If you are printing clinical documents to paper, you can hand it to the patient at the end of a visit. If it is not ready at the end of the visit you can inform the patient they can return and pick it up in 3 business days. If the patient does not return for the document and has not refused the receipt, you must mail it to the patient. If you facility has a website and a working patient portal that patients can become secure users, you have met the requirement by making the summary available to them on the portal. The patient does not have to have an active account or you do not need to monitor if the patient has viewed the summary for this summary to be included in the “provided” numerator count. However, if a patient requests a printed copy even though it is available in their portal, you must supply the written copy.
You can put an electronic copy of the summary on electronic media devices such as a CD or flash drive. These devices can be supplied by you or the patient. There are challenges to methods. Your staff that is responsible for adding electronic documents to external devices need to understand the procedures and HIPAA concerns. Using a patient’s device is risky for damage, using a device you supply can be much too costly.
So what if a patient refuses the summary but your certified technology only records the “provided” when it is printed? Remembering that if you ask a patient if they would like a copy of the visit summary and they refuse it, that is still counted in your “provided” numerator count. So the solution here is to print to a “virtual” printer. It never actually produces a piece of paper but the system counts it as “provided”. Be careful on this method and be sure the actual personal health information isn’t being stored on a computer where it is not considered secure and would pose a HIPAA violation.
Stay tuned for Part 2 and more information on providing a clinical summary to patients to meet meaningful use.