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Issue #10 




A Note from the CEO


Dear Reader, 


The external forces that are shaping healthcare delivery became stronger and more focused in 2012 with increasing emphasis on quality reporting, bundled payments, accountable care and the implementation of information technology solutions. In response to these forces, healthcare providers have been working hard to break down the silos of healthcare and create collaboration among the variety of services that comprise their delivery systems. What we saw last year and what we will continue to see over the next few years is a concerted push for more coordinated care with better patient safety and quality outcomes... all done at a lower cost. 


In this industry, the landscape is always changing; we continually face a complex set of systemic, regulatory and technological hurdles. For this reason, it is important that healthcare contractors, insurers and providers have the knowledge and tools to meet the challenges of the present, while remaining keen and nimble enough to react to the challenges of the fast approaching future. This edition of the Clarity Post spotlights a few of the top issues dominating healthcare right now and some of the ways we can work through the complexities of the industry together.  


Anna Marie Hajek

President & CEO

Clarity Group, Inc.


Healthcare News & Trends



Patient Safety Awareness



Celebrate Patient Safety Awareness Week March 3 - 9!


We at Clarity are proud to be a yearly participant in Patient Safety Awareness Week. In our role as a dedicated Healthcare Risk-Quality-Safety (RQS) organization, our mission has always been to manage professional liability risk for our clients, first and foremost, by enhancing the culture of patient safety at their organizations. We join the National Patient Safety Foundation (NPSF) and other healthcare organizations across the country in spreading this year's theme, Patient Safety 7/365: 7 days of recognition, 365 days of commitment to safe care.


Clarity strives to promote patient safety year-round as part of our commitment to our clients and the industry as a whole, but this year's theme ties directly in with one of our core missions, which is translating awareness into actionable knowledge. We take this week to honor and recognize the achievements made so far by our clients and the entire healthcare industry, but we know that it takes a holistic, year-round commitment to improve patient safety in measurable ways.


For a few tips from Clarity on how you can increase patient safety knowledge and awareness at your organization, click here


All Things Rural



Rural Gets Up to Speed


Toward the end of last year, the Federal Communications Commission (FCC) approved the establishment of the Healthcare Connect Fund (HCF) and the Skilled Nursing Facility (SNF) Pilot Program. The creation of these two programs, together with some reforms to the Rural Health Care Telecommunications Program, will give eligible rural healthcare providers access to funds for installing or enhancing high-capacity broadband internet service at a variety of facilities used for healthcare purposes.


For many, this increased internet capacity will pave the way to realizing the potential of things like electronic health records, data sharing, online training, web-based incident reporting and other health information technologies, which all contribute to increasing the culture of safety at healthcare organizations. For more information on these new programs, which are set to take effect in early 2014, click here.


NRHA Webinar - Reducing Risk Exposure in Rural Facilities


Contributor/Speaker: Heather Annolino, RN, MBA, CPHRM, Director, RQS Consulting Services, Clarity Group, Inc. 


Clarity is committed to providing content-rich educational opportunities through the National Rural Health Association's (NRHA) free webinar series. On February 13, we sponsored our latest webinar, Reducing Risk Exposure in Rural Facilities.


You are living in a changing least in terms of the forces affecting healthcare delivery today. As the delivery system evolves, potential risk exposures do as well. Taking an enterprise-wide approach to managing risk, quality and safety affords an open view of potential exposure areas and applying solid risk management processes can help mitigate those exposures. After listening to this webinar, you will be able to identify the basics of Enterprise Risk Management, recognize common risk exposures in different healthcare settings and apply several proactive risk management strategies to modify and more effectively manage those exposures.


Highlights from the webinar: 


First, what is Enterprise Risk Management (ERM)? ERM uses a process or framework for assessing, evaluating and measuring all of an organization's risks. ERM quantifies risks to assist in prioritizing significance, groups them into components or "domains" looking for inter-dependency, and devises strategies to manage each across the enterprise. By employing these different strategies at your organization, you are ultimately breaking down silos, opening up communication across the entire system of care and increasing risk management awareness in a changing healthcare landscape.


The following is a sample of domains discussed during the webinar and strategies related to the risks inherent to that area.

