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1 RCF Forum Call Mar 2017

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RCF Forum Call Mar 2017

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HIPAA Reminder:

When sending email, please do not include any identifying information. Theabove table developed by the Federal Department of Health and HumanServices gives definitions of 18 examples of identifying information.

As usually the case during roster season, we have seen an increase inPHI sent to Catherine at Muskie through email. Please use cautionwhen returning your roster and any modifications.

Protected Health Information (PHI)Information in any format that identifies the individual, including demographicinformation collected from an individual that can reasonably be used toidentify the individual. Additionally, PHI is information created or received bya health care provider, health plan, employer, or health care clearinghouse;and relates to the past, present, or future physical or mental health orcondition of an individual.

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De-identifiedInformation that has certain identifiers (see “identifiers” below) removed inaccordance with 45 CFR 164.514; no longer considered to be ProtectedHealth Information.(Note: Please be aware that individual participants may be identifiable bycombing other items in the data even when none of the following 18 identifiersare present. Thus, a study may still contain personally identifiable data (PID)even after removing or never acquiring the identifiers listed below, and theinvestigator may still need to provide complete answers for the data securityquestions (Items 8-10) in the protocol. )

IdentifiersUnder the HIPAA Privacy Rule “identifiers” include the following: 1. Names2. Geographic subdivisions smaller than a state (except the first three digits ofa zip code if the geographic unit formed by combining all zip codes with thesame three initial digits contains more than 20,000 people and the initial threedigits of a zip code for all such geographic units containing 20,000 or fewerpeople is changed to 000).3. All elements of dates (except year) for dates directly related to an individual,including birth date, admission date, discharge date, and date of death and allages over 89 and all elements of dates (including year) indicative of such age(except that such ages and elements may be aggregated into a singlecategory of age 90 or older)4. Telephone numbers5. Fax numbers6. Electronic mail addresses7. Social security numbers8. Medical record numbers9. Health plan beneficiary numbers10. Account numbers11. Certificate/license numbers12. Vehicle identifiers and serial numbers, including license plate numbers13. Device identifiers and serial numbers14. Web Universal Resource Locators (URLs)15. Internet Protocol (IP) address numbers

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16. Biometric identifiers, including finger and voice prints17. Full face photographic images and any comparable images18. Any other unique identifying number, characteristic, or code (excluding arandom identifier code for the subject that is not related to or derived from anyexisting identifier

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We continue to receive information via email. If you send a document with a name, asocial security number, medicare or mainecare ID, that is a hipaa violation.

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We are unable to calculate any quality measure that requires information from ICD-9 codesas this information is not being collected using the current tool.

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The current policies for MaineCare hospice and MDS-RCA do not allow for a nursepractitioner to diagnosis a terminal condition. The nurse practitioner can sign off on thehome health plan of care and treatment to authorize the services, but the nursepractitioner cannot diagnose the terminal prognosis.

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No entry tracking forms are required when a resident returns from the hospital or otherLOA. The only possible assessment at the time of re-entry might be a significant changeassessment, as appropriate, if there are two or more areas of improvement or decline.

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A Discharge Tracking form is completed when the facility has officially discharged theresident with no anticipation of return to the facility.

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We are looking for patterns of behavior, rather than a single occurrence that may havelasted for 4 days of a behavior. The MDS is used to calculate RUG groups that determinepayments for the facilities. A RUG should be reflective of a pattern of care that is providedby staff as needed by a resident, based on items coded on the MDS. RUG stands forResource Utilization Group. The resource being measured is staff time.

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if your staff documentation is consistently perceived as being inaccurate, there may be aninternal issue with documentation. The MDS coordinator should not code an inaccurateMDS based on inaccurate staff documentation. If the MDS coordinator believes staffdocumentation is inaccurate, he/she may interview staff across all three shifts who knowthe resident best to determine the correct functional status. It is the responsibility of thefacility to ensure staff understand the meaning of the coding terms and that staff utilize thecodes appropriately. As a reviewer, I would want to know what is being done to addressthe “system issue” if staff documentation was not sufficient to code the MDS.

MDS interviews of staff would not be considered the first line of documentation to supportcoding on the MDS, especially since the manual indicates “daily staff documentation for allshifts is the preferred method to support the coding of these indicators.” (MDS-RAIManual, page 47).

