HIPDB: Reporting Responsibilities Federation of Chiropractic Licensing Boards 81 st Annual Congress May 4, 2007 LCDR Shari W. Campbell, DPM, MSHS U. S. Department of Health and Human Services Health Resources and Services Administration Bureau of Health Professions Practitioner Data Banks Branch
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HIPDB: Reporting Responsibilities Federation of Chiropractic Licensing Boards 81 st Annual Congress May 4, 2007 LCDR Shari W. Campbell, DPM, MSHS U. S.
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HIPDB: Reporting ResponsibilitiesFederation of Chiropractic Licensing Boards
81st Annual Congress
May 4, 2007
LCDR Shari W. Campbell, DPM, MSHSU. S. Department of Health and Human ServicesHealth Resources and Services AdministrationBureau of Health ProfessionsPractitioner Data Banks Branch
Overview
HIPDB Background Report Data Compliance Activities System Improvements New Initiatives
HIPDB
Background
HIPDB Purpose
The intent is to protect the public, improve the quality of health care and deter fraud and abuse in the health care system by providing information about past adverse actions of practitioners, providers, or suppliers to authorized health care entities and agencies.
HIPDB BackgroundHIPDB Background
Established through Section 1128E of the Social Security Act as amended by Section 221(a) of Public Law 104-191, the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
Final regulations governing the HIPDB are codified at 45 CFR Part 61
All final adverse actions taken on or after August 21, 1996 must be reported
By Law, Who Must Report?
State Government Entities Federal Government Entities Health Plans
Who May Query the HIPDB?
Federal and State Government Agencies Health Plans Health Care Providers, Practitioners and
Health Care SuppliersExamples: Durable Medical Equipment Suppliers,
Pharmaceutical Suppliers and Manufacturers, Billing and Transportation Service Suppliers
What is Reportable?
Federal and State licensing and certification agencies must report final adverse actions* that are taken against health care: Providers Practitioners Suppliers
*Regardless of whether the final adverse action is the subject of a pending appeal
What is Reportable?
Licensing and certification actions: Revocation, Suspension, Probation, Censure,
Reprimand Any other loss of license or certification, or right to
apply for, or renew a license whether by voluntary surrender, or non-renewal
Any other negative action or finding that is publicly available information
What is Reportable?
Criminal Convictions Federal and State Prosecutors must report criminal
convictions* related to the delivery of a health care item or services
Civil Judgments Federal and State attorneys and health plans must report civil
judgments* related to the delivery of a health care item or services
Exclusions Federal and State Government agencies must report health
care providers, suppliers, or practitioners excluded* from participation in Federal or State health care programs
*Regardless of whether the conviction is the subject of a pending appeal
What is Reportable?
Other Adjudicated Actions Federal and State government agencies and
Health Plans must report other adjudicated actions, * which are defined as:
Formal or official final actions taken against health care practitioners, providers, or suppliers, which include the availability of a due process mechanism; and
Are based on acts or omissions that affect or could affect the payment, provision, or delivery of a health care item or service
*Regardless of whether the exclusion is the subject of a pending appeal
What is not Reportable?
Medical Malpractice Payments Settlements in which no findings or admissions
of liability have been made Temporary Actions; i.e. summary or emergency
HIPDB
Data
What is in the HIPDB?Practitioner Reports
18%
76%
1%
4%
1%
0%
State Licensure 193,910
State & Fed Exclusions 45,827
Judgments or Convictions 10,693
Gov't Admin 2,283
Health Plan 3,626
DEA 468
Cumulative Data as of 12/31/06
What is in the HIPDB?Practitioner Reports
8%8%
82%
2%0%
0%State Licensure 28,207
State & Fed Exclusions 2,916
Judgment or Conviction 2,595
Health Plan 529
Gov't Admin 120
DEA 23
Reports received in 2006
What is in the HIPDB?Organizations
26%
9%
3%
2% 0%
60%
State Licensure 2,061
State & Fed Exclusions 711
Judgments or Convictions 266
Gov't Admin 4,805
Health Plan 159
DEA 15
Cumulative Data as of 12/31/06
What is in the HIPDB?Organizations
14%
7%
4%
1%
1%
73%
State Licensure 197
State & Fed Exclusions 104
Judgment or Conviction 57
Health Plan 20
Gov't Admin 1,032
DEA 15
2006 Data
HIPDB QUERIERS
Self-Queries 5.7%
Gov't Hospitals 15.6%
Health Plans 64%
Government HealthProg 1.2%State Boards 8%
Other ServiceProviders 5%
8%
5%
2006 Data
64%
15.6%
5.7%
1.2%
Types of Reports on Chiropractors
2004 2005 2006 Total # of Reports
Licensure 184 309 1135 1628
Malpractice 235 213 208 656
Exclusions 134 48 69 251
Health Plan 111 128 96 335
JOCR 15 10 18 43
Clinical Privileges
6 5 13 24
Note: Data represents the date that the action was submitted to the NPDB or HIPDB
Note: Data represents the date that the action was submitted to the NPDB or HIPDB
Number of Reports
Chiropractor Licensure Actions
0%
20%
40%
60%
80%
100%
Reported2004
Reported2005
Reported2006
Action Taken 2006Action Taken 2005Action Taken 2004Action Taken 2003
HIPDB
Compliance Activities
