Medicare Compliance & Reimbursement

Why you should fax, not snail-mail, medical records to your QIO.

When someone files a quality of care complaint against your organization, you’ll no longer have 30 days to send the medical record to your Quality Improvement Organization (QIO) — now, you’ll have just 14 days.

This severely shortened timeframe is thanks to the recent changes to Chapter 5 of the QIO Manual, which the  Centers for Medicare & Medicaid Services  (CMS) originally published in the final rule back on Nov. 15, 2012, but has now put into place.

Initially set to apply to QIO scope of work beginning Aug. 1, 2014, CMS officials said they pushed back the effective date of the revised regulations until now. In a recent Skilled Nursing Facility (SNF)/Long-Term Care (LTC) Open Door Forum (ODF), CMS officials cited IT enhancements, QIO education and other issues as reasons for the delay in the effective date.

“Some of the more challenging aspects of implementing the new regulations have been the shortened timeline relating to reviews, navigating IT software challenges, and working with a new process that includes revised communication [methods],” a CMS official noted during the ODF. “The changes in QIO regulations that impact QIO operations will impact providers and possibly affect our beneficiaries.”

Your Deadline is Only 14 Days Away

Old way: You used to have 30 days to send in the medical record after you receive a medical record request from your QIO. Your QIO would send you this request after it receives a quality of care complaint or when conducting a general quality of care review.

New way: Now you have 14 days following receipt of a medical record request to send the medical record to your QIO. After receiving the medical record, your QIO then has 30 days to complete its review.

What to Do? Fax Records, Don’t Mail Them

Best bet: Due to this shortened timeline, some QIOs are encouraging providers to fax medical records, instead of sending them via traditional mail. For instance, KEPRO, the Beneficiary and Family Centered Care QIO (BFCC-QIO) for 33 states and the District of Columba, is doing just that. KEPRO has set up its own dedicated fax number for its quality of care department and instructs providers to fax records in its medical record requests.

Faxing the records is crucial, because “the new truncated timeline offers little in the way of a buffer zone should items get held up in the mail,” noted Dawn Crump, MA, SSBB, CHC, Vice President of Audit Management Solutions for HealthPort, in a Sept. 30 analysis for RACmonitor.com, a division of Panacea Healthcare Solutions Inc.

And you will also have a shorter amount of time to submit any follow-up communication to the QIO, Crump warned. “And it appears as though providers may not be told what this new deadline is until they receive the QIO’s initial review (which the QIO still has 30 days to complete).”