MiraVista: Medicare News Blog

CMS Announces Next Steps for Competitive Bidding

July 21st, 2014

Angela Hayden

 

The gavel has come down on next steps for the Competitive Bidding program as CMS has issued notice for a Recompete of both Round 2 and National Mail Order contracts. The original Round 2 and NMO contracts are in effect until June 30, 2016. Speculation has been circulating concerning what CMS’ next steps for the program would be since the issuance of a request for comment on a nationwide competitive bidding program in February 2014.  While the most recent announcement shifts focus toward the Recompete process, we fully expect the Nationwide Competitive Bidding effort to move forward in the days ahead via a separate notification process.

 

While most aspects of the program will remain the same for the Round 2 Recompete (R2RC), there were some minor, notable tweaks. For example, Round 2 encompassed a total of 91 Metropolitan Service Areas (MSAs) with 100 Competitive Bid Areas (CBAs) to sub divide the larger MSAs. However, for the Recompete there will be 90 MSAs and 117 CBAs; 16 of the MSAs in R2RC are divided into multiple CBAs to break up the expansive metropolitan areas and to avoid multiple-state bid areas. Additionally, any zip code changes that have taken place since Round 2 implementation have been translated into the R2RC zones.

 

As for products, the R2RC has been updated to reflect much of what we saw with the R1RC. Many categories have now been grouped rather than broken out for individual bid.  Under the R2RC Oxygen, CPAP, RADs and their related supplies and accessories have been grouped together into the Respiratory Equipment and Related Supplies and Accessories category.  Nebulizers which were grouped into the respiratory category for R1RC, have now been broken out into their own bid category for the R2RC.

 

Hospital beds and Group 1 and 2 support surfaces have been grouped together under the General Home Equipment and Related Supplies and Accessories category, which now includes three new products (commode chairs, patient lifts and seat lifts).  Under Round 1 Recompete TENS units were grouped into this General product category, however, for the Round 2 Recompete TENS devices and supplies will be included an independent category for bid.

 

Walkers, which were previously a stand-alone product category, have now been pushed into the Standard Mobility Equipment and Related Accessories category. This category now encompasses walkers, standard power and manual wheelchairs, scooters, and related accessories. The product category we do not see up for bid in this round which was included with the R1RC is External Infusion Pumps; CMS has indicated that this product will not be bid in the R2RC. See below for a full R2RC product list:

 

  • Enteral Nutrition, Equipment and Supplies
  • General Home Equipment and Related Supplies and Accessories (hospital beds and related accessories, group 1 and 2 support surfaces, commode chairs, patient lifts, and seat lifts)
  • Nebulizers and Related Supplies
  • NPWT Pumps, Related Supplies and Accessories
  • Respiratory Equipment and Related Supplies and Accessories (oxygen, oxygen equipment and supplies; CPAP devices; RADs; and related supplies and accessories)
  • Standard Mobility Equipment and Related Accessories (walkers, standard power and manual wheelchairs, scooters, and all related accessories)
  • TENS Devices and Supplies

The National Mail Order program will also be subject to Recompete at the same time as Round 2 with no notable changes to that program.

 

With the announcement, CMS also issued important dates for all suppliers to consider. The bidding schedule will be announced this Fall. During this time, suppliers that wish to participate in the bidding program will begin the registration process to obtain a User ID and password.  The actual bidding for the Recompete will not begin until winter of 2015; therefore suppliers will have roughly a year to prepare for the formal bidding process. Those who are currently contracted under Round 2 will be eligible to participate in the Recompete as long as all requirements are met for bidding. This is a new opportunity for suppliers that were not awarded a contract under Round 2 to participate in the newest round for contracting.

 

In order to be eligible to participate in the bidding process suppliers must have an accurate record with the Provider Enrollment, Chain and Ownership System and the National Supplier Clearinghouse. All participating bidders must be licensed for the product that they wish to supply in the state in which they are bidding in prior to submitting a bid. Additionally, all locations the supplier intends to offer product from must be accredited by a CMS approved accrediting organization for the items that they provide in a product category.  All other standard bidding rules will apply – more information on those rules can be found on the CBIC website at www.dmecompetitivebid.com.

 

Prior Authorization for General DME: Good or Bad?

