Archive for April, 2016

April 29, 2016

But It’s Not An Ulcer!- Part Two

In addition to the comment about how can it be a stage 1 ulcer when the skin is intact?……How often have you heard – “I’m certain it’s only a stage 2, it’s not a very deep wound!”

The recently released NPUAP guidelines for pressure injury staging includes clarifications that will assist with promoting accurate documentation and may positively impact your reimbursement and outcomes.

Assessing wounds can be confusing, especially when it comes to wound areas caused by unrelieved pressure.  As we know, physicians are the ones who must diagnose the wound type (in this topic referring to pressure), nursing can then define the stage.

Looking forward to CMS adopting the new terminology for OASIS and as it correlates for coding. WOCN will be discussing the updates as approved by the NPUAP in June.

Whether or not these changes make it to the OASIS C2 before it is implemented in January 2017 is questionable. The IMPACT Act has pushed for changes in standardized, cross-setting measures for post-acute care, so it may be impossible for CMS to switch gears and make such changes across the board for all post-acute settings. Included in the IMPACT Act are several quality measure domains updates. The first data collection to be standardized across all care settings are the skin integrity and medication reconciliation domains.

Thanks to guest bloggers, Sue Kennedy, RN, BS, CWOCN, FACCWS, and Debbie Ritter, RN, BSN, CWOCN, FACCWS owners of RitKen & Associates, LLC for their update on WOCN.

Sue can be reached at and Debbie at

Selman-Holman & Associates, LLC will have RitKen & Associates, LLC participate in some education offerings very soon regarding the changes in pressure ulcer guidelines.

Click here to read the original Press Release from NPUAP.

April 28, 2016

Office of Civil Rights Initiates Phase 2 of HIPAA Audits

Author: Gary Moss, April 2016


In 2011, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) was designated to support a pilot audit program. The objectives of these Phase 1 audits were to assess the controls and processes implemented by covered entities under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act. These regulations were established to require the privacy of protected health information (PHI), security of electronic PHI and breach notification.

On March 31, 2014, the OCR announced its plan for the Phase 2 audits, revising its audit program to include areas such as security risk assessments, ongoing risk mitigation plans and breach notification procedures. This phase also will include business associates, in addition to covered entities.

The OCR recently announced it has initiated the Phase 2 audits. The process begins with verification of an entity’s address and contact information. An email will be sent to covered entities and business associates requesting that all contact information be provided to the OCR on a timely basis.

The next step will include the transmission of a pre-audit questionnaire designed to gather data about the potential auditees. Combined with other data, this information will be used to create potential auditee pools. Responding to this request is critical, since the OCR will use publicly available information if an entity doesn’t respond. Using this alternative information, the OCR still may select an entity for an audit or subject it to a compliance review. Note:  Organizations should check their spam folders during the email notification process in case the OCR email is filtered or virus-protected.

As organizations continue to enhance their HIPAA programs to reduce the risk of PHI breaches and develop initiatives that will help prepare them for a potential OCR audit, these steps are key:

  • Perform comprehensive, periodic risk analyses
  • Maintain a current catalogue or repository of all business associate arrangements
  • Document encryption capabilities
  • Maintain updated, reviewed and approved HIPAA program and breach notification policies and procedures
  • Document all security training that’s been conducted
  • Maintain an inventory of all areas, including devices and databases, where PHI is stored

In the interest of being transparent about the audit process, the OCR’s updated protocols and audit program will be available on the agency’s website as the 2016 audit dates approach. These materials can be used by organizations to direct their internal self-audits as an additional component of their HIPAA compliance activities.

For more information, contact your BKD advisor.


April 15, 2016


The new set of ICD10 codes has been released. That’s right, there are more codes coming. They will be implemented on October 1, 2016. Let Selman-Holman & Associates be your guide to learning and understanding the newly released codes.

Our Code Pro University modules will be updated and we will be hosting a webinar in July. Be sure to sign up for our mailing list at You will receive email notices when the webinar and modules are available, and much more.


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April 15, 2016


Ever have one of those arguments about a Stage I pressure ulcer because the other person in the argument kept saying: “But there’s no ulcer. How can I document an ulcer?”

New terminology released by the National Pressure Ulcer Advisory Panel (NPUAP) will make you happy. Pressure ‘ulcers’ will no longer be known as ulcers. They will be known as ‘pressure injuries’ and the NPUAP will become NPIAP. That’s just one of the many changes that were made at the NPUAP meeting on April 8-9.npuap-logo

Other changes:  Just when we got used to returning to using Roman numerals to indicate stages, we’re going back to Arabic numerals (1, 2, 3, 4). Mention of friction contributing to pressure injuries has been removed.

Better, fuller descriptions of stages has been added, as well as other definitions for conditions that should not be documented as pressure injuries.

What’s next? CMS will need to adopt the new terminology for OASIS and the titles in the coding manual will need to be updated. The coding manual already uses Arabic numerals and doesn’t use the phrase ‘suspected’ deep tissue injury.

Here’s the link to the News Release:

Selman-Holman & Associates will be announcing a webinar and other on-site opportunities to learn about pressure ulcers, stasis ulcers and more very soon. Be sure to add yourself to our contact list for more updates.