when performed.”

• Minor revisions to the wording of immunology codes 86708-86709 for Hepatitis A antibody. The changes shouldn’t alter how to use the codes.

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Toxicology CPT Code Changes

January 1, 2016, CMS deleted all 2015 drug testing G codes and will continue to not recognize the AMA CPT codes for drug testing. CMS created three G codes for presumptive testing and four G codes for definitive testing. 1. Delete the following G-codes:

• a. G0431, G0434 • b. HCPCS codes G6030 through G6058

2. Continue to not recognize the AMA CPT codes 80300 – 803773. For presumptive testing, create three G codes. Only one of the three presumptive G codes may be billed per day.4. For definitive testing, create four G codes. Only one of the four definitive G codes may be billed per day.

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Presumptive Drug Testing

G0477 Drug tests(s), presumptive, any number of drug classes; any number of devices or procedures, (eg, immunoassay) capable of being read by direct optical observation only (eg, dipsticks, cups, cards, cartridges), includes sample validation when performed, per date of service.G0478 Drug tests(s), presumptive, any number of drug classes; any number of devices or procedures, (eg, immunoassay) read by instrument-assisted direct optical observation (eg, dipsticks, cups, cards, cartridges), includes sample validation when performed, per date of service.G0479 Drug tests(s), presumptive, any number of drug classes; any number of devices or procedures by instrumented chemistry analyzers (eg, immunoassay, enzyme assay, TOF, MALDI, LDTD, DESI, DART, GHPC, GC mass spectrometry), includes sample validation when performed, per date of service.

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Definitive Drug TestingG0480 Drug test(s), definitive, utilizing drug identification methods able to identify individual drugs and distinguish between structural isomers (but not necessarily stereoisomers), including, but not limited to GC/MS (any type, single or tandem) and LC/MS (any type, single or tandem and excluding immunoassays (eg, IA, EIA, ELISA, EMIT, FPIA) and enzymatic methods (eg, alcohol dehydrogenase)); qualitative or quantitative, all sources, includes specimen validity testing, per day, 1-7 drug class(es), including metabolite(s) if performed.G0481 Drug test(s), definitive, utilizing drug identification methods able to identify individual drugs and distinguish between structural isomers (but not necessarily stereoisomers), including, but not limited to GC/MS (any type, single or tandem) and LC/MS (any type, single or tandem and excluding immunoassays (eg, IA, EIA, ELISA, EMIT, FPIA) and enzymatic methods (eg, alcohol dehydrogenase)); qualitative or quantitative, all sources, includes specimen validity testing, per day, 8-14 drug class(es), including metabolite(s) if performed.G0482 Drug test(s), definitive, utilizing drug identification methods able to identify individual drugs and distinguish between structural isomers (but not necessarily stereoisomers), including, but not limited to GC/MS (any type, single or tandem) and LC/MS (any type, single or tandem and excluding immunoassays (eg, IA, EIA, ELISA, EMIT, FPIA) and enzymatic methods (eg, alcohol dehydrogenase)); qualitative or quantitative, all sources, includes specimen validity testing, per day, 15-21 drug class(es), including metabolite(s) if performed.)G0483 Drug test(s), definitive, utilizing drug identification methods able to identify individual drugs and distinguish between structural isomers (but not necessarily stereoisomers), including, but not limited to GC/MS (any type, single or tandem) and LC/MS (any type, single or tandem and excluding immunoassays (eg, IA, EIA, ELISA, EMIT, FPIA) and enzymatic methods (eg, alcohol dehydrogenase)); qualitative or quantitative, all sources, includes specimen validity testing, per day, 22 or more drug class(es), including metabolite(s) if performed.

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Pathology Reports

• Elements of the report• Clinical Information must include

• Referring Physician• Patient Demographics• Clinical signs or symptoms or personal history of disease (reason the test

was ordered)• Body of the report should include

• Description of the specimen, procedure(s) including stain panel, add’l studies etc.

• Diagnosis • If findings are negative – coding is based on signs or symptoms (indicated

in clinical hx)• Diagnosis can not be assigned on basis of “rule out”, “possible” or

“probable” history or findings

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Reminder: When service provided with a Resident or Fellow – Attending Attestation is required.

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CAP Guidelines for the Reporting of Nongynecologic Cytopathology Specimens

http://www.archivesofpathology.org/doi/pdf/10.1043/1543-2165-133.11.1743• Is the clinical history required in a report for smears?

