Foothold Technology

Overview

Security

Compliance

CR Medicaid Billing and HIPAA Compliance

HIPAA Information for our Clients

Foothold understands that our customers may be confused and experiencing some difficulty in determining whether and to what degree they are HIPAA compliant. To that end, we offer the following basic information regarding patient privacy and consent. Below you will find a list of explanations of various parts of HIPAA followed by sample forms that can be used at your agency. These explanations and sample forms come to us from a well-respected orgainzation in Wisconsin. The information may be freely distributed in its entirety provided that the copyright notice on each form is not removed. This information may not be sold for profit or used in commercial documents without the written permission of the copyright holder. This information is provided “as is” without any express or implied warranty. This information is for educational purposes only and does not constitute legal advice. If you require legal advice, you should consult with an attorney. This information may need to be modified in order to comply with local law. The forms and explanations are left in Word format for easy downloading.

Here are a few links with valuable information on HIPAA and compliance.

HIPAA information about AWARDS

Among other things, the new HIPAA regulations are designed to protect the security and privacy of agencies and the consumers they serve. At Foothold Technology, security is our top priority. Using Secure-Socket Layer (SSL) and 128-bit encryption technologies, Foothold Technology's security is second to none. We utilize several layers of encryption to protect data from both external sources and internal accessibility. Below are a number of our specific security measures which should address any concerns you may have.

A.W.A.R.D.S. safeguards the confidentiality of chart records.
All system users must authenticate themselves using a login and encrypted password. Passwords must meet minimum standards such as not using words found in a dictionary.
Your agency has its own separate database and database server process with login accounts for your agency's staff only.
The database server is protected by a "firewall" that by default blocks all access except the secure sockets layer connection to the web server process running for your agency alone.
All data transmitted to and from the database server uses 128-bit encryption, the highest legal limit that is also used by online banking.
Physical access to the servers is under lock and key. Backup media can be transported offsite by messenger and stored at a secure site under lock and key.
No access to chart records is permitted unless the user is direct care staff in that clinical program as determined by caseload information or the user is a supervisor in that program or that program's director has granted a specific permit to the user.
Access to progress notes is restricted to the past 10 days unless the consumer is on the caseload of the user or the user is the program director or the program director has issued a specific permit to the user. All exception permits have expiration dates set at the time the permit is issued.
A.W.A.R.D.S. keeps an audit trail each time a progress note is viewed.
A.W.A.R.D.S. blocks all access to notes concerning incidents except by the note writer and users who have a permit to access these notes.
Whenever an exception permit is issued to grant access to chart records, all administration staff with permits to issue such permits are automatically notified by an internal email message.

CR Medicaid Billing

593.6 (c) "Community rehabilitation services shall be provided in accordance with a service plan developed within four weeks of admission to the program."
A.W.A.R.D.S. automatically creates a schedule of service plan due dates that generate "tickler" reminders delivered as email messages. The Admission Note is due on the admission date. The due date for the Initial Service Plan (28 days following admission) is automatically generated and displayed on the Admission note. When the Initial Service Plan is opened, the first Quarterly Review date is automatically generated 90 days post admission and all subsequent QR dates are automatically generated as each QR is opened.

593.7 (1) "A full monthly rate will be paid for services provided to an eligible resident in a residence for at least 21 days in a calendar month."
593.7 (2) "A half-month rate will be paid for services provided to an eligible resident in a residence for at least 11 days in a calendar month."
A.W.A.R.D.S. automatically calculates the number of days the resident was in the program and out of the hospital during the calendar month and generates a billing report using either service codes or billing codes identifying full or half month eligibility. It also checks for Medicaid eligibility and authorization for services and provides the name and license number of the authorizing psychiatrist. A.W.A.R.D.S. automatically ensures that service types and dates are not duplicated.

593.8 (b) (4) "For reimbursement purposes, a contact shall involve the performance of at least one of the services indicated in the resident's current service plan."
A.W.A.R.D.S. displays the current service plan to the progress note writer so that only current goals and services may be selected for notes linked to the service plan. "Notes linked to the service plan" is the default note type selection when writing notes for CR residence programs.

595.14 (a) (1) "Case record entries shall be in no erasable ink or typewriter;"
595.14 (a) (2) "Case records shall be legible."
A.W.A.R.D.S. generates printed progress notes that comply with the uniform case record.

595.14 (a) (4) "Case records shall be dated and signed by appropriate staff."
A.W.A.R.D.S. prints the name and title of the writer with a signature line and both the date of the encounter and the date the progress note was written.

595.14 (b) "The case record shall be available to all the staff of the program who are participating in the provision of services to the resident."
A.W.A.R.D.S. allows program staff to access the progress notes and other records from any computer on the network using a secure password login and an encrypted data connection.

595.14 (b) (8) "...documentation of the type of service provided, the date it was provided, its duration and the name of the person rendering the service."
A.W.A.R.D.S. records the date and duration of the service and prints the goal, service and objective as well as the progress note. A.W.A.R.D.S. documentation is done by the person who provided the service and their name is automatically captured and stored as part of the note record.

595.14 (c) "Statistical information shall be prepared and maintained as may be necessary for the effective operation of the program, and as may be required by the Office of Mental Health."
A.W.A.R.D.S. generates numerous statistical reports including service plan utilization and QR progress assessment outcomes.

In addition, A.W.A.R.D.S. facilitates the process of selecting which notes will be billed by allowing supervisors to call up only eligible notes that are linked to the current service plan, at least 15 minutes in duration and provided on days when the resident is in residence and not hospitalized.

The A.W.A.R.D.S. billing report includes an analysis of the overall billing level with a break down of potential billing loss due to vacancy, Medicaid ineligibility, hospitalization and "insufficient services" with the resident and counselor identified in case of insufficient services.