Compliance Activities
Convey the importance of timely reporting Holding Policy Forums and talking with leadership of composite State
licensing boards Presenting to Associations/Federations of State licensing boards Presenting to State Association Medical Staff Services
Regulations Mandates reporting within 30 days of the date of the final action. NPDB: Title IV of Public Law 99-660, the Health Care Quality
Improvement Act of 1986, as amended and its implementing regulations (45 CFR Part 60)
HIPDB: Section 1128E of the Social Security Act as added by Section 221(A) of the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (45 CFR Part 61)
Compliance Activities
Monitor Timely Reporting Compare actions documented on State Licensing Board web sites to
actions reported to the NPDB and/or HIPDB Identify and contact States that have not reported any actions to the
NPDB and/or HIPDB Search other publicly available information for actions and payments
that should have been reported Review reports that are filed and later voided
Review a limited number of report narratives to determine if they are legally sufficient: Must include enough information so that future queriers knowing
nothing about the events giving rise to the report will have an understanding of what the subject practitioner is alleged to have done, the nature of the action taken and the reasons for the report
Compliance Activities
Compare NPDB payment reports to the NAIC summary payment reports (Supplement A to Schedule T)
Review Medical Malpractice Payment Reports that mention High-Low agreements in the narrative to determine if the payment was made for the benefit of the: Practitioner (reportable) Insurer to avoid the risk of a higher payment when the finder of fact
ultimately determines that the practitioner had no liability (not reportable) These reporters are asked to void the report
Monitor the eligibility of Data Bank Registrants Monitor for violation of Confidentiality Rules
HIPDB
System Improvements
June 18, 2007 System Release
Ability to correct a Revision-to-Action Report (IQRS and ITP) Ability to update a Subject Address when entering a Dispute
Statement or Secretarial Review Request Increase all Report Narratives and Subject Statements to
4,000 Characters Enhanced ITP Client Program for Password Encryption
New version will be posted on the informational website and available for download as of April 30, 2007
New version must be used on June 18 - previous version will not work
June 18, 2007 System Release
Display most recent Entity Information Section A will be expanded to include the most recent reporter name
and address (if it has changed) since the submission date Five variations
No change in reporter information Updated reporter information Original reporter is inactive with no successor Original reporter is inactive with a successor Original reporter is inactive with a successor, the successor is
inactive
No change
Reporter information is currentReporter information is current
Original Reporter inactive with no Successor
Reporter is inactive with no successorReporter is inactive with no successor
Original Reporter inactive with a Successor
Reporter is inactive with a successorReporter is inactive with a successor
Successor POC is provided if presentSuccessor POC is provided if present
Original Reporter inactive with a Successor
Reporter is inactive with a successorReporter is inactive with a successor
Successor POC is provided if presentSuccessor POC is provided if present
Original Reporter inactive with a Successor, and the Successor is also
inactive
Reporter is inactive with a successor, and the successor is also inactive
Reporter is inactive with a successor, and the successor is also inactive
Successor POC is provided if presentSuccessor POC is provided if present
June 18, 2007 System Release
Limit Registration Renewal Grace Periods There will be a limit of three months or four (4) grace renewals, whichever
is longer, in which the entity is permitted access to the system without actually renewing
Once the limit is passed, the system will permit the user to renew only. There will not be a grace period provided to use the system while the renewal is mailed and processed
Grace Period For Expired Entity Registrations The system considers an entity to be “inactive” once their registration
expires. Report change notifications are not sent to inactive entities To prevent an entity with an expired registration from missing report
change notifications, a 90 day grace period will be established
June 18, 2007 System Release
Addition of another option to Automatic Reinstatement Data Element (IQRS and ITP)
Currently, an entity can select only "yes" or "no" in response to whether a reinstatement is automatic at completion of the adverse action period Add a third response option:
Yes Yes, with conditions (requires a Revision to Action Report when status
changes) No
Automatic Reinstatement Options
Now three response options
Now three response options
Other Recent System Improvements
Historical Summaries Users can retrieve historical summaries of their queries and reports back to
June 2000. Use entity name and specific date range for the search Limited to one-year increments within three years of the search date
Query/Report Response Availability Available via IQRS for 45 days, previously only available for 30 days
