Date post: | 28-Dec-2015 |
Category: |
Documents |
Upload: | annice-chandler |
View: | 217 times |
Download: | 2 times |
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Special Considerations and Best Practices for Hospital & Medical
Equipment
Bob Mahaney, CPPS
November 14, 2013
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Who is in the room?
New member this year?
First NPMA educational event?
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Who else is in the room?
Type of business?
• University/University Hospital• Contract Property/Federal• State/Local Government• Private
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Regulatory Drivers for Hospital Assets
GAAP – Generally Accepted Accounting Principles
Medicare – Center for Medicare & Medicaid Services (CMS)
AHA - American Hospital Association
HIPAA – Health Insurance Portability and Accountability Act
2013 NPMA Fall ConferenceValue Through Professional Asset Management
GAAP
Generally Accepted Accounting Principles
• Primary guidance
Asset Capitalization Financial Reporting
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Medicare - One
Medicare Cost Reporting (MCR)
• Annual report of statistical and financial data
Used to determine the federal governments liability for care provided to Medicare beneficiaries
Provides CMS with data used to set payment rates
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Medicare - Two
Sets Requirements for Capitalization
• Capitalization Threshold $5,000 – across the board
Does not consider type of asset for threshold
If it lasts more than two years, it must be capital
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Medicare - Three
Sets Requirements for Depreciation
• AHA Estimated Useful Lives of Depreciable Hospital Assets
Separates fixed assets from moveable equipment
May impact your tagging requirements
2013 NPMA Fall ConferenceValue Through Professional Asset Management
HIPAA
High Level View
• Privacy Rule
• Security Rule
• Breach Notification Rule
2013 NPMA Fall ConferenceValue Through Professional Asset Management
HIPAA – Privacy Rule
Privacy Rule
• Maintaining the privacy of patient information Protection of patient data
Not truly asset related
Use screensavers and don’t discuss patient information without a need to know
2013 NPMA Fall ConferenceValue Through Professional Asset Management
HIPAA – Security Rule
“implement policies and procedures that govern the receipt and removal of
hardware and electronic media that contain electronic protected health
information into and out of a facility, and the movement of these items
within a facility.” 45 C.F.R. §164.310(d)(1)
2013 NPMA Fall ConferenceValue Through Professional Asset Management
HIPAA – Breach Notification Rule
Breach - ‘‘breach’’ as the ‘‘unauthorized’’ acquisition,
access, use, or disclosure of protected health
information. Treated as a “discovery”
• Date when known or should have been known
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Mitigation After the Breach
Must demonstrate actions being taken to avoid future breaches
If not, the government may offer suggestions based on NIST’s Recommended Security Control for Federal Information Systems and Organizations
• Could be much more burdensome to meet
2013 NPMA Fall ConferenceValue Through Professional Asset Management
National Institute of Standards and Technology
NIST Control -“develop, document, and maintain[ ] an inventory of information
system components that (a) accurately reflects the current system; (b) is
consistent with the authorization boundary of the information system; (c) is at
the level of granularity deemed necessary for tracking and reporting. . .and (e)
is available for review and audit by designated organizational officials.” NIST
SP 800-53 Rev. 3, Recommended Security Controls for Federal Information
Systems (2009) at Control CM-8
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Offsite Authorization Before Breach
Employee acknowledges that he/she may be financially liable for the loss of or damage to item(s) listed above if the loss or damage results from negligence, intentional act, or failure to exercise reasonable care, safeguards, maintenance, and service (Tex. Gov’t. Code Ann. Sec. 403.275 & 403.276). M. D. Anderson will enforce this restitution requirement in a manner that complies with the Fair labor Standards Act.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Offsite Authorization After Breach
I acknowledge that I may be financially liable for the loss of or damage to the device(s) listed above if the loss or damage results from negligence, intentional act, or failure to exercise reasonable care, safeguards, maintenance, and service (TEX. GOV’T. CODE ANN. §§403.275 & 403.276). MD Anderson will enforce this restitution requirement in a manner that complies with the FAIR LABOR STANDARDS ACT. I have read, understand, and agree to abide by all Information Security and privacy policies concerning the use of MD Anderson computing assets and safeguarding protected health information (PHI). I have read MD Anderson’s Information Resources Acceptable Use Agreement and User Acknowledgement, and I understand that Confidential and Restricted Confidential information, including and especially PHI, must remain on MD Anderson owned or leased devices and is subject to MD Anderson security controls. I attest that if any information on this Agreement changes in any material way (e.g., from Internal Use to Confidential or Restricted Confidential), I will promptly complete a new Agreement.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
HIPAA – Final Comments
Review your asset policies and procedures
• Are you tracking just assets or data devices also?