  1. Human Capital
    • Ensure hiring practices are proactive and conform to legal requirements
    • Clearly define and disseminate employment practice policies
    • Promote a safe workplace environment
  2. Clinical Risk
    • Establish processes for initial and ongoing evaluations of patients/residents
    • Prepare patient/resident/family for movement within the continuum
    • Assess staff competencies
  3. Operational
    • Formalize credentialing process for all levels of independent practitioners
    • Implement a communication process and tool to set expectations for services and outcomes
    • Develop a workplace violence prevention program
    • Monitor compliance with infection control practices
  4. Customer and Community
    • Ensure marketing materials convey realistic expectations and services
    • Evaluate patient, resident, family and employee satisfaction annually
    • Establish policy for media control
  5. Technology
    • Establish procedures to integrate new technologies into the organization
    • Ensure processes are in place to manage, store and maintain electronic data
    • Determine protocols for use of new technology services
  6. Legal/Regulatory
    • Establish medical information privacy protocols
    • Comply with regulations related to employment practices, billing practices and financial reporting requirements
To learn more about Enterprise Risk Management in the rural healthcare setting, listen to the webinar


Data & Security



HIPAA Omnibus Rule - Some Things You Need to Know


Contributor: Heather Annolino, RN, MBA, CPHRM, Director, RQS Consulting Services, Clarity Group, Inc.


"These changes not only greatly enhance a patient's privacy rights and protections, but also strengthen the ability of my office to vigorously enforce HIPAA privacy and security..." -- HHS Office for Civil Rights Director, Leon Rodriguez


On January 17, 2013, The Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS) released the much-anticipated, omnibus final privacy rule, which modifies the Health Insurance Portability and Accountability Act (HIPAA) of 1996. The new rule goes into effect March 26, 2013 and compliance is required by September 23, 2013.


The final omnibus rule enhances a patient's privacy protections, changes a covered entity's notice of privacy practices, provides individuals new rights to their health information, strengthens the ability to enforce the law, and requires updates to business associate contracts.


Some changes in the new rule:

  • Improper use or disclosure of protected health information (PHI) is presumed to be a breach requiring notification, unless the covered entity or business associate demonstrates through a risk assessment that there is a "low probability that the PHI has been compromised" or unless an exception applies. Eliminates the significant risk of harm threshold
  • Business associates are directly liable for HIPAA compliance. Agreements need to be revised
  • The revised definition treats certain subcontractors of the business associate as direct business associates, expanding all the same compliance obligations and liability exposures to the subcontractors
  • Significant changes with respect to marketing communications. Strengthening of the opt-out rights of individuals and expanded limits to the type of PHI that may be used or disclosed for fundraising purposes
  • Retains penalties and makes some modifications to strengthen enforcement to the HITECH Act
  • Disclosure of proof of immunizations to schools allows parents to verbally authorize records to be disclosed to the school
  • Prohibits health plans from using or disclosing genetic information for underwriting purposes and increases privacy protections for genetic information as required by the Genetic Information Nondiscrimination Act (GINA) of 2008

To learn more about the Omnibus Final Privacy Rule, click here.


Clinical Risk Management Issues



Avoiding Copy & Paste Errors in EMRs


In the last issue of the Clarity Post, we brought you a short list of things to consider and prepare for as you transition from paper medical records to an electronic medical record (EMR). Now that many healthcare organizations have implemented new systems, trends are already emerging. One trend that has been identified and poses risks to the organization and its patients is the act of copying and pasting information.


In one example, at Yale-New Haven Hospital in Connecticut, an intern copied and pasted a note in a patient's electronic health record (EHR) without updating it. The note, "Patient needs drainage, may need OR" appeared in the patient's electronic health record for several days, even after the surgical team successfully drained the abscess. The note was not updated leading to confusion among the staff. The patient's health was put at risk because the patient's antibiotic regimen was almost changed before someone realized what had happened. 


While copying and pasting may help make reporting faster and easier, it can be very problematic when you have multiple people tending to a patient and using an electronic health record as the main communication tool. If this method is going to be used, it needs to be done so with caution and the information needs to be updated appropriately.  

