Catholic Health Welcome to the first part of your orientation to Catholic Health. Please review the following slides. If you have questions regarding the material please bring them up when you attend you in class general orientation session. Catholic Health Corporate Compliance Anne Mason Compliance & Privacy Officer Principles of Corporate Compliance • • • • • Promotes Ethical, Professional, and Legal conduct “Doing what is right” Defines Responsibility/Accountability Supports CHS Standards Assurance of Quality Care Catholic Health System Standards Attain Compliance by: • Embracing our Mission and Values • Adherence to Policy and Procedures Found in Compliance 360 • Maintaining High Standards of Business and Ethical Conduct Important Keys to CHS Corporate Compliance Standards of Conduct Deal openly and honestly with others Maintain high standards of conduct in accordance to the CHS mission, directives of the Catholic Church, and applicable federal, state and local laws and regulations Conflict of Interest We have a responsibility to act on the best interests of Catholic Health. We need to avoid situations that lead to actual or perceived conflicts of interest Documentation and Billing Must be accurate and complete Catholic Health System Standards of Conduct Associate Compliance Guidebook provides information on the Standards of Conduct and is available on CHS website An observation of failure to follow Standard of Conduct, Policy or Procedures, or observation of an error requires reporting. Associates can face disciplinary action and even termination for failure to report such events. Catholic Health System Standards of Conduct All associates are expected to follow standards for: • Legal and Regulatory Compliance • Business Ethics • Conflict of Interest • Appropriate Use of Resources • Confidentiality • Professional Conduct • Responsibility And follow the Code of Ethics Gifts and other Free items • Associates may NOT accept any cash gifts or cash equivalent gifts (gift cards) from any person or business conducting or seeking to conduct business with CHS • Prior to receiving work related gifts, social or entertainment events, or free meals associates must consult with their supervisor. See CHS Policy for further information Conflict of Interest If working on behalf of CHS do your actions or activities result in personal gain or advantage, potential adverse effect for CHS, or the potential to interfere with professional judgment, objectivity or ethical responsibilities? Potential Conflicts of Interest Relationships include financial relationship for yourself or your immediate family member or secondary employment – Consultant – Speakers’ bureau – Advisory Panel – Administrative positions with Pharm or DME – Third party payor – Other entities doing business with CHS All potential Conflicts of Interest must be reported Insufficient or Inaccurate Documentation It is fraudulent to either document services that were not performed or to submit claims for services without appropriately documenting those services. • • • Missing clinical notes (dates, signatures, orders, care or service rendered) or test results Incomplete, or illegible documents Improper billing and coding can be interpreted as fraud or abuse and lead to a false claim with the government resulting in penalties. Reimbursement can only be sought for services or items that have been provided and appropriately documented. If it’s not documented, it’s not done False Claims Act Governs Fraud, Waste & Abuse It is a crime to knowingly make a false record, file, or submit a false claim with the government for payment A false claim can include billing for service that: • • • • was not provided or documented not ordered by a physician was of substandard quality Improperly coded or billed It is also unlawful to improperly retain overpayments Allows for Qui Tam Relator –notification to government with protection (Whistleblower provision) Medicare Conditions of Participation Government Sanctions • Individuals or entities can be excluded from participation in Medicare and Medicaid programs. • CHS must not submit any claims to Medicare and/or Medicaid in which a sanctioned individual or entity provided care or services. • If sanctioned, the person must provide notification immediately to the Compliance Officer. Providing High Quality Services and Upholding Patient’s Rights • Follow CHS Policies and Procedures • Offer Language Assistance Services to those in need • Ensure patient privacy and confidentiality is maintained (HIPAA and HITECH regulations) Catholic Health Compliance Policies Compliance Policies and Procedures are available on Compliance 