June 27th, 2014

Angela Hayden

 

A proposed rule was published on May 28th, 2014, seeking comment on a prior authorization program for certain DMEPOS items. In the proposal, CMS collected a Master List of 139 HCPCS that have been determined to have frequent,   unnecessary utilization. The list includes a variety of products such as hospital beds, RADs, Power Wheelchairs, Manual Wheelchairs, CPAPs, Support Surfaces and Lower Limb Prostheses.  The proposal suggests that a certain portion of the HCPCS within the Master List would be carved out and that list (referred to in the proposal as the Required Prior Authorization List) would contain those HCPCS subject to the Prior Authorization requirement. Not all items within the Master List would be rolled out at once; instead CMS seeks to slowly infuse those HCPCS to the master list over time.

 

Once the final list of HCPCS subject to the rule is determined, the list would be released with a 60 day notice for providers to get prepared for implementation. If the proposal is finalized, the program would be rolled out on both a national and local level depending on the scale of unnecessary utilization uncovered during data analysis of each area.  Also within the notice is a provision for CMS to use its discretion, at any time, to pause or suspend the program without creating a separate rule.

 

Should the rule become final, suppliers would be required to submit a request for Prior Authorization when billing for any of the selected HCPCS.  The request would need to be submitted to the DME MAC and would have to include documentation to support that the item complies with all coverage, coding and payment rules. The DME MAC would then have 10 days from receipt of all applicable information to render its decision.  In the instances where an expedited decision is necessary to preserve the life or health of the beneficiary, the proposal has included a provision for the DME MAC to render a decision within two business days of the receipt of all required documentation. Any claim submitted for one of the affected HCPCS without a valid prior authorization number would automatically be denied.

 

An interesting section of the proposal speaks to the applicability of this proposal to Competitive Bidding Areas: “We note that this proposal would apply in competitive bidding areas because CMS conditions of payment apply under the Medicare DMEPOS Competitive Bidding Program.”  This means that contracted suppliers would not be exempt from this protocol should the final rule come into action.

 

The proposal goes on to indicate that because of the existing PMD Demonstration Program, PMDs would be excluded from the initial rulemaking  – but this could be revisited once the original Demonstration has ended. The current PMD Prior Authorization Demonstration is active in seven states and not slated to expire until August 31, 2015.  A proposal to expand that program into 12 additional states is already in the works as of April 4, 2014.  The comment period for that proposal closed on April 18, 2014, with all comments in favor of an expansion.

 

For PARs that are denied or non-affirmed, the supplier would not be limited (based on this proposal) by a specific number of times that a request can be submitted for re-examination. The DME MAC would have 20 days to review the resubmission before rendering a decision.

 

The comment period for this proposal is open until 5pm Eastern Time on July 28, 2014.  Suppliers that wish to submit comment can do so using this link: http://www.regulations.gov/#!submitComment;D=CMS-2014-0070-0001

Update on FTF Directives for Multiple Physicians

May 13th, 2014

Andrea Stark

 

MiraVista has it on good authority that a clarification from CMS is imminent regarding scenarios where multiple physicians participate in the order process and whether this will be allowed under the FTF directives.  While we can only speculate on what the directive will actually contain, we are optimistic that the change will be a welcomed one by providers.

 

Currently, CMS has directed the DME MACs that only the physician that documents the FTF can be the one that orders the equipment.  However, the industry has presented CMS with numerous examples of instances where multiple practitioners can be involved.  One such example is a patient visiting a primary care physician with signs of obstructive sleep apnea.  After evaluation, the patient is referred to a sleep lab where the interpreting physician orders the CPAP and suggests an appropriate pressure setting.  Other scenarios are complicated in a hospital setting where multiple physicians evaluate the patient during rounds and the physician coordinating the discharge may or may not be the one that documented the prior evaluation(s).  Each of these two scenarios present suppliers with a predicament in the context of existing guidance.

 

MiraVista will continue to monitor for this development and will provide an update to our subscribers when the final direction is made available.

 

Still confused about Face-to-Face requirements? 

You are not alone.

 

The rules and requirements have continued to unravel since the publication of the Face-to-Face rule and many providers are still scratching their heads about implementation in the real world. Join our webcast “Face-to-Face in the Real World: How to Comply in Its Current Form” on June 3, 2014 at 3pm ET as Andrea Stark partners with HME News to discuss the Face-to-Face rule as it currently exists for DME providers and what to anticipate as we move forward.  Register on our webinars/seminars page.

 

MiraVista Seeking Associates

April 16th, 2014

 

“Do or do not.  There is no try.” – Yoda

 

MiraVista LLC, a medical billing and consulting company, is searching for candidates for full and part-time associate positions in our Statesboro, GA office.