• When this information is not submitted by the health care provider, the report should specifically state that ‘‘no clinical information is provided.’’

• Pathologists are not obliged to review patient records to find these data because they may not have easy access to those records, especially if the records or the pathologist is outside of a hospital setting.

• Some pathologists task assistants with this duty, whereas others personally contact the health care provider. The ability to review a patient’s record for clinical history of prior malignancy, radiographic reports, laboratory results, clinical signs and symptoms, and physical examination findings allows the pathologist to synthesize all data in order to provide an accurate assessment for that patient.

• Accessibility of an electronic patient record optimizes the outcome for the patient because a pathologist can review all pertinent medical findings and significantly narrow the differential diagnosis for a particular case.

• At a minimum, pathologists should indicate this review in the pathology report. It is optimal to provide a summary of relevant medical findings and how they relate to the interpretation of the specimen and outcome for the patient.

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Interstate Practice of Pathology With respect to states with restrictive licensure laws, a pathologist should either become licensed or refuse to accept specimens from that state unless an exception clearly applies.• Several states (5) prohibit physicians from consultation without a license for the specific state

(Connecticut, Idaho, Louisiana, Michigan, South Carolina & Tennessee). • Example: Idaho• Statute requires that any physician who diagnoses or treats a patient in Idaho be licensed in

Idaho regardless of where that physician practices.• Example: South Carolina• When a South Carolina physician requests an out-of-state pathologist to examine a specimen

and make a primary diagnosis, the out-of-state pathologist is required by state law to have a South Carolina license. However, an out-of-state pathologist who merely reports a numerical value, such as a prothrombin time, would not have to be licensed in this state. See CAP Today, link below.

“Specifically, pathologists who review specimens from out-of-state patients should familiarize themselves with the licensure statutes, regulations, and rulings in every state from which they accept specimens. Large national laboratories are, in many instances, already obtaining licenses for their pathologists in the jurisdictions from which specimens originate. But, as theSmith decision illustrates, this practice is far from universal among hospital-based pathologists

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Surgical Pathology ConsultationsCPT 88321- 88325

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88321 – Consultation and report on referred slides prepared elsewhere

• Does not include slide preparation88323 – Consultation and report on referred material requiring preparation of slides

• ALWAYS includes the preparation of a new set of slides (e.g. tissue block)

88325 – Consultation, comprehensive, with review of records and specimens, with report on referred material

• “comprehensive” consultation requires the review of the specimens AND all associated medical records

These codes are used to report consultations on material referred from another source

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CPT Coding - Consultations88321 - Slides prepared elsewhere

1. A request from the referring physician for theclinical pathology consultation

2. A copy of the pathology report referenced in the request

3. A copy of the provider’s consultation4. Any additional clinical information that would

support the “reasonable and necessary” basis for the service

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• 88323 Slides prepared “de novo”• All four (4) of the requirements for 88321 PLUS

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CPT Coding - Consultations

“Lab slips indicating the number of slides performed and number of specimens (tissue block)”

In order to bill 88323, the slides prepared cannot be for immunohistochemistry, which is a separately billed and paid as code 88342. The documentation must support that the physician performed and documented the additional services that the slide was prepared by the provider for histologic staining which is required to bill 88323.

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CPT Coding - Consultations

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88325 Comprehensive, record reviewAll four (4) of the requirements for 88321

PLUS

“Medical records supporting the need for this service”

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Billing Services When Working With Residents Fellows and Interns

All Types of Services Involving a resident with a TP Requires Appropriate Attestations In EHR or Paper Charts To Bill

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Pathology ServicesIn the teaching setting the attending pathologist qualifies for

reimbursement if:• The teaching physician's signature is the only signature on the report

(Carrier will assume that the author/attending is indicating that he or she personally performed the interpretation).

• If a resident prepares and signs the report, the teaching physician must indicate that he or she has personally reviewed the specimen and the resident's interpretation and either agrees with it or edits the findings.

