Friday, March 27, 2015

It's A Digital World

If one waits long enough opportunities appear, almost magically.

Early EAMS observers will remember this scene...
Medical records reproduction companies in California have been waiting now for 2 years to get a fee schedule.

Still waiting.

In the meantime the California Division of Workers' Compensation has come up with an alternative revenue generation program for them assuming the record companies wish to adapt and change their business models: mandating electronic medical records for the review process, specifically Independent Medical Review.

Timely submission (and more to the point, receipt) of medical records has been cited as a significant problem with the IMR process.

WorkCompCentral ran a series of articles a couple weeks ago based on a spreadsheet inadvertently obtained from Maximus Federal Services, the IMR contractor for California, highlighting the records problem.

Commentators, and the Division itself, lay a big chunk of the blame on Maximus for failing to have an adequate records management system.

Based on the spreadsheet, 6,743 IMR cases were missing medical records past the 15-day time limit for administrators to submit the documents. The records had been missing for 90 days or more in the majority of those cases.

Rupali Das, the Division of Workers' Compensation's medical director, presented statistics at Thursday's Commission on Health Safety and Workers' Compensation's review of SB 863 showing that the amount of time Maximus takes to issue a final determination letter dropped from an average of about 60 days in September last year to 24 days this month – but only in cases where complete medical records have been submitted. 

The average age for an IMR, including cases where Maximus has yet to receive records, has risen from about 60 days to 91 during the same time period.

DWC is now proposing that electronic records be mandated to hopefully eliminate this records management issue.

“One of the main issues right now is the paper process that is slowing down our (system),” Das said, noting during the meeting that claims administrators can already provide medical records electronically if they choose.

“We are working with claims administrations to encourage electronic submission of medical records,” she told the commission.

CHSWC voted to endorse the proposition and voted at its Thursday meeting to ask DWC to devote staff time to the issue with an aim toward putting out regulations.

I think this is a good idea, IF done correctly - it's one thing to mandate TRANSMISSION of electronic records, and another to mandate RECEIPT of electronic records.

Remember the key issue seemed to be failure by Maximus to match records to cases, so expert technical guidance will be necessary to promulgate effective regulations on a technical level to ensure smooth, accurate and seamless digital transactions. 

The sender has to be told what to send, and Maximus has to be told how to receive what is sent.

It occurs to me that the much-maligned document copy services have this expertise in place already; perhaps in this new age of records management these companies actually have a compelling place in the system post SB 863.

Regardless, this is a positive step towards modernizing California's system. 

My only caveat - recall all of the painful lessons from the design, development, release and maintenance of the Electronic Adjudication Management System...

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