 

Do you qualify?

 

If you just need a job, you will hate working with us.  We are perpetually trying to figure things out and get better; not just better than our competition, but better than ourselves.

 

While not a bad thing, we do not typically look for prior medical billing experience.  Quite frankly, it takes longer to break bad habits than to teach qualified people with no direct experience.  So the “better-than-$2.10 per hour plus tips” question is:  Do you qualify?

 

We require:

  • Strong communication skills.  To contribute to our staff, you have to initiate discussion and participate in debate.  You cannot do that without strong communication skills.  Twitter only counts if you are truly compelling in 140 characters or less.
  • Decent desktop computer skills.  We use Microsoft Excel…heavily.  Most other applications we use pivot on the general knowledge necessary to get around Microsoft Office products and popular browser-based web tools.  There are no wildly specialized applications that we use, but you have to know your way around a desktop computer.
  • Good research skills.  If you don’t know the answer to a question, you should be able to Google it…and get it…and then share it with us.
  • Hustle.  Period.

 

We admire the following:

  • Work experience.  4.0 grade point averages are great, but that is not how we operate.  We don’t have 3 weeks to do something perfect; we have 3 weeks to do lots of things pretty damn well.  If you have worked while putting yourself through school, mastered a craft of any kind, or even participated in meaningful extracurricular activities while paying the rent, we think that’s cool.
  • Other experience.  People who have seen and done things are awesome.  Some of the greatest innovations in our work come from ideas that are relatively boring in some other industry, culture, or environment.
  • College degree or certification.  To be clear, we are less interested in the specific degree than that it represents you push yourself to learn and you finish what you started.

 

If you are an experienced problem solver, call us.  If you are an experienced researcher that can develop and test hypotheses, call us.  If you are not afraid to push yourself to be better, call us.  Otherwise, it probably won’t work out.

 

If we have not convinced you to steer clear, we cannot wait to meet you.  Send your resume and cover letter to resume@miravistallc.com  

 

Comment Period Closing for CMS Competitive Bidding Proposal

March 25th, 2014

Andrea Stark

 

On February 26, 2014, CMS released a proposal to solicit public comment on how to apply the pricing and methodologies of the current competitive bidding programs to the remainder of the country. The proposal, located on the federal registry website, outlines the techniques being considered by CMS to adjust fee schedule payment amounts for DMEPOS items and services furnished in areas that are not included in the current competitive bidding programs. Among the considerations, CMS has explored the possible testing of a bundled payment system for certain items of DME which would completely transform the capped rental category as it is currently known.  The proposal puts a few ideas on the table and reiterates CMS’s intent to move forward with its expansion of the competitive bidding program by 2016. Providers have a unique opportunity to affect the outcome of this dialogue by submitting comments electronically via regulations.gov. As of 11:59 PM on March 24th, only 13 comments have been documented as received by CMS. It is vital that providers understand what is being proposed, contemplate the impact and provide feedback to CMS.

 

The electronic comment period for this proposal closes March 28th, 2014 at 11:59 PM ET.

 

Much to the dismay of the DME industry, the Competitive Bidding initiative is pushing forward with no signs of slowing down. To protect reimbursement as this moves forward, CMS must hear from the DME suppliers that will ultimately be impacted by these proposed changes.

 

Not sure what this proposal means for your business? 

Join the discussion as DME Consultant and Reimbursement Expert Andrea Stark dives into this proposal and discusses the major components during our March 27th webinar “CMS Sparks Conversation with DME – FTF, RAC Transition and Nationwide Competitive Bidding” at 3 PM ET. Register on  our website at http://www.miravistallc.com.

Newest FTF Development – Audits Begin for WOPD

March 7th, 2014

 

On December 3, 2013 CMS posted a clarification on the Face-to-Face rule that rattled the DME community.  The F2F rule, has effectively been divided into two major directives: 1) the requirement for a documented F2F within the six months prior to the written order, and 2) the requirement to secure a Written Order Prior to Delivery. CMS intends to enforce the Written Order Prior to Delivery for claims processed in January 2014.

 

Prior to the December announcement, enforcement of the Rule was delayed on two separate occasions.  The first was a three month delay in the enforcement from the original July 1, 2013 start date, and the second offered an unspecified delay of enforcement through an unspecified date in 2014.  However, on December 3rd, CMS came forward to indicate that only the F2F provisions were intended for delay and they never intended a delay for the WOPD requirement.  Amid several remaining unanswered questions, CMS and the MACs continue to move this portion of the directive forward.