360 (or in an on-site reference manual) and apply to all CHS associates Additional compliance policies are also applicable to: – – – – – – – Home Care Clinical Laboratory Physician Practices Nursing Facilities Coding & Billing Home Health Agency PACE Program Language Assistance Program • Ensures that limited English proficiency, or hearing impaired persons utilizing CHS services are able to understand and communicate with CHS associates and physicians • Provided FREE of charge to the patient Language Assistance Program Policy is found in Compliance 360 Language Assistance Program • • • • Mandatory service by law Family may NOT routinely interpret Offered upon initial contact AND every time medical information is provided Documentation is vital to compliance See Policy for additional information HIPAA/ HITECH HEALTH INSURANCE PORTABILITY ACCOUNTABILITY ACT and HITECH Health Information Technology for Economic and Clinical Health Act Privacy and Security Policies are in Compliance 360 What is Protected by HIPAA? Individually identifiable health information Also known as Protected Health Information (PHI) Transmitted or maintained in any form or medium Protected Health Information (PHI) Names Full face photos Medical Record Number Health plan Number Account Numbers Certificate/License Numbers Vehicle identifiers E-mail and web addresses Biometric Identifiers Geographic subdivisions smaller than a state All elements of dates related to birth date, admission, discharge, or date of death, ages over 89 Telephone and fax numbers Social Security Number Any other unique identifying data What Information Can Providers Share? for: Treatment, Payment or Health Care Operations • Only access portions of PHI necessary to carry out your duties or to fulfill request • Disclose minimum necessary for your job function based on need for the information • If unable to obtain patient consent, may use professional judgment to share information with a patient’s family and friends HIPAA Safeguards • Be aware of surroundings – Be conscious of who is in the immediate area when discussing sensitive patient information or at your computer terminal • Secure area when not attended – Close out of computer screens containing PHI before leaving the area – Close medical records/chart when not in use – Do not allow other associates to utilize your ID and password – Don’t leave papers with PHI in plain view – Report theft or loss of computer devices immediately Additional HIPAA Safeguards • Telephones - Be careful with phone call pertaining to patient information • Fax machines and Scanners - Pick up faxed or printed PHI immediately - Use fax cover sheet, verify # & receipt - Scan PHI only to CHS e-mail accounts • E-mail - Make sure to encrypt if being sent outside CHS - Careful forwarding and replying • Mail - Double check name/address and material prior to sending Sending e-mail with Sensitive Information All e-mails sent to a CHS web address are encrypted and therefore secure. Each e-mail sent outside the CHS system, will need to be encrypted if it contains sensitive information. For instructions on a sending external encrypted email type “encryption” in the search box of Compliance 360. UNAUTHORIZED ACCESSING AND DISCLOSURE OF PATIENT INFORMATION Curiosity can be a normal human trait – However accessing health information on yourself, family members, friends, co-workers, persons of public interest or any others that you are not involved in the care of or … – Disclosing PHI inappropriately are...VIOLATIONS of HIPAA Individuals do NOT have the right to look up their own health records Your computer use can be monitored Other Catholic Health Compliance Concerns • • • • • • • • • • • Lack of integrity Ethical concerns Theft or misuse of services Improper Political Activity Breech of Corporate Confidentiality Improper use of Proprietary Info. Environmental Health and Safety Issues Dishonest Communication (spoken or documents) Improper Business Arrangements Failure to follow Record Retention policy Receipt of incentives for patient referrals The Associate Guidebook or your supervisor can provide additional info. 3 Steps for Reporting CH Compliance Concerns Immediate supervisor or appropriate department Higher level manager Compliance Officer Compliance Line 1-888-200-5380 available 24/7 Confidential and Anonymous (if desired) Report behavior issues, HR policy violations, and union contract matters to Human Resources Catholic Health Non-Retaliation Policy • Protects associates from adverse action when they do the right thing and report a genuine concern • Reckless or intentional false accusations by CHS associates are prohibited • Reporting the possible violation does not protect the constituent from the consequences of their own violation or misconduct Associates have a duty to report HIPAA/Compliance concerns Catholic Health Associate’s Responsibility • Upholding CHS Mission and Values, Adhering to Code of Conduct, Policies & Procedures, and the Law • Completing education and employment requirements • Constant Monitoring for Concerns • Duty to Report Concerns and Support Non-retaliation • During an Investigation o o be truthful preserve documentation or records relevant to ongoing investigations Possible Consequences for Non-Compliance For the Associate and CHS Managers/Supervisors/Administrators • Fines and Prison sentences • Corrective Action includes termination of employment for violations or failure to report concerns For Catholic Health System • Exclusion from government funded insurance programs (Medicare/Medicaid) • Fines Things to Remember • Adhere to CHS code of conduct, policies & procedures, and other standards • Duty to report Compliance/HIPAA concerns as soon as aware of situation • Do the right thing apply ethical decision making • If uncertain… Always Seek Knowledge (A.S.K.) Use Associate Booklet as reference on CHS website CHS Contacts Compliance/HIPAA Privacy Officer Anne Mason 821-4469 CHS HIPAA Hotline 862-1790 HIPAA Security Analyst Sally O’Brien 862-1938 Corporate Compliance Hotline 1-888-200-5380 (available 24/7) All reports are confidential New York State Patient Bill Of Rights 19 Bill of Rights They are posted in all patient care areas They are available in Spanish as well as English If they don’t understand their rights, someone needs to explain them Receive treatment without discrimination Receive considerate and respectful care in a clean safe environment free from unnecessary restraints Receive needed emergency care Know the names and positions of people caring for them, and refuse their treatment Know who the MD is who is in charge of your hospital care A non smoking room Receive complete information about their diagnosis, treatment and progress Receive all information for informed consent Receive all information to give informed consent regarding do not resuscitate Refuse treatment and be informed of effect Refuse to take part in research Privacy in the hospital and confidentiality of all information and records of your care Participate in decision making about their care, including discharge Review of their medical record Receive an itemized bill with explanation of charges Complain without fear of reprisal Authorize family members to visit Make known your wished regarding anatomical gifts Catholic Health RISK MANAGEMENT What is “Risk Management”? Risk Management is the systematic review of events that present a potential for harm and could result in loss for the system. FOUR ELEMENTS OF RISK MANAGEMENT Risk Identification Review Occurrence Reports Review Patient/Visitor Complaints Participate in Root Cause Analysis Review concerns expressed by CHS staff FOUR ELEMENTS OF RISK MANAGEMENT Loss Prevention Educational Programs through CHS University Department specific inservices FOUR ELEMENTS OF RISK MANAGEMENT Claims Management Investigating & reporting occurrences and claims made to insurance carriers Assist with discovery requests for lawsuits Claims Management Assist with Summons & Complaints and Subpoenas **NOTIFY RISK MANAGEMENT IMMEDIATELY UPON RECEIPT OF A SUMMONS OR SUBPOENA Claims Management Within CHS, a process server is to be directed to Administration of the facility in order to serve a Summons or a Subpoena. (HIM may accept subpoenas for hospital records) ***INDIVIDUAL DEPARTMENTS SHOULD NOT ACCEPT, EVEN IF IT IS FOR SOMEONE IN THE DEPT FOUR ELEMENTS OF RISK MANAGEMENT Risk Financing Obtaining & maintaining appropriate insurance coverage: HPL (Healthcare Professional Liability) GL (General Liability) D&O (Directors & Officers) Property & Casualty Auto Crime Fiduciary (Finance) OCCURRENCE REPORTING An occurrence is an event that was unplanned, unexpected and unrelated to the natural course of a patient’s disease process or routine care and treatment. What are sources of an Occurrence? Patient harm/potential for harm like falls, med errors Visitor injury Patient related equipment “failure” What are sources of an Occurrence? Security issues like elopement, crime, altercations Lost or damaged property What is the purpose of an Occurrence Report? Enhance the quality of patient care Assist in providing a safe environment Quick notice of potential liability Who can complete an Occurrence Report? Any associate or physician who discovers, witnesses or to whom an occurrence