• Are you using one system or multiple systems?
• Can you identify data devices at the req/PO level?
2013 NPMA Fall ConferenceValue Through Professional Asset Management
X Ray Producing Devices
CT Scanner
Mammography Units
Ultrasound Systems
2013 NPMA Fall ConferenceValue Through Professional Asset Management
CT Scanner – Basic Components
Basic Components
• Gantry
• Console (typically located in an adjacent room)
• Electronics
2013 NPMA Fall ConferenceValue Through Professional Asset Management
CT Scanner - Image
2013 NPMA Fall ConferenceValue Through Professional Asset Management
CT Scanner – Site ID
Site ID Characteristics
• Never changes
• Referenced on the FDA Master Device Equipment Record
• Referenced on all maintenance and vendor work
• Referenced on all upgrades to original asset
2013 NPMA Fall ConferenceValue Through Professional Asset Management
CT Scanner – Site ID
Forklift Upgrade
• Site ID does not change
• Major upgrade to components
• Magnet is not replaced
2013 NPMA Fall ConferenceValue Through Professional Asset Management
CT Scanner – Asset Record
Parent and Child
• Parent - Gantry
Child - Console
Child - Electronics
2013 NPMA Fall ConferenceValue Through Professional Asset Management
CT Scanner – Future Upgrades
Partial disposal and add new child
Keeps the Site ID until final disposition of asset
Can use standard useful life for new child
Offers better tracking of cost and depreciation
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Surgical Instruments
Track in asset management system or expense
Budget guidelines are important to AM. Get involved
Surgical kits – easy target for capital/expense games
Guideline Example - A set or case of surgical instruments estimated at $5,000 or greater are a valid capital equipment request provided that at least one item in the set has a minimum unit cost of $5,000.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Inventory Tracking Improvements
Medical equipment requiring maintenance or calibration
• Obtain maintenance and calibration records from department responsible for providing this service.
Have them scan asset tags when they scan serial #
Best of both worlds: tag scan for inventory and serial # validation for tag on asset record
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Inventory Tracking Improvements
Hospital Beds
• Cleaned after each use
Make scanning the asset tag part of their routine
Tag scans can be used to support their documentation and give you a inventory hit
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Inventory Tracking Improvements
Equipment carts with laptops
• Have maintenance/calibration team scan the asset tags
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Making Tracking Improvements
Identify departments that routinely touch assets
Meet with them frequently
Find a benefit for them to scan and use the asset tag
Bring a scanner• Bring enough to go around
Follow up….follow up….follow up
2013 NPMA Fall ConferenceValue Through Professional Asset Management
The Wrap
GAAP and Medicare
• Consistent application of institutional accounting policies
• Don’t violate you own policies for any accommodation It will be selected from a random sample Never fails to be selected
2013 NPMA Fall ConferenceValue Through Professional Asset Management
The Wrap
More Medicare
• Be prepared to support differences in capital thresholds
• Be able to defend useful life assigned to assets
• Decide how much, if any, building service equipment will be tagged and tracked separately from the building
2013 NPMA Fall ConferenceValue Through Professional Asset Management
The Wrap
HIPAA
• Don’t have a breach
• Review all asset and data device tracking policies
• Get a seat at the table
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Questions
Remember – Bring something you learned
back to your workplace.