To avoid copy and paste errors, here are a few guidelines put forth by Weill Cornell Medical College's Dept. of Medicine:

  • Avoid copying and pasting of text from another person's note without attribution, as that is plagiarism and may constitute billing fraud
  • Avoid repetitive copying and pasting of laboratory results and radiology reports
  • Note important results with proper context, and document any resulting actions. Avoid wholesale inclusion of information readily available elsewhere in the EHR because that creates clutter and may adversely affect note readability
  • Review and update as appropriate any shared information found elsewhere in the electronic record (e.g., problems, allergies, medications) that is included in a note
  • Include previous history critical to longitudinal care in the outpatient setting, as long as it is always reviewed and updated. Copying and pasting other elements of the history, physical examination or formulations is risky, as errors in editing may jeopardize the credibility of the entire note
Source: "Electronic Health Record Documentation Guidelines V 1.2, 2012-2013," Dept. of Medicine, Weill Cornell Medical College, New York-Presbyterian Hospital

Patient Safety Organizations



Coming Soon! - Clarity PSO White Paper


Nursing Quality and Peer Review Programs - Tools and Strategies for Fostering a Just Culture of Safety

This white paper will discuss how two healthcare providers that manage nursing peer review and nursing quality programs are working together under the protections of Clarity PSO to identify interventions and strategies that support patient safety, nursing professionalism, leadership and a just culture. Keep a lookout for Clarity PSO's white paper to learn about the strategies and how you can use them within your organization.


If you cannot wait for the white paper, listen to our webinar, Nursing Peer Review - A Paradigm Shift in Improving Quality in Today's Healthcare Environment. This webinar focuses on how Cone Health in Greensboro, NC and Tallahassee Memorial HealthCare in Tallahassee, FL have created nursing peer review and nursing quality programs to improve professional performance and nursing care systems within their local facilities. We also discuss how Clarity PSO provides these members with a platform to share strategies and nursing concerns in a protected environment as afforded under the Patient Safety Quality Improvement Act (PSQIA).  


Clarity PSO Learning Series: #1 Medication Safety


Contributor: Tom Piotrowski, RN, MSN, CSSGB, Executive Director of Clarity PSO


Just Released!


As part of Clarity's role as one of the nation's earliest and most trusted Patient Safety Organizations, Clarity PSO has just released the first in our newest series of online educational tools. Since data is meaningless without knowledge, and knowledge is pointless without action, we are pleased to publish what we are "learning" through our analyses of incident data reported by our PSO clients. Each of the reports will include our findings on a given topic and our recommendations on how to use knowledge to mitigate risk and improve patient safety.


For our first subject, we looked at medication errors. High-alert medication lists are well known, and though they vary, many organizations see overlap in the drugs that are involved in errors and incident/event reports. These medications are identified as such due to a combination of characteristics, including unique/strict dosing parameters, the ability to alter mental and physical status, monitoring requirements such as laboratory results, and high volume utilization. These characteristics mean that these medications are involved in either/both a relatively high number of medication-related incidents or those events that have great potential for harm. The hope is that with the knowledge and attention surrounding these particular medications and well-constructed implementation changes, the incidence rate of errors involving these medications will decrease over time.


Clarity PSO conducted several studies on data reported from our client organizations. From our analyses of Common Format medication error reporting, it is clear that despite all of the attention surrounding "high-alert" medications, many of them remain the more frequently reported medications classified in events reported to the PSO.


To read the full report and learn more about Clarity PSO's findings, click here.


Clarity Spotlight



Upcoming Events


Stop by our booth at the following conferences:


March 19 - 21, 2013

Red Lion Hotel at the Park
Spokane, WA

Booth #63


The 16th Annual Michigan Rural Health Conference

April 11 - 12, 2013

Soaring Eagle Casino & Resort

Mt. Pleasant, MI


NRHA's 36th Annual Rural Health Conference
May 7 - 10, 2013

Kentucky International Convention Center

Louisville, KY
Booth #316 



Phone: 773-864-8280       Email:      Website:       Twitter: @claritygrp



This newsletter contains links to sites which are not owned or maintained by Clarity Group, Inc. Clarity Group is not responsible for the content of non-Clarity Group linked sites, and the views expressed on non-Clarity Group sites do not necessarily reflect the views of Clarity Group, Inc.


This information is provided for informational and educational purposes only and should not be construed as financial, medical and/or legal advice. Specific questions regarding this information should be addressed to local advisors and legal counsel. 2013 Clarity Group, Inc. All rights reserved.