Billing Alert

Nursing Homes, Nov, 2004

Q: Our business office manager and accounts receivable employee ask a lot of questions about the care and treatment of individual residents--more than necessary for billing purposes. Both seem to think they should have access to all resident information. How much information do they need for financial purposes, and what information would be a violation of HIPAA?

A: The amount of protected health information (PHI) your staff is using, disclosing, or requesting is subject to the minimum necessary provision of the HIPAA regulations. Based on this provision, your facility must determine what PHI is necessary for your staff to carry out their job functions. Use common sense. For example, if someone on your staff is responsible for determining the appropriate ICD-9 codes for billing claims, that staff member will need access to the resident's complete medical record to accomplish that task. Your collections staff should never have access to medical records because their tasks only require the information typically found on the resident's admission paperwork, commonly called the resident face sheet. This data includes the responsible party, addresses, phone numbers, and insurance information. Determine by job function what PHI your staff need to know to carry out their duties. Make a reasonable effort to limit PHI access to the minimum necessary to accomplish the intended purpose of the use, disclosure, or request.

From Billing Alert for Long-Term Care by Lee Heinbaugh, consultant, PMG, LLC (Cleveland), published by HCPro, Inc. (www.hcpro.com). Nursing Homes/Long Term Care Management bears no responsibility for the opinions/advice contained herein.