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OkHIMA September 2017 Newsletter

Please check out this month's newsletter!

Inside this Issue:

Summary of the initial OHCA Provider Letter dated 7/31/17 -Important Changes to Signature Requirements – Effective 9/1/17

Signature requirements policy of OAC 317:30-3-4.1(1) (E) & 317:30-3-30(b) are revised to clarify that all medical records that substantiate, or could be used to substantiate, the provision of Medicaid-reimbursed services must be authenticated within (3) days of the underlying service. Authentication must, at the very least, include the provider’s signature and the date of his or her signature ID.  
  • “Days” will be interpreted by OHCA staff to mean standard business days.As a result, days will not include weekends (Saturday and Sunday), or any state holiday;
  • The three-day timeline includes any time that might be needed for transcription;
  • These authentication requirements apply to all medical records, including electronic health records;
  • Authentication must occur before submitting a claim to the OHCA for payment; and
  • There is no “good cause” exception in the signature requirements that extends or otherwise changes the three-day timeline for authentication.
  • OHCA requires that all services provided and/or ordered be authenticated by the author (hand written, electronic signature, or signature attestation statement).
  • Orders for clinical diagnostic tests and outpatient prescription drugs are not required to be signed but if unsigned, there must be medical documentation by the treating physician that he/she intended for the test(s) to be performed or drug given and that documentation must be signed.

OHA Hotline update - 8/23/17

OHA worked actively with OHCA staff about their objection to this rule. Based on those discussions and comments from providers, the OHCA staff recognized the rule as enacted is problematic and OHCA intends to modify through the emergency rule making process. The rule making process is as follows: The agency will propose a new rule (clarifying the requirement) through the state’s emergency rule-making process, which includes public comment and public hearing. Following the approval by the OHCA board, the newly modified rule will go to the Governor for action.

OHCA Global Message - 8/25/17

As part of its 2017 permanent rule changes, OHCA amended OAC §§ 317:30-3-4.1(1)(E) and 317:30-3-30(b) to clarify when medical records must be signed and dated, for the purposes of Medicaid reimbursement. The changes were made through the usual permanent rulemaking process, and the agency did not receive any negative comments about the proposed changes during the thirty-day public comment period. In accordance with Oklahoma law, these amended rules will become effective on September 1, 2017.  
OHCA, however, has recently received concerns from numerous SoonerCare providers about the feasibility of the rule changes – specifically, the revised language that requires medical records to be signed and dated within three days of the provision of the underlying service. OHCA is committed to working with our partners to ensure that a more flexible timeframe for record authentication is established via rulemaking, as quickly as possible. OHCA plans to accomplish this by:

1) submitting emergency rules to Governor Fallin that would return the timeframe for medical record authentication to the timeframe in effect today (where authentication is “expected on the day the record is completed,” or, if the medical record is transcribed by someone other than the provider, “within three business days from the day the record is completed”); and
2) in collaboration with our partners, drafting new, permanent rule changes for medical record authentication that are both clear and unambiguous, and respectful of the realities of healthcare practice.

It is expected that OHCA will be able to submit the aforementioned emergency rule changes to Governor Fallin’s office shortly after its scheduled October 12, 2017, Board meeting. In the meantime, OHCA would like to assure its providers that during this limited window (from September 1, 2017 until the emergency rules become effective); the 3 day rule will not be added to the OHCA audit protocol.

New Delegate Year: 2017

The 2017-2018 House of Delegates began on July 1 2017 and will continue until June 30, 2018. CSAs elect or appoint members to AHIMA’s House of Delegates (House) based on the apportionment formula. Each CSA has at least one delegate and up to five to represent them (OkHIMA has 5!). Delegates are a CSA’s link to AHIMA and the House. Please contact your delegates with questions you might have.
The AHIMA Bylaws define the House’s purpose as, “the House of Delegates shall exist to govern the profession of health information management by providing a forum for membership and professional issues and to establish and maintain professional standards of the membership.” 
To start the new Delegate year, 99 delegates gathered virtually on July 21st, 2017 to learn about being a delegate for the House. About 2/3 of those on the call were new to this role.

Speaker Chrisann Lemery, MSE, RHIA, CHPS, FAHIMA and Speaker-elect Catherine Porto, MPA, RHIA, CHP led the education and discussion. Additionally, Delegates learned about the upcoming 2017 House meeting and their role to prepare. Additionally, resources were shared that are posted on the State Leaders and House community.  Look to your delegates for information about the House and the profession. Be sure to meet with them and learn more about how you can help governing the profession.

Register NOW for the 2017 OkHIMA Convention and Vendor Show

Come one, come all- join us at OkHIMA Convention and let the show begin!  Our two day conference features sessions focused on HIPAA, Quality Payment Programs, Risk Management, Coding, Resume Writing, Leadership and SO MUCH MORE!!!

You won't want to miss this year as Cirque du OkHIMA shows the magic and wonder HIM will bring to healthcare in the future! Please join us September 20th for the Welcome Reception and September 21st and 22nd for the Convention. Up to 12 CEUs are available.

Registration Fee:

ONLY $299 for members
ONLY $329 for non-members

Register Here or Click HERE for More Information

Interested in being an Exhibitor or Sponsor?
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Help Support the OkHIMA Scholarship at the OkHIMA Convention and Vendor Show

Come prepared to the OkHIMA Annual Convention! Tickets are available to purchase for a chance to take home this Kate Spade purse and wallet set. Tickets are $20 each or 3 for $50. All proceeds from this will benefit the winner of the 2017 OkHIMA Scholarship!

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