HIPAA Compliant Fax Via Email-to-Fax and Fax-to-Email With a Hosted Fax Service Provider

I recently read an article from a fax service provider that claimed sending fax-to-email via a fax service provider was a HIPAA compliant fax solution. As a former Product Manager for MCI’s hosted fax service, and as a current fax solution provider, I knew this was incorrect as the PHI is traveling over the public internet which is not HIPAA compliant. This article’s purpose is to tell the reader how to be HIPAA complaint when using internet fax.

I currently work with integrated internet fax and OCR applications that created automated data entry applications. One of the applications for this integrated service is EOB processing as well as HCFA processing so we know inbound PHI traversing the internet as an image via internet fax is not HIPAA compliant from working with many customers and evaluating the HIPAA regulations. We know that PHI as an image cannot travel over the internet as an email without the image being encrypted while remaining in HIPAA compliance because the information is not protected. The following information on PHI is from the HHS.gov web site.

What Information is Protected

Protected Health Information. The Privacy Rule protects all “individually identifiable health information” held or transmitted by a covered entity or its business associate, in any form or media, whether electronic, paper, or oral. The Privacy Rule calls this information “protected health information (PHI).”12

“Individually identifiable health information” is information, including demographic data, that relates to:

the individual’s past, present or future physical or mental health or condition,
the provision of health care to the individual, or
the past, present, or future payment for the provision of health care to the individual,

and that identifies the individual or for which there is a reasonable basis to believe it can be used to identify the individual.13 Individually identifiable health information includes many common identifiers (e.g., name, address, birth date, Social Security Number).

The Privacy Rule excludes from protected health information employment records that a covered entity maintains in its capacity as an employer and education and certain other records subject to, or defined in, the Family Educational Rights and Privacy Act, 20 U.S.C. §1232g.

Internet Fax Path

Consider the flow of an inbound fax-to-email; a user places a form on a fax machine and sends a fax, it traverses the PSTN as data, it is then converted from data and “packaged” by the hosted fax server as an image and sent via email to the email address mapped to the fax number. The path when traveling the PSTN via data is HIPAA compliant, but unless the path from the host fax service to the email address is a point to point connection like a T-1 or a VPN, or encrypted, like PGP, the email is not HIPAA compliant as it is traveling over the public internet. In the case of an outbound email-to-fax, unless a secure connection exists between the user domain and fax service provider, email-to-fax cannot be HIPAA compliant because once again, PHI is traveling via the public internet.

Based on the challenges of sending HIPAA compliant internet fax, it’s difficult for the small end user, but relatively easy for a large inbound application because a VPN can be used. The moral to the story is that many fax service providers are claiming to have a HIPAA compliant fax solution, unless they can explain how the image of PHI is not traveling over the public internet, they are incorrect. Go to http://www.hhs.gov/ocr/privacy/hipaa/understanding/summary/index.html for the source on HIPAA compliance.

PC Magazine Internet fax article

As I SaaS internet fax professional and former Product Manager for MCI’s Internet Fax platform I’m always watching for anything new and interesting on the industry. So I was a little disappointed that PC Magazine would have such a high level (space) blurb about Internet fax when there are much more interesting developments. Even in 2005 I was working on combining OCR functionality with Internet fax to create automated data entry applications. PC Magazine, can I write an article for you?

Internet Faxing Reaches the Mainstream; Rumors of the fax machine’s impending demise have been greatly exaggerated.

Jamie Lendino. PC Magazine. New York: Nov 8, 2005. Vol. 24, Iss. 19; pg. 1

» Jump to indexing (document details)

Full Text

(135 words)

Rumors of the fax machine’s impending demise have been greatly exaggerated. Despite numerous predictions of the paperless office in the 1990s and the idea that e-mail and Adobe Acrobat render faxing obsolete, many people still rely on paper transmissions.