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In cases where the documentation shows simply a countersignature of the resident's interpretation by the teaching physician – no charges should be submitted by the attending physician

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Pathology TP Sample Attestations• Surgical if there is no gross and Flow Cytometry and Peripheral

Smear Consultations: • Microscopic only: ‘All microscopic slides and flow

cytometry data (if applicable) have been reviewed and interpreted by the signing pathologist’

• Surgical cases with gross and microscopic: • “The gross description and all microscopic slides have been

reviewed and interpreted by the undersigned pathologist”• Surgical cases with gross only:

• “The gross specimen has been personally reviewed and interpreted by the undersigned pathologist”

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Pathology TP Sample Attestations• Coagulation Consultations:

• ' These tests have been reviewed and interpreted by the signing pathologist'

• Hematopathology: • ' The gross description, flow cytometry data (if applicable) and

all microscopic slides have been reviewed and interpreted by the undersigned pathologist'

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E/M IP or OP: TP must personally document at least the following: That s/he performed the service or was physically present during

the key or critical portions of the service when performed by the resident; AND The participation of the teaching physician in the management

of the patient.Example: ‘I saw and examined the patient and agree with the

resident’s note…’Time Based E/M Services: The TP must be present and document for the period of time for which the claim is made.Examples : E/M codes where more than 50% of the TP time spent

counseling or coordinating care

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Face-to-Face Visits and Consultations

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Modifiers: Provider Documentation MUST Support the Use of All Modifiers

Increase reimbursement

Indicate specific

circumstances

Provide additional

information

Prevent denial of services

Facilitate correct coding

A billing code modifier allows you to indicate that a procedure or service has been altered by some specific circumstance but has not changed in its definition.

Modifiers allow to:

Documentation in the report must support the use of any modifier

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When to Use Modifiers – To Bundle or Not

Bundled – verb: to collect or gather up into a mass (Oxford Dictionary)• A “bundled” service includes all of the steps necessary to complete a

given procedure. • Most CPT codes for procedures include additional CPT codes that are

inherently part of a r procedure.

• Unbundling - occurs when 2 or more CPT codes are used to describe a service when a single, more comprehensive code exists that accurately describes the service performed.

• “Bundled codes” can be “unbundled” to indicate that although they can be part of another procedure performed on the same date of service, for this encounter they should be paid separately.

• National Correct Coding Initiative (NCCI) edits provide most, but not all edits. Pre-billing “scrubber” checks for edits before billing.

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Modifier 59: Distinct Procedural Service

Designates instances when distinct and separate multiple services are provided to a patient on a single date of service and should be paid separately.

Modifier-59 is defined for use in a wide variety of circumstances to identify: ◦ Different encounters Different anatomic sites (Different services

(Most commonly used and frequently incorrect). Subsets of Modifier-59 XE - Separate Encounter, a service that is distinct because it occurred

during a separate encounter. Used infrequently and usually correct.◦ XS - Separate Structure, a service that is distinct because it was

performed on a separate organ/structure. Less commonly used and can be problematic.◦ XP – Separate Practitioner, a service that is distinct because it was

performed by a different practitioner. ◦ XU – Unusual non-overlapping service, the use of a service that is

distinct because it does not overlap usual components of the main service.

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Modifier – 91 Repeat Clinical Diagnostic Laboratory Test

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If an ordering physician requests a laboratory test thatrequires that several of the same services (CPT code)be performed for the same beneficiary on the sameday, modifier -91 should be used to indicate thatmultiple clinical diagnostic laboratory tests were doneon the same day. (This modifier should not be usedwhen multiple tests are described under a single code,e.g., glucose tolerance test.)

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Modifier GC CMS Manual Part 3 - Claims Process - Transmittal

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Teaching Physician Services That Meet the Requirement for Presence During the Key Portion of the Service when working with a resident or fellow

Teaching Physician Services that are billed using this modifier are certifying that they have been present during the key portion of the service.

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2015 PQRS CMS Quality Improvement Programs

Meaningful Use (MU)Physician Quality Reporting System (PQRS)Value Based Payment Modifier (VBPM)

• Considered one of the “Medicare quality improvement incentive program”

Physician “Provider” Quality Reporting (PQRS)

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PQRSReporting Requirements:Reporting Period= Full CY Report 9 Measures from 3 National Quality Strategy Domains

2016 CAP PQRS/VBM Online Tools Participating in PQRS had been voluntary, but now it is becoming mandatory if one wants to avoid Medicare payment penalties. Pathologists are at risk of having Medicare payments reduced when CMS determines that they could have participated in PQRS and did not. Performance on PQRS measures in 2016 will be the factor deciding whether their Medicare Part B payments will have a negative PQRS and value-based modified (VBM) adjustment in 2018.• While the CMS has said that the penalties will not apply for pathologists

who have no applicable PQRS measures, the CMS plans to review claims to check that none of the measures applied. Eligible physicians face a 2% penalty in 2018 for not successfully reporting PQRS measures in 2016. PQRS also is a factor in the VBM, which also could penalize eligible physicians by an additional 2% to 4% in 2018 following the 2016 PQRS reporting year.

