First Class Solutions, Inc.℠

Serving the Healthcare Industry Since 1988
Consulting Services
5 Star Service
Excellent Results
Management Consulting
Our experienced consultants understand the importance of integrating systems, structure, strategy, culture, people, skills, and work processes based on an organization’s core values and goals. We have been providing health information related consulting services since 1988. Like Farmers Insurance, “we’ve seen a thing or two!” Some good…some bad… We apply the Best and Better Practices we have seen or implemented to benefit your organization.

Our management consulting services are in the health information, health information/revenue integrity and information governance areas and include Health Information Department Management and Practices, Accreditation Preparation, HIPAA, Compliance, Strategic Planning, Revenue Cycle concerns, and a host of related services for small and large acute and long-term acute care hospitals, skilled nursing and long-term care facilities, physician practices and other ambulatory programs, specialty sites, health departments, and, yes, even other consulting firms.

However, in 2017, we added a new area of consulting to meet the needs of our clients: Human Subject Research Compliance and Operational Services.

See our services  below.

We are not your traditional healthcare consulting firm…We are proud to provide you tailored services to meet your needs.
Operational Assessments - Whole Department or Just a Function:
Known for our comprehensive operational assessments, these services are ideal for identifying information governance voids, workflow improvement opportunities, staffing, space, and scheduling adjustments, and ways to improve cashflow and benefit the revenue cycle we often identify opportunities to absorb work from others and more effectively serve the department’s customers. Operational assessments are conducted by experienced Health Information Professionals who will thoroughly review each aspect of your daily operation and the HIM department’s effectiveness in the revenue cycle.

Our assessments of the HIM department includes an extensive review of all functions and interviews with key customers and revenue cycle partners, such as, Access, Patient Financial Services, Denial Management, Emergency Department, Risk Management, and Human Resources. The assessment incorporates systems used, policies and procedures, revenue cycle enhancement, and sensing the mood of the department. Each available employee is interviewed to allow us to understand the unique record processing activities from chart creation to completion. Coding quality validations are an optional component available for an assessment engagement.

Compliance related issues, redundant and out dated work efforts, labor relation concerns, and non-essential resource use may be surfaced during the assessments. Clients have utilized these assessments to establish action plans for department leadership, explain Premier (or other benchmarking reports) variations, and occasionally to justify staffing and capital requests.

Our operational assessments can be scaled to apply to one or two functions, such as document imaging or HIPAA privacy readiness. Additionally, we can apply the same techniques to other departments.

For document imaging, it is important to stream line this activity as clinicians, coders, case manager, and other members of the healthcare team need patient information now. They cannot wait several days for the scanning team to pick-up, prep, scan and index the documents. Serious patient care errors can occur in the interim. We assess the scanning team’s schedule, staffing workflow, productivity, office layout and technology. The assessment goes beyond the scanning operation, however. It includes understanding where the source documents are created, when and by whom, to allow us to recommend a schedule that accommodates the scanning operation’s clients and to identify opportunities to eliminate paper source documents from the get-go.

For HIPAA, your policies and procedures need to reflect your practices today and address each of the HIPAA requirements and recognize that HIPAA rules may not be same as those required by the Substance Abuse and Mental Health Services Administration (SAMHSA). Our assessments include walk-throughs in your organization at different times of the days, asking staff questions to test their awareness of your HIPAA and/or SAMHSA policies and understand their responsibility with certain privacy practices, confirming that valid business associate agreements are in place, and verifying that forms, policies and applicable procedures apply for each of the regulations. Our comprehensive assessment is conducted by certified privacy and security professionals. We also can assist you with your risk management activities including assisting with breach investigations and developing an incident response, corrective action/mitigation plan.
Documentation Improvement Services:
Improving reimbursement requires accurate coding based on comprehensive physician documentation that supports the care provided to the patient. We work closely with utilization/case management, coding professionals, and clinicians on proper documentation techniques. Our documentation improvement services are tailored to your organization.

Healthcare organizations must find innovative ways to deliver care efficiently while maintaining high quality standards for patient and customer service. Today, no provider can be “average.” Therefore, we do not expect your staffing needs to be the “average” of your peers. Our staffing analysis is not “cookbook” based. Our consultants dissect your Premier or other benchmark data to determine the cause(s) of the variances. They will study each employee’s duties, the flow and load of work, and the demands through the day and week. Coupled with the unique characteristics of your organization and this data, our consultant will recommend staffing that will meet your work demands.

