Red Flags Rules Process for the Front desk staff
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- Barnaby Garrett
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1 Red Flags Rules Process for the Front desk staff Purpose: Identify the process and workflow of establishing a patient identity and maintain access control to protect account information in order to minimize the effects of identity theft and maintain compliance as stated in the Federal trade commission s Identity Theft rules. The patient must answer questions correctly to receive protected health information (PHI) or billing information. Background: Rowan Medicine strives to prevent the intentional or inadvertent misuse of PHI. It is our responsibility to report criminal activity relating to identity theft and theft of services to appropriate authorities and to take steps to correct and prevent further harm to any person whose name or other identifying information is used unlawfully or inappropriately. Responsibility: The Executive Director of Rowan Medicine, Director of Operations, Director of Central Billing Office and Department Administrative staff shall be responsible for communicating and enforcing the above process as it relates to persons involved in Faculty Practice and patient care. Education & Training: Practice Administrative staff are to ensure that staff members are trained to recognize common signs of medical identity theft in day-to-day operations, such as a discrepancy in patient identity information and how to respond. Each staff member is responsible for attending either an in house live training session or training via video on the web. Maintain a record of completion. Monitoring: Practice Administrators for each division is responsible to ensure that each staff member is up to date with education and training sessions. Audit reports will also be run monthly by IRT to assure that the system is being used correctly. 1
2 1 Workflow Processes 1.1 Patient on Phone for first time When updating registration before the patient is in the office presenting ID, the Picture ID Sources must be completed. When this happens use the option of UNAVAILABLE from the menu. NOTE: This will be audited to validate that one the patient has come into the office that the information has been validated and updated. 1.2 Patient is in the office In order to verify the patient s identity, the staff member must ask for the patient s Photo ID (State Driver License, Non Driver License or the parent / caretaker/guarantor Photo ID). The office staff will check the patient registration screen in the Practice Management system and confirm the date of birth and zip code on the ID matches the system and are correct. Scan the ID and current insurance card into EMR. Follow the process which is outlined below on updating CB. The first screen captures two required and one optional Challenge Questions. The verification of the patient s date of birth and zip code are the first two. This information will be defaulted in the fields required in the Practice Management system. The third question may be used if desired, but is not required. Challenge Questions Screen 2
3 Once security questions are answered, Front Desk users need to proceed to next page and answer the rest of the security questions. Challenge Verification Screen Challenge Outcome- Once the account has been set up and a patient is requesting PHI/Billing Information, use the drop down to answer if the patient answered the challenge questions correctly or incorrectly. 3
4 o These questions are asked and answered each time the patient calls in requesting PHI or Billing information or when presenting without identification o If the outcome is anything other than Cleared, report as per compliance policy attached to this document. Reg Update Source- Use drop down to identify the source of the information/data you used to update the patient s registration. o NOTE: Interface refers to any of the interfaces utilized by Rowan Medicine (e. g. Ingenious Med, Kennedy, etc.) o The patient name in Registration must be updated to reflect the name on the Federal/State Issued ID (See Picture ID Source options below) Transportation provided by outside source- This is a Yes/No question (Was the patient brought in by someone other than a family member?) - Patients transported by a service or CARES patients who do not bring their identification with them can have their identification verified by the transporter or State worker. o Collect the Employee ID badge (Transport Employee work badge or State Employee work badge) o Make notation in comment field regarding how this patient s identity was validated (e. g. Tom Jones Case Worker- ID Badge) o NOTE: In the Picture ID Source field, use OTHER PHOTO ID 4
5 Picture Id Source- Use drop down to answer the source of the identification used to validate patient identity and challenge questions. o If editing registration before patient arrives, select Unavailable from the drop down list Secondary Id Source- Use this option only if there is no state or federal issued id (e. g. driver s license) o If the patient doesn t have a state/federal ID, then two sources of identification are required. Here is where you would document the second source. Comment- Free text field Prior to turning a patient away due to insufficient ID, ID Discrepancies or Failure to Present an ID, a Supervisor must be consulted o If the Supervisor authorizes the visit, a comment must be entered indicating why they approved the visit (e.g. minor being seen without parent) o Supervisor s responsible to report if not authorized to the Compliance department. 5
6 1.3 Viewing Red Flags via Scheduling, Registration updates, Invoice Inquiry Edit Registration o These questions are asked and answered each time the patient calls in requesting PHI or Billing information or when presenting without identification o If the outcome is anything other than Cleared, report to Supervisor first and the Supervisor will follow the compliance policy. From VTB chose Registration Then choose Add/Edit Patient Bring up patient that you want to view/verify Put a check mark in the Edit Registration box Click OK Navigate to the CHA page to verify patient challenge outcomes, once the patient validates identity, document in the Challenge Outcome field. 6
7 1.3.2 Invoice Inquiry From VTB select Invoice Inquiry Bring up patient that you want to view When the Edit Registration Data? Box appears, enter YES. Once the Registration Edit box appears, enter 1: Navigate to the CHA page to verify patient challenge outcomes, once the patient validates identity, document in the Challenge Outcome field. Once you select OK, you will be sent back to Invoice Inquiry to finish your task. 7
8 1.4 EMR Users When responding to a patient Inquiry, first view the security information in Reg. Validate the Date of Birth and the Zip Code of the patient. Open a PHONE NOTE and in the Summary of the Call box, use the Quick Text.RED and.s to document the security questions were asked and validated. 8
9 This validation must be made with each new contact with the patient, even within the same PHONE Note, for example it should be validated when the patient calls in, and then again when the patient is called back. 9
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