 

As of February 18, 2014, we are beginning to see the first of what we except to be many audits as a result of this announcement.  The Jurisdiction C DME MAC posted a notice of a service-specific prepayment review of a number of HCPCS affected by the F2F rule:

 

  • E0607 – Home Blood Glucose Monitor
  • K0001 – Standard Manual Wheelchair
  • K0002 – Standard Hemi Manual Wheelchair
  • K0003 – Lightweight Manual Wheelchair
  • E0748 – Osteogenesis Stimulator
  • E2510 – Speech Generating Device
  • E2402 – Negative Pressure Wound Therapy Electrical Pump

 

This pre-payment review is an effort to verify compliance with the Face-to-Face provisions concerning the detailed written order prior to delivery (DWOPD) requirements.  Claims subjected to this audit will be developed for additional documentation including:

 

  • Written Order Prior to Delivery
  • Delivery Documentation
  • Pertinent patient records
  • Copy of the ABN if used

 

While this audit was announced by the Jurisdiction C DME MAC, we expect that the other MACs will be following suit in the days ahead.

 

Face-to-Face Clarifications Rattle DME Community

December 9th, 2013

Andrea Stark and Angela Hayden

 

A ground breaking clarification posted by the Centers for Medicaid and Medicare Services to the Face-to-Face Encounter home page on December 3rd, 2013, has sent providers reeling.  The clarification states “The delay of enforcement only applies to the face-to-face requirements in CFR §410.38(g)(3). CMS expects full compliance with the remaining portions of the regulation.” Earlier this year the final rule mandating Face-to-Face Encounters for select items of DME, affecting 166 HCPCS, indicated an effective date of July 1, 2013.  However, CMS issued a delay to October 1, 2013, and then further delayed enforcement until a date yet to be announced in 2014.  This rule not only requires that a face-to-face encounter with a physician, nurse practitioner, physician’s assistant or clinical nurse specialist take place and be documented within six months prior to the detailed written order, but an additional requirement also establishes the necessity to collect a Detailed Written Order prior to delivery (even in cases where a verbal or dispensing order had previously been sufficient).

 

CMS begun instructing contractors to educate providers on a few key expectations, notably that they are expecting DME providers to follow all of the written order prior to delivery requirements set forth in the rule (dating back to July 1, 2013).

 

We have discovered that behind the scenes, the Program Integrity Manual has already been updated in several key sections through Revision 468.  This revision cites it was: Issued: 05-31-13; was Effective 07-01-13; and has an Implementation of 07-01-13.  The Program Integrity Manual (PIM) is the instruction manual used by the auditing contractors to enforce Medicare policy.  These citations clearly state they are in effect and implemented as of July 1, 2013 which is quite troubling from a retroactive audit standpoint.  The following are brand new sections that detail CMS expectations about procurement of a written order prior to delivery for items subject to the face-to-face rule:  Section 5.2.3.2 Detailed Written Orders for Face-to-Face Encounter, 5.2.3.2.1 – Face-to-Face Encounter Conducted by the Physician, 5.2.3.2.2 – Face-to-Face Encounter Conducted by a Nurse Practitioner, and 5.2.3.2.3 – Detailed Written Order for Covered Items.

 

Another curveball popping up in education sessions from some of the DME MACs includes instructions that they expect providers to have signed medical record notes in hand before delivering equipment to comply with the rule (after the delay expires).  If CMS maintains this course, this interpretation will be particularly burdensome to physician practices that send all their documentation out for transcription prior to making the documents available.  The interpretation is also counter intuitive to several critical need products such as oxygen and other items on the list.

 

Providers and advocate agencies have been reaching out to specifically discuss the impossibility of a retroactive enforcement of these additional provisions due to the inextricable connected nature to the Face-to-Face provisions.  The industry has been told that a Med Learn Matters article is forthcoming, but we are hopeful we can come to a mutual understanding of the key issues prior to the release of formal education on these issues.  Uncertainty still remains regarding several key issues, however, as more information on this topic develops, MiraVista will continue to disseminate key updates.  Please see additional education on this topic on our blog and via our Products menu.

 

PECOS Edits Officially Coming in January – Will Your Claims Deny?