During any staffing analysis, we consider the effectiveness of the management structure and workflow bottlenecks related to physical layout, virtual work environments, interdepartmental coordination, and organization’s policies and procedures. From this analysis, we are able to project a department’s organization structure, staffing protocols, monitoring techniques, productivity standards (inclusive of incentive plans, if applicable), coverage schedules, and training needs. We can assist your management staff in any reengineering efforts and change agent facilitation
Space Analysis and Warehouse Assessments:
For your Health Information, Coding, Document Scanning, or Case Management Services: Out of space? Planning a new department? Attempting to predict space needs for the future? Our consultants will work with you to design a space that compliments a logistically sound workflow. Our space planning affiliates will identify equipment and furnishings to meet your needs.

Have a warehouse full of who knows what? We have tackled warehouses stuffed to the gills, in total disarray, with leaking ceilings, and worse! We will assess the contents, identify what can go and drag it out of the rubble, organize the remaining and/or offer options to make it “disappear” yet remain accessible to allow you to close or use the warehouse for more pressing purposes.

Inservice Training Programs, Onsite or Audio Seminars:

Staff education programs can be tailored to your needs for a variety of subjects that include, but are not limited to:
• Release of Information, Confidentiality, Disclosure Management, Amendments, Legal Health Record/Designated Record Set, and e-Discovery,
• Privacy and Security or HIPAA, in general, and
• Coding education for coders or providers.
Policy and Procedure Manual Updating and/or Preparation:
As new regulatory and accreditation changes are introduced, policy and procedure manuals must be updated. Our consultants review the procedures with those doing the job to determine if the procedure is accurate, needs revision, or no longer exists. Policies are updated based on those regulations impacting your organization, including, accreditation agencies, State, Federal, HHS, CMS, HIPAA, OIG, OCR, and others regulatory entities.
Accreditation Preparation:
Clients have options today for their accreditation services. Regardless of the entity chosen to perform the accreditation survey, all surveys focus on quality, patient safety, regulatory compliance, demonstrable policies and procedures, leadership, and clinical competence. One department or hospital-wide, our professionals can assist and lighten the burden on your staff. We have “experienced” surveys be and are available to facilitate your organization’s preparation.
• Initial readiness assessment
• Corrective Action Plan development
• Action plan monitoring and “prodding”
• Model sharing to avoid starting from scratch
• Tips from other experiences
• Staff education
• Policy and procedure review and updating
• Medical staff bylaw, rule, and regulation review and modification
• Credentialing guidance
Strategic Planning Facilitation:
For organization leadership, our consultants can facilitate your biennial or one-in-awhile strategic planning initiatives. These programs are designed to introduce planning techniques to new Boards and leadership and to assist Boards and leadership in updating old and out of date strategic plans.

Teaching Boards the fundamentals of strategic planning and distinguishing the Board’s role from operational management is the cornerstone of our strategic planning services. Concepts such as SWOT and 4DX are used to define opportunities and craft important goals for the organization.

Topics such as conflicts of interest, ethical decision making, HIPAA, compliance and overall government expectations for a compliance program can be incorporated in the planning session.
Specific Program Evaluations:

Sometimes a focused review of a condition is needed. It could be for a/an:


               •    rise in claim denials,

               •    storage facility with records and who knows what that has been left in disarray,

               •    increase in physician or patient complaints,

               •    overly complex, out of date, and confusing medical staff rules and regulations, or

               •    increased mis-scanned documents.


We have experience with situations similar to these and for your organization, we will trace the work processes and thoroughly investigate the condition to make recommendations that will improve the situation.


Over time it is necessary to re-assess whether a program should continue as is, be modified, or eliminated. It’s difficult to do this type of review when you’re too close to the program. Our consultants have assessed the need to continue with in-house services such as transcription and document scanning or outsource it, and with outsourced services such as coding and release of information or bring it back in-house. 


You decide what you want us to do and not do. We can evaluate options, speak with existing staff and your Human Resources/Talent Management department, if needed, create RFPs and obtain proposals, work through contracts, define the key actions that need to be taken, and manage the transition of onboarding or offboarding.


