System Compliance team provides Helpline, EHI, Wisconsin DHS 75 updates
09/09/22 01:20:pmCompliance and Ethics Helpline reminder
Since launching the Compliance and Ethics Helpline in early June, the majority of reports are focused on patient care and are submitted by anonymous employees.
Please keep in mind that the Helpline is for asking a question or reporting any situation involving a potential compliance or ethical violation, including misconduct or violation of the law, Rogers’ Code of Conduct, or company policy.
The Helpline is separate from the patient incident reporting system, which is where employees are asked to report patient care concerns and other matters involving an occurrence that deviates from established policy and procedure or results in a staff, patient, or visitor safety event, complaint, or grievance.
“Thank you to everyone who has brought forward a question or concern to the Compliance and Ethics Helpline,” says Colleen Kelly, chief compliance officer. “Rogers is committed to an environment where open, honest communications are the expectation, regardless of job title or position. Requesting and addressing compliance and other potential concerns foster a culture of mutual trust and respect, which is ultimately good for our employees, patients, and the communities we serve.”
Electronic health information (EHI) definition expansion, policy changes
In 2020, the Office of the National Coordinator for Health Information Technology (ONC) issued a final rule implementing certain provisions of the 21st Century Cures Act to:
- Prohibit information blocking (a practice that is likely to interfere with access, exchange, or use of EHI, unless the practice is covered by an exception or is otherwise required by law)
- Advance interoperability (the ability of two or more systems to exchange EHI and use the information once it is received)
- Support the access, exchange, and use of EHI
Starting on October 6, 2022, the definition of EHI will expand to include all electronic Protected Health Information (ePHI) that a patient has the right to access under the Health Insurance Portability and Accountability Act (HIPAA).
In other words, requests for access need to include, if requested, the entire EHI dataset as denoted in Rogers’ designated record set under HIPAA (see policy ADM-HIM-101: Designated Record Set and Legal Health Record). To ensure compliance with these requirements, System Compliance is actively partnering with Clinical Technology Services, Legal, Revenue Cycle, and other Rogers teams.
For specific questions regarding compliance with the Cures Act, please contact compliance analyst Rebecca Sandler at Rebecca.Sandler@rogersbh.org.
Revised Wisconsin DHS 75 compliance date coming soon
The new requirements take effect on October 1, 2022, affecting all Wisconsin providers certified under Wis. Admin. Code ch. DHS 75. As the project team nears the finish line, we want to remind employees to reference the new Mental Health & Addiction Recovery Update intranet page for updates, resources, and the latest news.