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The intent of P3a is to record specific monitoring required by the resident, as determinedby the physician or a registered nurse, for an acute condition. This could include monitoringan acute condition or a chronic condition that has exacerbated into an acute episode.

Acute conditions are severe, sudden in onset, and have a short course. This could describeanything from a broken bone to an asthma attack.

A chronic condition, by contrast is a long-developing syndrome, such as osteoporosis orasthma. Note that osteoporosis, a chronic condition, may cause a broken bone, an acutecondition. An acute asthma attack occurs in the midst of the chronic disease of asthma.Acute conditions, such as a first asthma attack, may lead to a chronic syndrome ifuntreated.

Some examples could be: Diabetes with unstable glucose levels, Angina requiringincreased medication as a result of recurring episodes. Other examples of acute conditionsare: Gall Bladder Attack (Cholecystitis), Bronchial Pneumonias, as well as decompensatingpsychiatric conditions, e.g., Schizophrenia, Bipolar Disorder.

P3b. The intent of P3b is to record specific monitoring required by the resident forpossible serious, untoward side effects related to a new medication or for effectiveness of anewly prescribed treatment. If the resident has been placed on a new medication thatrequires special monitoring for serious untoward effects or has been placed on a newtreatment that must be assessed for effectiveness over a period of time then code this

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area.

Some examples of serious or untoward side effects :Life threateningCould lead to hospital admission or evaluationCould requires intervention to prevent disability or permanent damageAllergic or other systemic reaction

Code by placing the numeric code for the person responsible for the monitoring , 1. RCFNurse; 2. RCF Other Staff; or 3. Home Health Nurse. Code 0 if no monitoring is required. Ifmore than one person is responsible code for the highest level.

The need for on-going monitoring of an acute condition (unstable, fluctuating, medicallycomplex) or new treatment/medication must be documented by the physician or aRegistered Nurse. Review the resident’s clinical record. Clinical records must containdocumentation by the person coded as being responsible for the monitoring to show thatmonitoring has occurred during the look back period.

Once again, documentation is required!

Here is what the case mix review nurse will be looking for:1. A note of the “need” to monitor by a physician or RN within the look back period or the

week before.2. A note or entry in the care plan of WHAT needs to be monitored, why, and what needs to

be report to physician as abnormal.3. At least one note that monitoring was done within the 7-day look back period by the

staff identified in P3 on the MDS-RCA

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If the resident has been placed on a new medication, administered by any route, thatrequires special monitoring for serious side effects or drug interactions, it may be coded inthis area. An increase or decrease in the dosage of a medication is not a new medication.

If the resident has a newly prescribed treatment that must be assessed for effectiveness,it could be coded in this area.

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If the resident has been placed on a new medication, administered by any route, thatrequires special monitoring for serious side effects or drug interactions, it may be coded inthis area. An increase or decrease in the dosage of a medication is not a new medication.

If the resident has a newly prescribed treatment that must be assessed for effectiveness,it could be coded in this area.

Change in insulin dose: not P3b, but it could possible be coded under P3a if there areunstable blood sugars.

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Code as follows: 0. No monitoring required, 1. RCF Nurse; 2. RCF Other Staff; or 3. HomeHealth Nurse. If more than one person is responsible code for the highest level.

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MaineCare Benefits Manual, Chapter III, Section 97, Appendix C, 8030.6 The Departmentwill utilize the roster in identifying MaineCare residents and their most recent assessment.It is the provider’s responsibility to check the roster, make corrections and submitcorrections to the Department or its designee within one week of receiving the roster.

7020Schedule of Resident Assessments: The provider must complete the MDS-RCAwithin 30 days of admission and at least every 180 days thereafter during a resident’sstay. The provider will sequence the assessments from the date in Section S.2.B of theMDS-RCA, Assessment Completion Date. The provider will complete subsequentassessments within 180 days from the date in S.2.B. Providers must complete asignificant change MDS-RCA assessment within 14 calendar days after determinationis made of a significant change in resident status as defined in the Training Manual forthe MDS-RCA Tool. Providers must complete a Resident Tracking Form within 7 daysof the discharge, transfer, or death of a resident. Providers must maintain all residentassessments completed within the previous 12 months in the resident’s active record.

7060.1 The Department will sanction providers for failure to complete assessmentscompletely, accurately and on a timely basis. (this means that discharges that are notcompleted within the established time frame may be calculated into the final error rate andthat could lead to sanctions.)

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