HIPAA

PHP site and medical recordkeeping standards are based on several sources including OSHA regulations, AMA documentation recommendations, and NCQA requirements.

GENERAL

1. There will be adequate parking space, lighting, seating, and appearance of the office site.
2. There will be handicap accessible parking places, entrances, and rest rooms at each site.
3. All compressed gas tanks will be in-wall lines, wall mounted, or in approved containers for safety.
4. Fire extinguishers will be accessible, filled, and dated. Inspection date will be within one year of date of review.
5. There will be at least two exits. Exits will be easily identified and hallways will be unobstructed.

EXAMINATION ROOMS

1. Syringes and needles will not be easily accessible to patients.
2. Disposable patient care equipment (ear speculums, vaginal speculums, etc.) is recommended, but not required.
3. Reusable equipment will be decontaminated appropriately.
4. Sterile equipment package dates will not be expired.
5. Paper towel wall dispensers will be in use.
6. Soap dispensers will be in use.
7. Trash containers will have liners.

APPOINTMENTS/TRIAGE

1. Access parameters:
   • Emergent-Immediate access.
   • Urgent-Within 72 hours.
   • Routine-Within 4 weeks.
   • Health Maintenance Exam (routine physical)-Within 4 months.
   • After Hours-Physician contact within 1 hour.
2. Telephone and/or walk-in triage procedures will ensure that members receive appropriate, medically sound advice, as well as recognition of, and intervention in urgent/emergent situations.
3. Outside of business hours urgent care procedure/expectations will be easily accessible to members to ensure twenty-four hour a day health care access.

MEDICATIONS

1. Medications will be stored in a way that deters access by patients.
2. Medication dates will be monitored for expiration dates on a regular schedule.
3. Medications will be labeled with name of medication, strength, and expiration date visible.
4. Refrigerated medications will be stored in a separate refrigerator. (No food or specimens.)
5. Medication refrigerator will have a thermometer inside, demonstrating a temperature of between 2-8oC or 36-46oF.
6. There will be evidence that the temperature is monitored on a routine basis, and corrective actions taken if the temperature is found to be outside of above range.
7. Narcotics and other Schedule II medications will be stored in a double locked manner with a record of usage.
8. Members will receive accurate prescription medications with appropriate information.

INFECTION CONTROL

1. Regulated waste is disposed of in closed, leak resistant, red color-coded or biohazard labeled containers.
2. Contaminated laundry is bagged and labeled as such. If laundry is wet, container will be leak resistant.
3. Sharps containers are puncture resistant, leak resistant, closeable, and placed as near as feasible to the area of use.
4. Hand washing facilities are available, accessible, and in use.
5. If an autoclave is used, efficacy is ensured by:
   • Live spore counts performed at least annually, and heat/steam sensitive tape test at least monthly, or
   • Live spore counts at least monthly.
   • There will be documentation of above.
6. Contaminated surfaces and equipment are decontaminated with an appropriate disinfectant whenever contaminated, and at the end of every work shift.
7. Universal Precautions are observed to prevent contact with blood or other potentially infectious materials.
8. Personal protective equipment is available and in use.

INSPECTIONS/ CERTIFICATION

1. All practitioner labs that perform examination of any human specimens for the purpose of assessing health, or diagnosing, preventing, or treating any disease or impairment will have a CLIA certificate to ensure that all federal requirements have been met.
2. If x-rays are performed on site, a current certificate will be displayed.

MEDICAL RECORDKEEPING

1. There will be a written policy for the maintenance of medical records, which addresses confidentiality.
2. Medical records will be stored in a safe, accessible manner that maintains member confidentiality.
3. Medical records will be maintained in a consistent, organized manner, which facilitates continuity of care and accessibility of information. (Includes problem list, consistent allergy or nkda notation, immunization records for children and adolescents, physician notation of diagnostic tests, consultation reports, etc.)
4. Each patient's medical record is separate. (May be separate within family records.)
5. Inactive records will be maintained in a safe and retrievable place for at least 7 years.

PHP medical record standards are based on AMA documentation recommendations and NCQA requirements.

1. Each page of the medical record will include patient identification, either by name or ID number.
2. Personal biographical information will be included on each patient's medical record.
3. All entries in the medical record will contain author identification.
4. All entries will be dated.
5. The medical record will be legible.
6. Significant illnesses and medical conditions will be indicated and readily identifiable on a problem list or flow sheet.
7. Medication allergies and other adverse reactions will be noted prominently in the medical record. If there are no known allergies, this should also be noted in the record.
8. Past medical history will be easily identifiable. (Includes serious accidents, operations, and illnesses. Includes menstrual and pregnancy history of adolescent and adult females. For children and adolescents, relates to prenatal care, birth, operations, and childhood illnesses.)
   • Family history will be available.
   • Social history will include age appropriate assessment. (Includes assessment of alcohol, tobacco, and other substance use/abuse by patients 14 years or older.)
9. Each encounter note will include a reason for encounter (chief complaint), history and physical exam (subjective/objective assessment), a clinical impression or diagnosis, a plan regarding treatment and/or further evaluation, and when indicated, follow-up care.
   • Unresolved problems from previous visits will be addressed in subsequent visits.
   • Medication administration/injection will be recorded, including drug name, dosage, and route.
10. Lab, x-rays, and other studies will be ordered appropriately and documented in the encounter note. The reason for the above studies will be documented or easily implied.
11. Consultants will be utilized appropriately.
    • When consultation has been requested, there will be a report or notation from the consultant in the medical record.
12. Consultation, lab, and imaging reports filed in the chart will be initialed by the primary care physician to signify review, or a notation is made in the medical record acknowledging review of specific diagnostic test results.
    • Reports presented electronically or by other methods have some representation of physician review. Consultation, abnormal lab and imaging study results have an explicit notation in the record of follow-up plans.
13. Medical records of children and adolescents 0-16 years old will contain documentation of each immunization. When immunizations are not up to date, documentation will indicate reason or plan.
    • Immunization documentation will contain record of serum, manufacturer, lot number, date, and site of administration for immunizations provided after 1995.
    • If immunizations are obtained elsewhere, the medical record should note this, and that immunizations are up to date.

PHP accepts electronic claims from all clearinghouses, as well as HIPAA-compliant files from providers.  Our payer ID number is 12399.*

If you have any questions or issues regarding electronic claim submission, please contact PHP Customer Service at (260) 432-6690, ext. 11; toll-free at 1-800-982-6257, ext. 11; or custsvc@phpni.com.

* Our payer ID number is also 12399 for electronic remittance advice (835).