Clinical Pertinence, Closed or Open Record Studies, Record Audits, Data Abstraction:


Need data collected for state, federal, accrediting, or research requirements? We can assemble a team of abstractors to review records for designated documentation elements, completeness, and/or other purposes


Physician Practice Services:


Our expertise includes large and small physician practices. Physician practices require customized services to meet their needs, the regulatory environment, and their budget. We will assist you in building an effective professional fee billing infrastructure that includes:


              An appropriate organizational model

              Transparency, standards, and controls

              An appropriate coding and compliance model

              ICD-10 and E&M 2021 comfort level


We offer support in the following areas for physician practices

• Coding, Information Governance and Analytics:
Coding is critical for the practice’s fiscal health but also serves as the tool that defines the complexity of care being provided and the provider’s public profile. Our coding professionals are available to coach you on E&M, CPT, HCCs, and, of course, ICD-10. Governing your data through accurate and complete coding allows you to build a public profile with the correct information about your practice.
• Entering a risk arrangement with a health plan?
You’ll need to understand the hierarchical condition categories (HCCs). These are used in Medicare Advantage, Affordable Care Act (ACA) and other commercial risk adjusted programs. Our professionals are certified risk coding specialists. We know the documentation and coding rules and will explain why E&M is no longer the driver of your reimbursement. We can analyze your existing coding data and identify opportunities for improvement.
• Uncertain whether your coding is correct?
CMS indicates that it will audit 20% of all providers billing Medicare. CMS’s audit focus will be to find documentation that is insufficient to justify codes for services billed. CMS brings extra muscle to the table by using the Recovery Audit Contractors and Risk Adjusted Valuation Contractor to do the audits. Fiscal penalties can be substantial. Our consultants know and understand the CMS compliance rules and use them to determine whether your documentation meets CMS’s stated documentation requirements. We will assess your documentation to determine if you’re capturing all the conditions that should be coded but are often overlooked (for example, pain) and then our coding professionals can educate you on how to improve your coding and documentation. These additional conditions may help achieve some of your MIPS measures.
• Received a letter from CERT?
Not certain what to do? Call us to help you analyze the CERT’s findings and assist you in evaluating next steps and a response.
• Are your “favorites” being denied?
We can assess your EHR favorite codes and your denials to determine whether the conditions that have been earmarked for your ease lack the specificity needed to meet medical necessity.
• Still using a superbill? 
Our coding professionals can update your superbill(s) with new ICD-10CM and CPT codes. Avoid billing edits and denials for using of outdated codes.
• HIM/medical records related services: 
Our credentialed professionals can assist you with all medical record aspects of your practice:
Your EHR may be missing important documentation that is required to meet regulatory expectations, but more so there could be issues with your EHR creating documentation without your knowledge or that does not represent the services you provided. 
We can arrange for one of our credentialed health information professionals to assess your situation and guide you through the mine fields.
• HIPAA Privacy/Security: 
Coupled with your medical record challenges, there are regulatory hurdles that must be addressed with HIPAA and The Substance Abuse and Mental Health Services Administration (SAMHSA) requirements. Our consultants will help you recognize the relationship between your paper or electronic records and:
• how to respond to an e-discovery request and
• what you’re required to do when a patient requests access to their records.
We believe there are many benefits to having a compliant office environment. When your team works in a culture that understands, promotes, and respects compliant practices, you will likely experience improved communication, complement your quality and risk initiatives, enhance your reimbursement, and drive patient satisfaction
Human Subject Research Compliance: Program and Operational Consulting Services
We launched our research compliance program and operational consulting services in 2017 after recognizing that organizations often need assistance in ensuring that their research activities comply with all research related regulations to protect the participants during research.