November 7th, 2013

Anglea Hayden

 

After nearly four years of operating under Phase I of the PECOS project, CMS has officially released the implementation date for Phase II edits via MLN Matters Article SE1305. Phase II was originally set to go into effect on May 1st of this year, however an eleventh hour delay published on April 29th pushed the implementation to an unspecified future date.  Medicare Contractors have now been officially instructed to deny claims that are linked to an ordering or referring physician that is not PECOS enrolled as of January 6, 2014.

 

DME providers have seen PECOS Phase I warning messages dating back to October 1, 2009, when the project was first initiated.   Providers initially received warning messages via claim status reports. Those warning messages were then migrated to the Medicare Remittances in the form of remark code N544 after the 5010 conversion, where they are currently still reported.  The N544 remark code is an indicator that future claims tied to the same non-PECOS enrolled ordering or referring physician will deny.  Once the edits take effect in January, these claims cannot be reprocessed until that physician is officially enrolled, and providers risk an unnecessary hold on reimbursement for these claims.

 

With the PECOS surrogate program now underway, providers have a better chance at getting busy physicians properly enrolled with PECOS to mitigate claim denials.  The surrogate program allows physicians to delegate the enrollment process to employees or third parties.  When working with overwhelmed referral sources, DME providers certainly understand just how valuable this tool can be.

 

While getting non-enrolled physicians to enroll in PECOS is an important part of the compliance process, most denials will be a result of non-matching records.  The PECOS Phase II edits require that the physician’s record match exactly to what is being submitted on the claim, which means that any typographical errors  in the spelling of the physician’s name, or transpositions of the NPI number within your records will cause the claim to deny.  Providers that have not already begun to scrub their files for these errors should do so immediately to ensure all records are clean prior to January 6, 2014.

 

The key to this process is to be proactive.  The majority of the denials that will result from the implementation of Phase II can be avoided by taking action now to scrub your physician records. Providers have enough uncertainty in the current market; don’t let the implementation of Phase II be another barrier between you and your Medicare reimbursement.

 

For more information on the steps to take to avoid claims denials and to better understand how the PECOS project will impact your business join us for our special webinar PECOS Revisited conducted by Reimbursement Consultant Andrea Stark on December 12, 2013 at 3pm (see details on registration here) or contact our office to schedule a consult with Andrea at 803-462-9959 ext. 246

 

CMS Releases SPAs for Round 1 Recompete

October 1st, 2013

Angela Hayden

 

The CBIC posted the newly released single payment amounts for the Round 1 Recompete on October 1st. As a part of the Competitive Bidding program CMS is required to “recompete” contracts at least once every three years. Round 1 of Competitive Bidding affects nine metropolitan areas. While it initially began with a false start, it was re-launched as the Round 1 Rebid program which officially took effect on January 1, 2011. The existing contracts under Round 1 Rebid will expire on December 31, 2013. With the announcement of payment rates for the next round of competition, CMS will take the next three months to establish contracts and educate providers before the Round 1 Recompete launches on January 1, 2014. A total of 16 products are affected by Round 1 Recompete which CMS has broken into six categories. Those products are:

  • Respiratory Equipment & Related Supplies & Accessories
    • Oxygen Equipment & Supplies
    • CPAP Equipment, Supplies & Accessories
    • Respiratory Assist Devices, Supplies & Accessories
    • Standard Nebulizers
  • Standard Mobility Equipment & Related Accessories
    • Walkers & Accessories
    • Standard Power Wheelchairs, Scooters & Accessories
    • Manual Wheelchairs & Accessories
  • General Home Equipment & Related Supplies & Accessories
    • Hospital Beds & Accessories
    • Group 1 & Group 2 Support Surfaces
    • TENS Units
    • Commode Chairs
    • Patient Lifts
    • Seat Lift Mechanisms
  • Enteral Nutrients, Equipment & Supplies
  • Negative Pressure Wound Therapy Pumps, Related Supplies & Accessories
  • External Infusion Pumps & Supplies

According to the release, single payment amounts for the Round 1 Recompete show an average reduction of 37% off of the traditional fee schedule amounts. However, specific product categories are seeing cuts as deep as 47% off of fee schedule amounts. The steepest reimbursement reduction appears to be in the general DME category for the Riverside-San Bernardino-Ontario CA Competitive Bidding Areas (CBA), where rates were cut by 56%. CMS did issue a breakdown of the number of contract offers they expect to award by CBA and product category which can be accessed here. Until the contract offers are formally accepted and fulfilled, we will not know who the contracted providers will be, the final number of awarded contracts and/or locations serving beneficiaries in these nine areas. If a provider declines a contract, CMS will extend offers to other eligible providers that did not make the initial cut.