is reported, is responsible for documenting the event immediately by means of the Occurrence Report. Anyone who requires assistance should contact the department manager. DO NOT MAKE COPIES OF AN OCCURRENCE REPORT What happens to the Occurrence Report? The completed Occurrence Report is to be forwarded to the Department Manager Who will investigate the occurrence and forward to either Quality & Patient Safety Dept or Security as indicated in the Risk Management process Risk Management Process Patient and visitor safety are assessed from both clinical and environmental perspectives Notify Quality & Patient Safety of patient occurrences Notify Security of visitor or property occurrences Risk Management will be notified by QPS or Security and will participate in evaluation of occurrence Risk Management will report occurrences to insurance carrier in cases of potential liability Risk Management will manage claim as indicated Documenting an Occurrence in the medical record •Date (MM/DD/YY) and time (military) •State facts, be clear and concise •Your own observations •If event described to writer, use quotes or “according to…” •Do not place blame in the record •DO NOT REFER TO OCCURRENCE REPORT IN THE MEDICAL RECORD EMTALA REGULATIONS EMTALA is the Emergency Medical Treatment and Active Labor Act (aka COBRA) EMTALA provides a Guideline for safely and appropriately transferring patients in accordance with Federal regulations. EMTALA REGULATIONS The law provides for a medical screening exam (MSE) to all individuals seeking emergency services on hospital property. Hospital property includes the driveway, parking lot, lobby, waiting rooms and areas within 250 yards of the facility. If an emergency medical condition is found, it will be stabilized within the hospital’s ability to do so, prior to the patient’s transfer or discharge. If a patient does not have an emergency medical condition, EMTALA does not apply. *** IMPORTANT: NEVER SUGGEST THAT A PATIENT GO ELSEWHERE FOR TREATMENT IDENTITY THEFT Fair and Accurate Credit Transactions Act of 2003 or “RED Flag Rules” Hospitals that maintain covered accounts must develop and implement written policies and procedures to identify, detect, prevent, and mitigate identity theft. IDENTITY THEFT “RED FLAGS” •Alerts, Notifications, Warnings •Presentation of Suspicious information •Suspicious Activity •Notice from patient, law enforcement, etc **Patient Access, Health Information, Finance, IT Depts primarily involved IDENTITY THEFT You can help reduce opportunities for Identity Theft by keeping PHI confidential and out of public view. If you believe someone is presenting suspicious documents or acting in a suspicious manner, notify your supervisor who will notify Risk Management Catholic Health RISK MANAGEMENT DEPARTMENT Carol Ahrens, RN, BSN Director, Risk Management 821-4462 Joanne Ricotta, RN, BSN Risk Management Coordinator 821-4463 Linda McGavin Risk Management Technical Assistant 821-4467 Valerie Pizarro Legal Services Administrative Assistant 821-4468 Violence in the Workplace What is Workplace Violence?? NIOSH (National Institute for Occupational Safety and Health) defines workplace violence as violent acts (including physical assaults and threats of assaults) directed toward persons at work or on duty. Types of Violent Acts Threats: Expressions of intent to cause harm, including verbal threats, threatening body language, and written threats. Physical assaults: Attacks ranging from slapping and beating to rape, homicide, and use of weapons such as firearms, bombs, or knives. Muggings: Aggravated assaults, usually conducted by surprise and with intent to rob. Who is Violent? Workplace violence in hospitals usually results from patients and occasionally from family members who feel frustrated, vulnerable, and out of control. When Does Violence occur? Violence takes place – During times of high activity such as meal time or visiting hours or patient transportation – When service is denied – When a patient is involuntarily admitted – When limits are set regarding eating, drinking, tobacco or alcohol use Who is at Risk?? Hospital personnel having direct contact with patients and families are at increased risk. Case Reports An elderly patient verbally abused a nurse and pulled her hair when she prevented him from leaving the hospital to go home in the middle of the night. An agitated psychotic patient attacked a nurse, broke her arm, and scratched and bruised her. A disturbed family member whose father had died in surgery walked into the E.D. and fired a handgun, killing a nurse and an EMT and wounding a physician. Where May Violence Occur?? Anywhere in the