OHCP offers this Telehealth Privacy Tips resource for providers and patients.  If you are a provider, we encourage you to share this resource with your patients.

 

 

In addition to the information outlined in the Office of University Compliance’s November Compliance Chatter: The Gift Rules, specific considerations also apply to the giving and receiving of gifts in the healthcare environment. These considerations particularly apply when interacting with patients, visitors, or potential referral sources, such as physicians, vendors, or other people or entities with the ability to influence or recommend the use of goods, facilities, items, or services or who are in a position to refer patients to UConn Health.

With the holiday season upon us, keep the November gift highlights from the Office of University Compliance, the University Guide to the State Code of Ethics, and these key considerations in mind regarding the acceptance or offering of gifts with regard to patients, visitors, and Referral Sources:

1. Never solicit, or ask for, gifts. Solicitation of gifts may constitute an actual, potential, or perceived conflict of interest and/or violation of the Federal Anti-Kickback Statute.
2. Never accept or offer a gift intended to influence referrals or result in the purchase of goods or services from UConn Health, and avoid the acceptance or offering of gifts that may be perceived as having these effects.
3. Never accepts gifts of cash or cash equivalents (such as a gift card). Refer those wishing to make monetary gifts to the UConn Health Foundation, including to the Expressions of Gratitude.
4. For non-cash or non-cash equivalent gifts, never accept gifts of strictly personal benefit that exceed nominal value, such as tickets to a concert or sporting event (see the State Code of Ethics).
5. A department or clinical unit may accept a modest perishable gift, such as an edible item to be shared by all staff within that department or clinical unit, provided the value of the perishable gift does not exceed nominal value (see the State Code of Ethics).
6. Carefully consider the acceptance and offering of gifts, and contact UConn’s State Ethics Liaison, the Office of Healthcare Compliance & Privacy, and/or the UConn Health Office of the General Counsel if unclear about accepting a gift or if you’ve received a prohibited gift and do not know how to return it.

UConn State Ethics Liaison: Kim Fearney, kim.fearney@uconn.edu

Office of Healthcare Compliance & Privacy: ohcp@uchc.edu

UConn Health Office of the General Counsel: generalcounsel@uchc.edu

Patient identity must be verified when using or disclosing patient information. It is vitally important to identify the correct patient for many reasons, including but not limited to patient safety, protection of privacy, and proper billing.

• Per UConn Health policy, at a minimum, verify identity using the patient’s full name and date of birth. Regulation requires the use of as many identifiers as necessary to ensure identification of the correct patient.
• In addition to the UConn Health verification requirements, the Office of Healthcare Compliance & Privacy strongly recommends using at least one additional identifier, such as the last four (4) digits of the patient’s Social Security number (if available) or address.

Remember:

• Double-check to ensure the correct medical record is open for the correct patient, every time. Patients may have the same or similar names and dates of birth.
• Direct all requests to change or correct patient identifying information to Patient Access at 860-679-1600 or dl-patientaccess-namecorrections@uchc.edu or Data Integrity at 860-679-3795 or dataintegrity@uchc.edu. Patient identifiers must not be changed without appropriate supporting documentation. Further, any proposed changes to date of birth or Social Security number must be directed to Data Integrity for validation and processing.
• If you discover that more than one patient has the same name or other identifiers, do not disclose this information to the patient with whom you are speaking. For example, do not say, “We have three other patients here with your same name.”

Questions or Concerns:

• If you have questions about the Identification and Protection of PHI policy or related procedures, need guidance, or have a privacy concern, please contact the Office of Healthcare Compliance & Privacy at ohcp@uchc.edu or 860-679-6060.
• If you have questions regarding UConn Health verification requirements or the Core Patient Identifiers and Naming Convention policy, please contact Health Information Management at 860-679-3380.

 

Please join the Office of Healthcare Compliance & Privacy (OHCP) in celebrating National Compliance and Ethics Week November 6^th – 9^th. This highly recognized week is an opportunity to refresh the UConn Health workforce on the importance of healthcare compliance and privacy at UConn Health and create awareness about the OHCP program. Stop by the Food Court in the Main Building on November 7^th between 11 am and 2 pm to chat with OHCP team members, test your healthcare compliance and privacy knowledge in a round of “Jeopardy,” and enter into a prize gift card drawing.  Can’t make it on November 7^th? Watch the daily Lifeline messages during National Compliance and Ethics Week for other opportunities to test your healthcare compliance and privacy knowledge and become eligible to win a gift card. Fostering a culture of healthcare compliance and respect for privacy is our shared responsibility – truly a team effort. The OHCP team looks forward to seeing you on November 7^th!

 

 

The Office of Healthcare Compliance & Privacy (OHCP) welcomes both Hillary Barigye and Joelle McCarthy to our team.

