All of you are familiar with some of the regulatory requirements that affect your practice, as identified by their acronyms and initials: HIPAA, CMS, CoPs,PQRS, SCIP, ACO, HCAHPS. For hospital-based practices, there are now two additional “ingredients” in our regulatory alphabet soup that will require your attention: OPPE and FPPE. Historically, hospital medical staff appointments and reappointments have been primarily a subjective process, where the clinical chief signed off on credential/privilege requests, perceived competencies and specific skills. The Joint Commission and other accrediting bodies and payers have established more stringent guidelines for the ongoing evaluation of medical staff members. The Ongoing Professional Practice Evaluation (OPPE) and Focused Professional Practice Evaluation (FPPE) are now becoming part of every hospitalbased anesthesia practice’s routine. These evaluations are expected to occur on a regular basis and serve as the key component to the hospital reappointment process. Key Components   In adopting the Accreditation Council for...

“Much has changed in health care since HIPAA was enacted over fifteen years ago,” said HHS Secretary Kathleen Sebelius in the Department of Health and Human Services’ January 17th press release announcing the publication of the long-awaited final omnibus rule with Modifications to the HIPAA Privacy, Security, Enforcement and Breach Notification Rules under the Health Information Technology for Economic and Clinical Health Act and the Genetic Information Nondiscrimination Act. “The new rule will help protect patient privacy and safeguard patients’ health information in an ever expanding digital age.” The final omnibus rule will go into effect on March 26, 2013. Covered entities such as anesthesia and pain medicine practices and billing companies including ABC—and their business associates—must be in compliance by September 23, 2013. The final rule changes HIPAA in several important ways: It toughens the definition and consequences of failure to notify affected parties of security and privacy breaches;It strengthens...

Many “Covered Entities” within the meaning of the privacy and security provisions of the Health Insurance and Portability Act of 1996 (HIPAA) are managing more and more of their patient information electronically.  Indeed, not moving to electronic health records (EHRs) may cost physicians a percentage of their Medicare remittances—or at least the loss of a potential bonus of up to $44,000—under the EHR Incentive Program, as discussed in our last several Alerts.Collecting, analyzing, reporting and storing electronic patient information present perhaps even greater HIPAA challenges than does the use of paper records, however.  Data entered on a computer can be copied more easily, more cheaply, more prolifically and even passively.  Once unsecured data are moved from the computer on which they are created to other media, manually or wirelessly, controlling the information becomes nearly impossible.  The key word in the preceding sentence is “unsecured.”  The recently finalized HIPAA regulations on Breach Notification impose...

The acronym “HIPAA” has become a household name since the enactment of the Health Information Portability and Accountability Act of 1996, which, among other things, established rules for protecting and securing patients’ health information. In fact, it is not uncommon to hear about breaches of patient information costing healthcare providers and suppliers six and seven figure civil monetary penalties or settlements. Typically, such settlements and penalties have arisen out of patient complaints that the privacy of their protected health information (PHI) has been compromised. However, beginning November 2011, patient complaints will not be the only way in which the Department of Health and Human Services (HHS) Office of Civil Rights (OCR) will learn about non-compliant entities.Section 13411 of the American Recovery and Reinvestment Act of 2009, which established the Health Information Technology for Economic and Clinical Health (HITECH) Act, requires the Secretary of HHS to “provide for periodic audits to ensure...

“Cloud Computing” is a phrase we hear thrown about constantly in the technology industry these days. To the casual observer, it can be synonymous with the internet or perhaps used to identify a specific program available over the web. Large organizations such as hospitals typically understand the nuance that exists when discussing and integrating cloud computing concepts, but since many anesthesia practices must double as their own internal IT departments, confusion may arise as to what cloud computing is and how it affects your business.Many tout the cloud as the next evolutionary step to the traditional software and support models but fail to evaluate the true benefits and costs. As this software and platform model continues to mature, we must ask, “How will cloud computing affect my practice and how can I benefit?”WHAT IS CLOUD COMPUTING?This seems to be an ever evolving answer. While many industry experts expected to have a...