hospital but it is most frequent in the following areas: – Psychiatric wards – Emergency rooms – Waiting areas – Geriatric units What are the Effects of Violence?? Effects range in intensity and may include: – Minor physical injuries – Serious Physical injuries – Temporary and permanent physical disabilities – Psychological trauma – Death Effects of Violence Violence can have a negative effect on an organization as reflected by: – Low morale – Increased job stress – Increased worker turnover – Reduced trust of management or co-workers – Hostile working environment Risk Factors Contact with violent people or those with history of violence Contact with those under the influence of drugs and/or alcohol Contact with people having psychotic diagnoses Contact while transporting patients Contact with people perceiving a long wait for service Working alone Safety Tips Watch for signals of impending violence: – Verbally expressed anger and frustration – Body language such as threatening gestures – Signs of drug or alcohol use – Presence of weapons Be Alert Assess current demeanor when you enter a room or begin to relate to a patient or visitor Be vigilant throughout the encounter Don’t isolate yourself with a potentially violent person Keep an open path for exiting Diffusing Anger Present a calm, caring attitude Don’t match the threats Avoid giving commands Acknowledge a person’s feelings Avoid behavior that may be interpreted as aggressive If potential for violence occurs Remove yourself from the situation Call security for HELP if needed Report any potential or actual violent incidents to dept manager Summary No universal strategy exists to prevent violence All hospital workers should be alert and cautious when interacting with patients and visitors Staff need to be aware of polices and procedures relating to violence prevention ‘The process of transforming CHS into an organization with a superior ability to deliver patient-centered, quality, compassionate healthcare through outstanding professionals and innovative technology.’ Welcome to Equinox Equinox - Why? Individual Hospitals – “grew-up” with their own process, culture, technology Need for Electronic Health Record (EHR) Improve Quality Enhance Patient Safety Equinox – How? Comprehensive effort to standardize and improve processes Standardized Clinical Practices New and innovative technology like Soarian Welcome to Equinox Equinox - When? Now! Process started in 2004 and is ongoing Strategic Alliance with Siemens Medical Solutions – 10 year agreement Drive toward “meaningful use” of EHR Equinox – Who? Everyone – directly and indirectly! Welcome to Equinox Examples of Equinox in Action: Soarian Clinical Technologies Clinical Standardization Process Financial Process Redesign Mercy Hospital Emergency Center Process – New triage/registration Culture – Patient-centered focus Technology – Computers at the bedside, integrated wireless communication Welcome to Equinox Your Role… Stay informed Ask questions Identify ways to “do it better” always with the patient in mind Embrace change! Welcome to Equinox Questions - contact…. EQInfo@CHSBuffalo.org Catholic Health System General Orientation Level 1 Quality and Patient Safety What is Performance Improvement? It is a Focused approach to identify, evaluate and improve strategic clinical processes to realize our overall goals of improving patient safety and clinical outcomes What does Catholic Health Focus on? Strategic “Dashboard” Categories Include: • Patient Satisfaction (e.g. willingness to recommend, overall rate of experience etc.) • Patient Safety Indicators (Healthcare Acquired MRSA, Central Line infections, Medication Reconciliation, Restraints…) • Publicly Reported Indicators (30 day Mortality Rates – AMI, HF,AMI, Pneumonia, Surgical Care Infection Prevention) • Quality Incentive Indicators (Reduction of Unreconciled Medications, Avoidable Delays) What does Catholic Health Focus on? 2008 CHS ACUTE Quality Indicators Updated November 24, 2008 - Improved from New for 2008 AVERAGE SEVERITY RATE (All Ocurrences) 51% AVG HARM EVENTS (7,8, & 9) PER MO 176% Q PATIENT SATISFACTION - WOULD YOU RECOMMEND AMI PERFECT CARE Q 93% 83% 86% 1.00 0.50 MORTALITY RATE = 2.36% (Northeast Comparison @ 25Th%) 89% CORE MEASURES PNEUMONIA PERFECT CARE 0.00 76% Q -0.50 RELATED RE-ADMISSION RATE 102% 1.50 79% - No change from previous month HEART FAILURE PERFECT CARE Q RAPID RESPONSE TEAM RATE 155% CLINICAL PATIENT SAFETY OVERALL PATIENT SATISFACTION New for 2008 previous month - Declined from previous month PATIENT SATISFACTION SCIP 1-2-3, VTE 1 & 2 PERFECT CARE Q 79% Q 108%UNRECONCILED MEDICATIONS HAND HYGIENE 76% New