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Physician Impact

Workflow and documentation changes

TO DO:Study Measure Specifications

Ensure documentation meets measure requirements

Bill PQRS quality code when required

Document chronic conditions/secondary diagnoses

Use Smart Phrases if needed

Ensure medical support staff completes required documentation

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CAP Pathology CMS 2016 PQRSBreast Cancer Resection Pathology Reporting

• Measure #99 – pT category (primary tumor) and pN category (regional lymph nodes) with histologic grade

Colorectal Cancer Resection Pathology Reporting• Measure #100 – pT category (primary tumor) and pN category (regional

lymph nodes) with histologic gradeBarrett’s Esophagus

• Measure #249 – Esophageal biopsies with a diagnosis of Barrett’s esophagus that also include a statement on dysplasia

Radical Prostatectomy Pathology Reporting• Measure #250– Reports include the pT category, the pN category, the

Gleason score and a statement about margin status

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CAP Pathology CMS 2016 PQRSImmunohistochemical (IHC) Evaluation of HER2 for Breast Cancer Patien ts

• Measure #251 – Quantitative HER2 evaluation by IHC uses the system recommended by the ASCO/CAP guidelines

Lung cancer reporting (biopsy/cytology specimens) (New)• Measure #395 – Pathology reports based on biopsy and/or cytology specimens

with a diagnos is of non small cell lung cancer classified into specific histologic type or classified as NSCLC-NOS with an explanation included in the pathology report

Lung cancer reporting (resection specimens) (New)• Measure #396 - Pathology reports based on resection specimens with a

diagnosis of primary lung carcinoma that include the pT category, pN category and for non small cell lung cancer, histologic type

Proposed New Melanoma reporting (New)• Measure #397 – Pathology reports for primary malignant cutaneous melanoma

that include the pT category and a statement on thickness and ulceration and for pT1, mitotic rate

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CASE SAMPLES

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HIPAA, HITECH, PRIVACY AND SECURITY• HIPAA, HITECH, Privacy & Security Health Insurance Portability and Accountability Act – HIPAA

– Protect the privacy of a patient’s personal health information– Access information for business purposes only and only the records you need to

complete your work.– Notify Office of HIPAA Privacy and Security at 305-243-5000 if you become

aware of a potential or actual inappropriate use or disclosure of PHI,including the sharing of user names or passwords.

– PHI is protected even after a patient’s death!!!

• Never share your password with anyone and no one use someone else’s password for any reason, ever –even if instructed to do so.

If asked to share a password, report immediately.If you haven’t completed the HIPAA Privacy & Security Awareness on-line CBLmodule, please do so as soon as possible by going to:

http://www.miami.edu/index.php/professional_development__training_office/learning/ulearn/

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HIPAA, HITECH, PRIVACY AND SECURITY• HIPAA, HITECH, Privacy & Security• Several breaches were discovered at the University of Miami, one of which has resulted in• a class action suit. As a result, “Fair Warning” was implemented.• What is Fair Warning?• • Fair Warning is a system that protects patient privacy in the Electronic Health Record• by detecting patterns of violations of HIPAA rules, based on pre-determined analytics.• • Fair Warning protects against identity theft, fraud and other crimes that compromise• patient confidentiality and protects the institution against legal actions.• • Fair Warning is an initiative intended to reduce the cost and complexity of HIPAA• auditing.• UHealth has policies and procedures that serve to protect patient information (PHI) in• oral, written, and electronic form. These are available on the Office of HIPAA Privacy &• Security website: http://www.med.miami.edu/hipaa

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Available Resources at University of Miami, UHealth and the Miller School of Medicine

• If you have any questions or concern regarding coding, billing, documentation, and regulatory requirements issues, please contact:

• Iliana De La Cruz, RMC, Director Office of Billing Compliance • Phone: (305) 243-5842• Officeofbillingcompliance@med.miami.edu

• Also available is The University’s fraud and compliance hotline via the web at www.canewatch.ethicspoint.com or toll-free at 877-415-4357 (24hours a day, seven days a week).

• Office of billing Compliance website: www.obc.med.miami.edu

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