Part of the benefit of using an Agency Management Platform is that it allows workflows and data submission to payers, including state Medicaid, to happen inside of the platform.  All documentation and billing that would historically have to be submitted by snail mail and have an actual written signature can be managed electronically, including digital signatures. In order for any agency management platform to be useful, it must follow the digital signature guidelines that are prescribed in the Health Insurance Portability and Accountability Act (HIPAA). All 50 states accept digital signatures, as long as they follow the law.

Below is the definition and parameters of electronic signatures direct from the Centers for Medicare and Medicaid Services:

 

What Is an Electronic Signature?

There are several definitions to clarify.

• A digitized signature is an image of a pen-to-paper signature.

• An electronic signature can be an electronic sound, symbol, or process associated with a record. It is a mark added to a document to indicate intent to sign.

• A digital signature is a form of encryption that tightly binds documents to a unique number or electronic "fingerprint." Private companies called certification authorities provide private/public software key combinations used to encrypt and decrypt documents, and they issue "certificates" to bind the public keys to the key holders. However, certification business practice lacks national governance guidelines.

Electronic signatures are legally valid in all 50 states, and the security standards of electronic signatures are addressed in the security and privacy provision of the Health Insurance Portability and Accountability Act (HIPAA).

HIPAA transactions do not require a digital signature at this time. However, HIPAA-covered entities that use electronic signatures for transactions must adhere to U.S. Department of Health and Human Services electronic signature standards. The software program must provide:

• Nonrepudiation - assurance that the signer cannot deny signing the document in the future,

• User authentication - verification of the signer's identity at the time the signature was generated, and

• Message integrity - certainty that the document has not been altered since it was signed.

To learn more about the measures MediSked takes to ensure digital signatures and access security are to the highest standards, please click here. By accepting the terms and agreements and logging in using your unique username and password, you have confirmed electronically who you are. Digital signatures are used throughout the workflow in MediSked Connect. Not only are they used to approve a note, plan or when making an observation, but also anytime a change is made. It is very easy to see the history of a note or plan as changes are made and kept in the record of the document.

It’s no secret that every state Medicaid system has a unique set of requirements for documentation and billing of waiver services. It is a cumbersome process to follow the requirements and stay abreast of any changes to remain in compliance at all times. For this very reason, MediSked has a dedicated Compliance Department. Their job is to monitor and be experts in the requirements for documentation in every state that our customers operate in.

Through our platform, a Compliance Pack is installed for every customer that is specific to their state’s requirements. This ensures that all of the documentation matches requirements and is accepted by your state. Updates are made to the Compliance Pack as state requirements change.This is a managed process on our end that essentially doesn’t require any work on our customers’ end to stay compliant.  Our Compliance Department is a huge asset to our customers and a key to an Agency Management Platform.

SUMMARY OF FINDINGS

 

DOH claimed Federal Medicaid reimbursement for some OPWDD waiver program services provided by New York City providers that did not comply with certain Federal and State requirements. Of the 100 beneficiary-months in our random sample, DOH properly claimed Medicaid reimbursement for OPWDD waiver program services during 86 beneficiary-months. However, DOH claimed Medicaid reimbursement for services that did not comply with certain Federal and State requirements for the remaining 14 beneficiary-months.

 

Of the 14 beneficiary-months with services for which DOH improperly claimed Medicaid reimbursement, 2 contained more than 1 deficiency:

• For 6 beneficiary-months, DOH claimed reimbursement for service units billed that exceeded service units provided.

 

• For 4 beneficiary-months, DOH claimed reimbursement for OPWDD waiver program services that were not supported by adequate documentation.

 

• For 3 beneficiary-months, DOH claimed reimbursement for OPWDD waiver program services that were not provided.

 

• For 3 beneficiary-months, DOH claimed reimbursement for services that were not provided pursuant to a written plan of care.

 

The claims for unallowable services were made because DOH and OPWDD’s policies and procedures for overseeing and administering the waiver program were not adequate to ensure that (1) providers claimed reimbursement only for services actually provided and maintained all the required documentation to support services billed and (2) OPWDD waiver program services were provided only to beneficiaries pursuant to written plans of care.

 

Based on our sample results, we estimate that DOH improperly claimed $7,772,807 in Federal Medicaid reimbursement for OPWDD waiver program services during calendar years 2006 through 2008.



RECOMMENDATIONS

 

We recommend that DOH:

• refund $7,772,807 to the Federal Government and

 

Link:

http://oig.hhs.gov/oas/reports/region2/21001027.pdf

In the search for the best software solution, provider agencies regularly come across EMR (Electronic Medical Record) and EHR (Electronic Health Record) systems. For most agencies, EMRs are not the best fit based on the types of services that make up the bulk of agency offerings. An Agency Management Platform (AMP) is a better choice in most cases. Below is a quick guide to understand the difference between EMRs and AMPs.

 

-Clinical in Nature. EMRs are not intended for the unique requirements of a waiver provider agency. Instead it is for more clinical agencies. Most EMRs are off the shelf, which means that it is intended to be used as-is, without a lot of modifications. A typical provider agency would have to make many modifications based on their unique workflows and demands.

 

-Episodes of Care. EMRs are a system that’s based on a workflow that clearly has a beginning, middle and end. It is clinical by nature, so the focus is on records management and the creation and documentation of patient assessments and treatment plans on the front end. The work flow clearly follows a path that an agency would treat the “patient” and eventually discharge them. In fact most have a module called Discharge and Transfer Management. We all know that with an Agency Management Platform, the workflow is about providing a lifetime of service and support to the individuals they serve. Goal plans and service notes replace assessments and treatments and managing employees to help individuals reach fulfilled lives are what is important in our system. The bottom line: a provider agency would have a bunch of modules and workflows that have no relevance to them or they would have to change some of their processes to fit the system- which is risky and costly.

 

-Disconnected schedules and shifts. Because EMRs are not targeted to provider agencies, they don’t treat their schedules or appointments, clients, employees and service programs in the same capacity as an AMP. Most have schedules that seem more like an Outlook calendar where you can schedule “events” with a client similar to scheduling a meeting in Outlook but those “events” don’t bring billable hours, service notes, and pay rates together. With most EMRs, it seems like everything is floating on its own, whereas AMPs tightly integrate everything through its platform to ensure tight audit controls, premium service delivery, and trackable payroll and billing information. Most don’t mention anything about error free scheduling- the ability to eliminate double bookings or unqualified staff which an AMP schedule engine does. This goes back to the fact that the average clinical agency that an EMR is serving does not have the home and community based schedules that a provider agency has.

 

-Not focused on waiver specific compliance. Another big piece of an Agency Management Platform is the compliance packs that come standard. So an agency using an AMP is always in compliance with all federal, state and local requirements automatically. Both from a billing and documentation standpoint. This is huge for Medicaid supported services, which is our focus. That is not a focus with EMRs.

 

-Paying for irrelevant functionality. There are some similar functionalities when it comes to certain things like their billing – both EMRs and AMPs integrate with general ledger and payroll software, reporting, HIPAA security measures, we’re also SureScripts certified for e-prescribing. EMRs are more medically slanted, which doesn’t really benefit most provider agencies and it definitely takes the cost of a much higher. Both offer medications management but it’s not a focus for us or most of our customers.

 

Ultimately, most EMRs are geared for agencies that deal with episodes of care that have a beginning and an end. Agency Management Platforms are completely built around supporting agencies that provide a continuum, or lifetime, of care. That affects the functionality and purpose of the software as explained above.