Timely Reporting Notice regarding timeliness of reporting included on the Report Verification
Document (RVD)
NPDB - HIPDB
New Initiatives
Proactive Disclosure Service (PDS)Section 1921: expansion of the NPDB
Proactive Disclosure Service (PDS)
The intent of PDS is to protect the public and improve the quality of health care by providing information to entities as soon as it is received by the Data Banks Average querier receives a new Data Bank report in 302
days Opens as a Prototype on May 1, 2007
Prototype status expected to last 18 months for evaluation purposes
The Current Query Process
Hospitals, other health care entities, including MCOs, State and Federal agencies query the Data Bank by requesting information on a routine schedule
A seamless, secure internet system permits a user to query one or both Data Banks
Users query in preparation for reappointment or during the re-credentialing process (typically every 2 or 3 years)
The query fee is $4.75 per name, per Data Bank
The PDS Process
A subscription service that notifies subscribers of new information on any of their enrolled practitioners within one business day of Data Banks receipt of the information
Notification is sent via email; the entity must log in to retrieve the information
Offered as an alternative to and not a replacement of the current querying method
Report format, information and data reported to the Data Banks will not change
Can use PDS for NPDB, HIPDB or both Fee is $3.25 per enrolled subject / per year
PDS Enrollment
Enrollment Confirmation: An enrollment confirmation confirms that a
practitioner is enrolled in the PDS May be used to demonstrate compliance
with accreditation standards
Enrollment confirmations include Subject information PDS enrollment dates, and Enrollment status
PDS Enrollment
When a practitioner is first enrolled in the PDS, the enrollment confirmation will include all reports on the practitioner to ensure the entity is aware of all existing reports in the Data Banks
This is included in the price of PDS
Enrollment confirmations for enrolled practitioners and previously enrolled practitioners whose enrollments have been cancelled within the last four years will be available, upon demand
Users always have access to all the active reports on a subject
Users always have access to all the active reports on a subject
Report Notification
Other PDS Characteristics
Data Bank report availability:
Report disclosures will be available on the IQRS for 45 days in PDF format
All reports in the Data Banks for each enrolled practitioner will be available upon demand
Other PDS Characteristics
Subscribing to the service:
A 12-month subscription period for each enrollee (practitioner)
The subscription expires on the last day of the same month of the following year
i.e., all practitioners enrolled in May 2007 regardless of the exact date of enrollment will have a subscription expiration date of May 31, 2008
Section 1921
A provision of the Social Security Act as amended by Section 5(b) of the Medicare and Medicaid Patient and Program Protection Act of 1987, as amended by the Omnibus Budget Reconciliation Act of 1990.
Enacted to provide protection to program beneficiaries from questionable health care practitioners and to improve the anti-fraud provisions of Medicare and Medicaid.
Section 1921
Notice of Proposed Rule Making Published in the Federal Register on March 21,
2006 Expected final in October 2007 Expands the NPDB
Major reports Added by Section 1921 Adverse actions or findings by private accrediting
organizations such as: NCQA URAC The Joint Commission The Commission on Accreditation of
Rehabilitation Facilities
Section 1921
Adverse licensure actions taken against all health care practitioners
Broader than issues related to professional competence and conduct
Adds the same type of licensure actions currently reported to the HIPDB
Reportable: without Section 1921
NPDB Medical Malpractice Payments Adverse Actions (physicians and
dentists) Licensure Clinical Privileges* Professional Society
Membership* Medicare and Medicaid Exclusions (all
practitioners) DEA Actions (all practitioners)*other practitioners may be reported
HIPDB* Licensure Actions Medicare and Medicaid Exclusions
and other exclusions from Federal or State Health Care Programs
Health Care Related Criminal Convictions, or Civil Judgments
Other Adjudicated Actions or Contract Terminations
*Practitioners, Providers and Suppliers
Reportable: with Section 1921
NPDB Medical Malpractice Payments Adverse Actions (physicians and
dentists) Licensure Clinical Privileges* Professional Society
Membership* Medicare and Medicaid Exclusions (all
practitioners) DEA Actions (all practitioners)*other practitioners may be reported
HIPDB* Licensure Actions Medicare and Medicaid Exclusions
and other exclusions from Federal or State Health Care Programs
Health Care Related Criminal Convictions, or Civil Judgments
Other Adjudicated Actions or Contract Terminations
*Practitioners, Providers and Suppliers
Section 1921
Access Entities that are currently allowed to
query the NPDB will have access to Section 1921 reports
Entities given access to the NPDB through Section 1921 will be allowed to query ONLY for Section 1921 reports
Web Site - www.npdb-hipdb.hrsa.gov NPDB and HIPDB Guidebooks Interactive Training Brochures and Fact Sheets Statistics Annual Reports Instructions for Reporting and Querying