In July, Hillary joined our team as an Administrative Program Coordinator. With five years of experience working in academic medical centers providing program support to various departments, most recently in the UConn Health Department of Public Health Sciences, Hillary brings knowledge, skill, and an eager enthusiasm for building processes and standards. In his new role, Hillary provides project support, data analytics, and reporting coordination for the OHCP, and we thank Hillary for his innovative, early, and meaningful contributions to improving our office’s communication, project management, and technical platforms.

This month, Joelle joined our team of Assistant Privacy Officers. Joelle’s previous experience working in healthcare involved Privacy Officer and Policy Writer roles, as well as contributions to the development of an enterprise-wide compliance program for privacy at the corporate headquarters for military medicine. We look forward to Joelle’s expertise contributing to the OHCP’s ongoing collaborative evolution of privacy elements in our program.

Please join us in welcoming Hillary and Joelle and wishing them success in their new roles at UConn Health.

Why?

In alignment with federal requirements, UConn Health requires the immediate reporting of known or suspected compliance and privacy concerns and incidents.

Who?

All members of the UConn Health workforce have an obligation to report any compliance or privacy concerns or incidents at the time of suspicion or identification.

How?

You may report concerns and incidents to:

• Your manager or supervisor
• The Office of Healthcare Compliance & Privacy
  Email: ohcp@uchc.edu
  Phone: 860-679-6060
  Online:  Report a Privacy Incident

• UConn’s 24/7 anonymous REPORTLINE
  Phone: 1-888-685-2637
  Online: Make a Report – EthicsPoint – University of Connecticut

UConn’s Non-Retaliation Policy prohibits retaliation against an individual who reports a compliance or privacy concern or incident in good faith or who participates in a related investigation.

The Office of Healthcare Compliance & Privacy partners with various units across UConn and UConn Health, promoting a culture of compliance and respect for privacy in healthcare. One of our integral partners is UConn Health’s Case Management Department.  Lori Pawlow, Director of Case Management, shared her insights into how the important work of UConn Health’s Case Management Department contributes to UConn Health’s commitment to compliance.

Case Management professionals guide and coordinate care and services provided to UConn Health patients to ensure that services are provided in accordance with federal and state regulations. Additionally, they assess the patient’s insurance benefits to determine whether services will be covered and inform patients of potential financial liability related to the care they receive. At UConn Health, this team includes RN Case Managers, Social Workers, and Utilization Review professionals.

As Director, Lori enjoys the collaboration with interdisciplinary teams throughout the institution, the connection with finance and billing, and the relationships with patients and their families. According to Lori, Case Management uses different review platforms to determine patient’s eligibility for inpatient and observation status, reviews options for discharge or transition of care with patients and their caregivers, and continually monitors for severity of illness and medical necessity to determine appropriate level of care.

Case Management and Utilization Review must be dynamic and evolutionary to meet the needs of our growing and diverse patient population and ever-changing regulatory guidelines. When there are questions regarding regulatory requirements, the Office of Healthcare Compliance & Privacy acts as a resource to research and provide guidance. The collaboration and rapport between Case Management and the Office of Healthcare Compliance & Privacy make the Case Management department an effective and dependable compliance partner.

 

The Centers for Medicare and Medicaid Services (CMS) publishes requirements for Medicare-covered services and procedures in documents called National Coverage Determinations (NCDs). An NCD is a nationwide determination of whether Medicare will pay for an item or service, and an NCD includes descriptions of provider, documentation, and indication requirements for payment. CMS creates NCDs through evidence-based analysis with opportunities for public participation in reviewing drafts. Currently, approximately 340 published NCDs describe requirements to receive federally funded reimbursement dollars for particular services.

Maintaining awareness of requirements for services delivered in your operational area(s) proves useful in supporting providers, staff, Revenue Cycle, and the rest of the institution in proactively meeting criteria to receive federal reimbursements for clinical care. A complete list of NCDs can be found in the CMS National Coverage NCD Report.

If you have any questions about requirements for services delivered in your area, please contact the Office of Healthcare Compliance & Privacy at ohcp@uchc.edu or x6060.

OHCP is pleased to share a meaningful update about UConn Health’s management of the upcoming expiration of the federal COVID-19 Public Health Emergency (PHE), expiring May 11, 2023.

During the PHE, the Centers for Medicare and Medicaid Services (CMS) eased certain regulatory requirements for healthcare providers and institutions to better deliver healthcare in unprecedented circumstances. Over the next several months, UConn Health anticipates adjusting the policies and regulatory flexibilities utilized during the PHE in accordance with applicable requirements and guidance.

With the PHE now ending, UConn Health organized a multidisciplinary workgroup to develop a roadmap for the transition and provide additional communications on updates and further guidance. For a helpful summary of the topics requiring changes, and for which you can expect more information to come, please refer to the UConn Health COVID-19 PHE Roadmap.

We appreciate the hard work and sacrifices made during the pandemic, and we look forward to working together during this transition.