Our research compliance consultants are available to provide services domestically and globally for every aspect of your research compliance and/or research quality assurance program, whether it be:
• ad-hoc staffing needs,
• top-down review of your entire program,
• execution of the research itself to ensure compliance,
• research study startup to closeout.
Our Research Compliance consulting portfolio includes:
Research Integrity:
• Education and training for responsible conduct of research both to improve your existing program offerings and also to satisfy federal requirements.
Program Formation and Policy Management:
• Whether you need to improve your existing integrity program and policy, or are starting from scratch, we are able to assist you in establishing a solid infrastructure and proper policies to ensure your program is compliant with the Office of Research Integrity (ORI) and Department of Health and Human Services (DHHS) expectations.
Research Misconduct:
• We can provide guidance in how to structure your Allegation, Inquiry, and Investigation phases, or provide these services if your organization doesn’t have the resources available.
• We will assist you in understanding the sequestration (data collection) processes and requirements as defined by the federal Office of Research Integrity (ORI) as well as assisting you in the data collection.
• We can help you vet candidates or engage a forensics specialist.
• Building relationships with the federal ORI in the face of misconduct findings is essential. We have a presence in the ORI community and will assist you in navigating research misconduct investigations
Research Compliance:
• Staffing and Evaluation: Assessing your current workforce and assisting in education and retention measures.
• Regulatory and Compliance Infrastructure: Reviewing your organizational chart, positions, determining needs for resource requests, and logistical support with building your program.
Human Research Protection Program (HRPP):
• Building your HRPP from scratch or assessing and refining of your existing HRPP, and
• HRPP consulting in areas such as conflicts of interest, grant writing, contract negotiation, program budget planning.
Institutional Review Board(s) (IRB)
• Creation of an IRB charter and structure for your organization,
• Membership/Recruitment for your existing IRB,
• Workflow analysis geared toward performance improvement and increased productivity with limited resources,
• Virtual management of your IRB,
• Regulatory evaluation of your infrastructure, and
• IRB Policy and procedure creation and maintenance.
Human Subject Administration
• Assisting with interviewing potential staff members,
• Constructing and updating your compliance/business plan, and
• Organizational planning including: Recommending your initial infrastructure, evaluation of current infrastructure, and, if necessary, assist you in launching a complete reorganization.
Auditing/Monitoring
• Creation of auditing/monitoring plans,
• Defining committees for data safety monitoring needs,
• Committee management,
• Performing auditing and monitoring for your program, and
• Providing pre-audit preparation for external governing bodies, sponsors, governmental agencies, accrediting bodies.
Association for Accreditation of Human Research Protection Programs (AAHRPP)
• Application preparation for accreditation,
• Preparing your team for initial or ongoing accreditation site visits, and
• Implementing changes in response to site visits.
Research Compliance Plan/Program
Ensuring your plan includes the essential processes:
• Evaluation and assessment
• Process Improvement,
• Program Development,
• Risk Mitigation, and
• Navigating unexpected FDA, IRB, or other regulatory entity unplanned visits.
Education
Educating staff or preparing materials and resources for your staff to conduct the education yourself and
Assistance with obtaining vital certifications:
• Deciding which certifications best suit your organization strategically,
• Building employee professional development programs, and
• Preparation materials for individuals taking exams.
With our experience across every angle of the research enterprise, plus our access to industry professionals for one-off needs, our team provides comprehensive resources for your organization’s research compliance needs.
Department Vacancy Relief
About Our Management Consultants:
Our team comes to you equipped to handle today’s problems. And today’s health information management (HIM) environment is one that is dynamically changing. Unlike past years when the health information management department was a physical location within the organization housing some paper records but working within electronic health records, the HIM department has evolved into a different structure. HIM today is partially virtual, decentralized, and entrenched in information governance for the healthcare organization. It has taken on information security roles, data analytics and data mining of the entity’s Big Data, oversees privacy controls, disclosures,blocking and release of information practices, ensures revenue integrity through coding an CDI integrity, monitors patient identity, and governs the health information of your patients from a broader spectrum than the historical paper record days.

Today’s Health Information Management and Health Information Integrity directors are responding to challenges unlike the past and need to think “outside” the traditional 4 walls of yesteryear. They must play an integral role in EHR enhancement, staff productivity, cost reduction, regulatory compliance, external audit intrusions, revenue cycle enhancement, privacy protections, and a myriad of hotspots percolating in our industry. Additionally, these directors must serve as a change agent to streamline information governance throughout the organization and motivate staff to adopt change, focus on customer relations, encourage innovation, and foster collaboration within the healthcare organization and the community served.

Our team of professionals will be visionaries for your health information integrity activities and actively participate in creating solutions for the future information demands of your healthcare delivery system.

Finding an innovative Director or Manager for your HIM, and Coding Departments takes time. In the interim, these critical functions can drift off-course with a significant impact on your cashflow, the revenue cycle, privacy monitoring, and release of information disclosures. 

Our approach to vacancy management is to assign an experienced Health Information Professional with a proven management track record to your organization while you search for the right Director or Manager. Our managers can effectively work 100% virtually.

Our manager will routinely update you on the status of the department and will:
• Assume day-to-day management (excluding payroll)
• Evaluate present daily operations
• Stabilize the department’s operations
• Organize workflow and processes
• Interact and collaborate with other department heads and leadership
• Serve as a liaison between medical, clinical, and financial staffs
• Collaborate with others to enhance revenue cycle performance
• Prepare budgets and update policies and procedures
• Participate on committees and taskforces
• Educate others as needed
• Establish and/or monitor productivity standards
• Evaluate capital and space needs and define requirements
• Monitor compliance with regulatory and accreditation agency requirements
• Orient your newly hired manager
Recruitment Assistance:
We assist our clients with their recruitment efforts in two ways:
• Upon request, we will conduct a search for a candidate. The search services include advertising, screening interviews, and referral of qualified candidates to the client.
• We will conduct testing of coding skills for coding candidates. Results will be conveyed only to you, the client, to allow you to factor in the coding score in your selection criteria.
Services are provided on an hourly and/or percentage and cost-incurred basis.