Inpatient Psychiatric Post-Payment Reviews
On a monthly basis, Permedion sends medical record requests for Inpatient Psychiatric Post-payment reviews to a number of Ohio Medicaid fee-for-service inpatient psychiatric hospitals. The specific records chosen for review are the result of both targeted and random selections.
Hospitals must provide medical records within 30 days of the date printed on Permedion’s request letter. A provider’s failure to produce records within the time frame is subject to withholding or recoupment of Medicaid payment. There is no appeal process for failure to produce medical records. Under the circumstances, it is recommended that providers as quickly as possible respond to the medical record requests they receive.
Medical Record Preparation
- Respond as quickly as possible to medical record requests. Records received after the deadline will result in technical denials.
- Permedion requires the entire medical record. By working closely with the hospital medical records department, ensure that the charts sent to Permedion are complete. If electronic medical records (EMRs) are provided, this is particularly important because Permedion has noted a pattern of important elements missing from these types of charts. The following represents documentation frequently missing from the EMRs received for post-payment review:
- Multi-Disciplinary Treatment plans with signature pages
- Contraindications to seclusion and restraint.
- Documentation related to seclusion and restraint.
- Discharge plans with signatures.
- Psychosocial assessments.
- Certificates of Need.
Utilization Review for Post Payment Reviews
It is advantageous for providers to be knowledgeable of the post-payment process. Not only does it aid in knowing what to expect from Permedion, but also enables a hospital to develop internal procedures for best managing medical records requests. The following information will support provider efforts at addressing post payment review notifications:
- Permedion mails a medical records request letter to the provider.
- The provider sends the medical records to Permedion within 30 days of the date printed on the request letter.
- The Permedion nurse reviewer receives the medical records. A determination will be made within 30 days of the original medical record submission due date.
- A report with results of the medical record review is sent to the provider.
Protected Health Information
Post-payment reviews require that the entire medical record be sent to Permedion. However, personal health information (PHI) is protected by law in order to support patient privacy. Permedion and providers should work together to ensure that unnecessary records not be shared.
A central aspect of the privacy rule is the principle of “minimum necessary use” and disclosure. A covered entity must make reasonable efforts to use, disclose, and request only the minimum amount of PHI needed to accomplish the intended purpose. A covered entity must develop and implement policies and procedures to reasonably limit uses and disclosures to the minimum necessary. When the minimum necessary standard applies, a covered entity may not use, disclose or request the entire medical record unless it can be specifically justified.
Change of Contact
As needed, hospitals should contact Permedion with any primary contact changes. Permedion’s experience has been that sometimes the proper hospital personnel do not receive correspondence on a timely basis because it was delivered to the incorrect person.
In order to update a hospital primary contact with Permedion, complete the Change of Contact form.