 

MiraVista will continue to keep you posted as updates are announced. Be sure to sign up for our mailing list to catch breaking news updates!

 

Are You Prepared for the Final HIPAA “Omnibus” Rule Compliance Deadline?

September 12th, 2013

Maureen Bacon & Angela Hayden

 

Note:  This editorial is designed to give you an overview of several changes in the Final Rule which is 138 pages in its final form.  Information in this article should not be construed as legal advice.  For specific questions about how to interpret or implement official requirements within your organization, please consult the source document or contact a knowledgeable healthcare attorney.  For a more in-depth editorial on this ruling, see our most recent edition of VistaNotes available for purchase on our products page at: http://www.miravistallc.com/products.php.

 

The term “HIPAA Compliance” is very commonplace in our industry.  HIPAA, is the acronym for the Health Insurance Portability and Accountability Act of 1996.  This rule included provisions that require the Department of Health and Human Services (HHS) to improve the efficiency and effectiveness of the health care system and to set national standards for the security and privacy of individually identifiable Protected Health Information (PHI). On January 25, 2013 HHS issued a new Final Rule that modifies previous rules1.  The Final Rule wraps all of the previous rules into one, and provides reference to all the parts of the original rules that providers must continue to follow.  The final rule, appropriately deemed the Final “Omnibus” Rule, became effective on March 26, 2013 and established a compliance period of 180 days, making September 23, 2013, the ultimate deadline for compliance.

 

If this is the first time you are hearing about this new “Omnibus” Rule, you are not alone. The Competitive Bidding and National Mail Order initiatives have taken center stage in our industry, and this updated ruling has flown largely under the radar.  In the Final Rule, any entity that is involved in the transmission of any PHI in electronic form is considered to be either a (1) Covered Entity (CE), (2) business associate (BA) of a covered entity, or (3) subcontractor of a business associate (SubBA). This classification system breaks down the relationship of businesses involved in the transmission of PHI and how PHI should be handled between entities.  Companies that create, receive, maintain or transmit protected health information on behalf of a covered entity are now considered business associates under the new federal regulations and are now subject to business associate agreements regardless of their status as a CE, BA or SubBA. Additionally, all business associate agreements must meet the compliance regulations described within the rule.  Providers that have business associate agreements executed prior to January 25, 2013, will need to amend those agreements before September 22, 2014 in order to become compliant.  Any new business associate agreements executed on or after January 25, 2013, should be replaced with new compliant agreements on or before September 23, 2013

 

Two of the most significant changes to the rule that providers should take note of relate to the definition of what constitutes a “breach” and an update to the breach notification process.  Previously, an “incident” was considered a breach that required written notification only if the PHI disclosed was unsecured or identifiable and the risk of “harm” was great.  The new final rule mandates that providers must perform a risk assessment that now more objectively determines a breach’s risk of “compromise”. The four factors of the risk assessment are: (1) To whom the disclosure was impermissibly made, (2) Whether the PHI was actually accessed or viewed, (3) Whether or not the recipient could identify the subjects of the data, and (4) Whether the recipient took appropriate mitigating action.  As a result, we will likely see many more instances of breach that require written notifications.  

 

Providers are also faced with changes regarding the Marketing, Fundraising and Sale of PHI.  Through this final rule, new limits have been set on how information can be used and disclosed for marketing and fundraising purposes. Additionally, the final rule states that the sale of an individual’s PHI is now prohibited without their express permission. 

 

One of the more labor intensive burdens placed by the final rule requires providers to revise their internal training and procedures to reflect compliance with the modifications.   This involves updating existing HIPAA Authorizations and Forms to adhere to these new requirements.

 

Providers should note that this article only scratches the surface of the complexities within this Final “Omnibus” Rule. We encourage readers to seek additional information on the Health and Human Services website https://www.hhs.gov for the details of this rule and how it will impact their business.

 

1Security (Security and Electronic Signature Standards) Proposed Rule – published in 1998

HIPAA Privacy Rule – proposed 1999

Final Privacy Rule – released 2000

Final HIPAA Security Rule – published 2003

Genetic Information Nondiscrimination Act (GINA) – signed into law 05/21/2008

Breach Notification Final Rule – published 2009

Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as a part of the American Recovery and Reinvestment Act of 2009 – signed into law 02/17/2009

Final HITECH Rule – became effective 11/30/2009


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