for 2008 HEALTHCARE ACQUIRED MRSA INFECTIONS (per 1,000 patient days) 97% VENTILATOR ASSOCIATED PNEUMONIA (per 1,000 vent days) 98% 91% CENTRAL LINE INFECTIONS ( per 1,000 line days) RESTRAINTS (excludes Critical Care) SURGICAL SITE INFECTIONS - NYSDOH - Class 1-4 (Hips,CABG, Colon) New for 2008 PRESSURE ULCERS 148% 92% 71% Solid Line Represents Target Outside Solid Line - GOOD! Better than target Inside Solid Line - VARIANCE! Not meeting target Note: Q - Included in 2008 Quality Incentives Culture of Safety At CHS we believe that the patients and associates safety are our main concern. As a result we have focused our efforts to strengthen our Culture of Safety with the ultimate goal of eliminating medical errors to our patients and injuries to our associates. How? By raising our expectations of our Board, Leaders, Physicians and Associates. We expect every ASSOCIATE, LEADER and PHYSICIAN to: Pay Attention To Details Communicate Clearly and Directly & Perform Effective Handoffs Have a Questioning Attitude Work Together With Your Team Follow the Rules Additional Patient Safety Initiatives: National Patient Safety Goals The Catholic Health System fully endorses and supports the Joint Commission (JC) standards wherein any employee who has concerns about the safety or quality of care provided in the hospital may report these concerns to the JC. Furthermore, CHS demonstrates it’s commitment by taking no disciplinary action against any associate who reports a safety or quality of care concern to the JC. Any employee can also feel free to report these concerns to the Quality and Patient Safety Department in their facility INFECTION CONTROL Infection Control 2010 Infection Prevention is everyone’s responsibility ! Together we can prevent and reduce the risk of infection in healthcare for our patients, associates, families and visitors. 86 Infection Control The Infection Control Program is designed with prevention in mind… Compliance and guidance is primarily from these agencies: • New York State Department of Health • Center for Disease Control • Occupational Health and Safety • Joint Commission 87 Infection Control How are infections transmitted? • Dependent on the type of infection Respiratory infections are transmitted through coughing, sneezing and talking by someone who is ill. Other infections may occur from: • Direct skin to skin contact • Contaminated inanimate objects A strong immune system is extremely important in keeping healthy. 88 Infection Control INFLUENZA • Transmitted through respiratory secretions • Includes seasonal, H1N1 and others • Practice respiratory etiquette and hand hygiene • Meticulous hand hygiene 89 Infection Control HANDWASHING Traditional Hand Washing Use running water and soap. Remember to keep the water temperature comfortable. 15-20 seconds is needed for effective Hand washing. Sing “Happy Birthday”!! Apply friction to all surfaces. Rinse and dry; turn off faucets with a paper towel. THAT’S IT!!! Hand Hygiene Waterless Hand Sanitizer is available and is just as effective as soap and water except when taking care of patients with C-diff. Waterless Hand Sanitizer dispensers are conveniently located throughout the building. Waterless Hand Sanitizer should not be used when your hands are visibly soiled because you need the mechanics of hand washing. * Artificial fingernails of any sort are not to be worn in the clinical areas. 90 Infection Control 91 Infection Control ASSOCIATE HEALTH • Associates should not work while ill • Prior to returning to work after illness, associates must be ever free for 24hrs and off antipyretics • Annual Health Assessment/PPD • Obtain vaccines (eg. Influenza, Hepatitis B) • Report any potential communicable illness exposure (eg. Chicken Pox) for appropriate guidance 92 Infection Control EMERGENCY PREPAREDNESS Two Plans: • Pandemic Influenza • Bioterrorism Both are addendums to the Emergency Management Plan • Information available at: •Compliance360/Emergency Management /Surge Capacity 93 Infection Control Click on the Bug… Easy as 1, 2, 3!!!!! 1. Open Internet Explorer 2. Click on Favorites / CH Enterprise Links / Click on the Bug 3. Right click and Create Shortcut for easy desktop access! 94 Infection Control Hand Hygiene Hand washing Hand Sanitizer Foam in Foam out Gel in Gel out Before and after every patient contact Before donning and after removing gloves 95 Infection Control Additional prevention strategies** exist for : Ventilator associated pneumonia Central line bloodstream infection Surgical site infection Catheter associated urinary tract infection **Please consult with nursing education or the infection control department 96