New Workflow Process for Use of PHI in Complex Procedure Pricing

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RMG/CCTO has developed a new workflow process for use of PHI for complex procedure pricing to ensure minimum necessary access to PHI. The new documents can be found at Coordinator Corner:

In order to approximate a reasonable estimate of hospital charges for a complex procedure, RMG/CCTO requires the assistance of the study team and Patient Financial Services (PFS) to identify previous examples upon which we can develop a reasonable estimate. This is an operational business need.

For more information on best practices, keep on reading.

  • The PI should identify a list of patients (ideally 3-5) known to have completed the required surgery/complex procedure or a very similar procedures within the past year.
  • Dates of service must be at least 3 months old to obtain a complete estimate since it takes time for all the charges to be processed through the billing system.
  • To assure that the minimum necessary access to PHI is maintained, The PI submits patient names, MRNs and dates of service via secure email directly to hospital Patient Financial Services (PFS): Jackie Barajas for technical billing reports and to Judy Guzman for professional billing reports (SHC) or Sydney Piaia (LPCH).
  • PFS runs the reports and strips them of PHI, including names, MRNs and dates of service, then sends to the PI with cc to RMG or CCTO.
  • PFS deletes the original email request from the PI.
  • The MD that will perform the procedure should review and edit the billing reports to remove charges that would likely not be applicable to the study subjects. The reports can be reviewed for consistency, length of time, acuity, pre-operative diagnostics, ICU vs regular bed, etc.
  • Study team/PI sends the edited billing information to RMG/CCTO to incorporate into the study budget. No PHI should be sent to RMG or CCTO.

The de-identified information is added to the workbook on a separate tab and linked to the RPS form in the applicable sections and research discounts are applied. As required by the sponsor’s payment schedule, these charges are included in budgeted per patient fee or calculated as an invoiced item.