New Law effective April 5, 2021 – ONC (Office of National Coordinator)
Your emergency Mandatory Monthly Module consists of nearly twenty pages of documents addressing the major components required to meet the mandates of the new law effective April 5, 2021 from the ONC (Office of National Coordinator).
Not all verbiage and/or all sections of each document will apply to your office. All forms are customizable and parts not applicable can be deleted.
We recommend you create a NEW compliance binder labeled for this law. When documents are demanded by the government you are only required to produce that which is demanded. If you add this compliance to a general binder or HIPAA binder, and produce the entire binder when requested, then the government has the right to investigate anything you send. Only send the minimum and don’t send ANYTHING until you speak with us.
Audit tool.
Helps prove you are meeting the requirement to identify and fix deficiencies in your compliance program. It will help quantify what changes you need to make to be compliant with the new law (and HIPAA rule changes) regarding ‘information blocking’ and what needs to be reflected in your mitigation/action plan as items to be corrected. This will need to be repeated periodically and will be followed up in the MMM program, to assure any changed, updated or forgotten/missed requirements are rectified.
Mitigation/action plan.
Shows that you are in the process of fixing those things, found to be deficient through your audit tool, to approach better compliance.
Written policies.
Details what your beliefs are and what you intend to do as a doctor and office team. These are produced from your mitigation plan to demonstrate the changes you have undertaken to fix deficiencies that require new or altered policy under this new law.
Written procedure.
Details HOW you carry out your new policies to meet requirements of the new law.
Staff and doctor training.
Trains doctors and staff to understand what the requirements are, why your policies are what they are and what procedures you need to follow to help achieve compliance while developing a DEFENDABLE POSITION!
We will have additions, updates and alterations as time goes on and enforcement is monitored.
Time and experience create clarity!
Remember: we are NOT attorneys and are NOT offering legal advice. These are fluid situations that will be ever changing. You are responsible to be current and stay current relative to state and federal laws that regulate your profession. We offer suggestions and assistance that can be utilized, modified or ignored. We make no representation as to the accuracy of our opinions or usefulness of our suggestions or products.
Download New ONC Law – April 5 – Information Blocking Doc
Download ONC Law – FAQ 21st Century Cures Act Final Rules Doc