Fortunately, most of these users can gain numerous benefits by going with an Inter-net fax service. You can send and receive faxes via e-mail, which means you can do it from work, home, or on the go, as well as view them online from your e-mail account whenever you wish. Received faxes come in as PDFs, so you can store them on your hard drive or resend them to another party. You can also send Microsoft Word documents, Excel spreadsheets, and other files directly from within those applications without having to print or convert them first.

Bruteforce SEO software review

If you manage a web site and try to drive traffic to it, you know that SEO is both important and time consuming. Building links is a cumbersome process. I’ve been using Bruteforce in combination with IBP to optimize my websites. Bruteforce enables 50 hours of link building work in about 10 minutes. It works as advertised, and I was a cynic, click below to view a demo of the software, it’s truly worth your time.

http://www.bruteforceseo.com/?offer=E8ACC0A4135D

Online Internet Fax Service & OCR Software Service Reduce Paper & Streamline Document Management

The link below is an article published on how to combine Internet Fax with an OCR Service Bureau http://ocrservicebureau.com to create an OCR Document Managment Service via cloud computing.

http://www.americanchronicle.com/articles/view/124002

Save Big With Automated Invoice Processing

Here is another great example of an inhouse solution using OCR technologies to lower the cost of manual data entry. This case study does not tell you the the capital cost, implementation time and cost or accuracy levels. Kevin

An OCR (optical character recognition) solution allows Alltel Corporation to automate invoice processing and recoup nearly $735,000 per month in early payment discounts.

Integrated Solutions, September 2008
Written by: Ken Congdon

Everybody likes a good discount. Discounts, whether a result of clipping coupons or bulk shopping, allow us to stretch our dollars in impressive ways on a personal level. However, in business, discounts can play an even more significant role in a company’s bottom line. In fact, most corporate accounts payable (AP) departments establish set discounts with their top vendors for early payment of vendor invoices. These discounts are typically small on a percentage basis, but can result in thousands of dollars in savings per month if the quantities or dollar amounts of the invoices are large enough. Therefore, ensuring your AP department does everything it can to take advantage of these early payment discounts can have a significant impact on the financial performance of your business. Alltel Corporation’s AP department recently realized its manual system for processing vendor invoices was causing it to miss out on approximately 60% of its early payment discounts. In response, the company implemented an OCR system that automates invoice data collection and accelerates the payment process.

MANUAL INDEXING BOTTLENECKS CREATE INVOICE BACKLOGS
With more than 13 million customers and $8 billion in annual revenue, Alltel Corporation is the fifth-largest telecommunications provider in the United States. In July 2006, the company decided to split its landline and wireless divisions into two separate companies. This split effectively cut the company’s AP team of 45 employees in half. At the same time, it was decided that the landline company would no longer process any network invoices. Therefore, the AP department for Alltel Wireless inherited 5,000 new invoices per month (in addition to the more than 10,000 it already received) that it had to process with half the staff.

At the time of the split, Alltel Wireless’ AP department used a manual method of processing vendor invoices. Invoices were received in paper form via the mail and electronic form via an electronic mailbox. This electronic mailbox, however, was only electronic to vendors. Alltel had to print, prep, and stamp all the invoices that it received electronically and image these documents on a Fujitsu fi-5900C scanner in the same fashion as it did the paper invoices. Each image was then routed to a group of data entry employees who were responsible for manually keying important invoice information into the imaging system in order to create an index for that image. Once this index was created, the image was uploaded into Alltel’s Open Text electronic workflow system to route for corporate approvals.

The primary bottleneck in this system occurred at the manual data entry phase. “We had three full-time employees and seven temps working 10 hours a day and six days a week trying to manually index our 15,000-plus monthly invoices in a timely manner, but they just couldn’t keep up,” says Lynn Smith, finance manager for Alltel Wireless.
Smith notes that one of the reasons for these data entry delays was the unreliability of the temp workers. “It would take us three weeks to train new temps on what to do, and, in the end, many of them weren’t motivated or able to do the job,” she adds. “This resulted in a lot of turnover in that area of our department. In fact, between 30 and 40 people probably filled those 7 temp positions over a year’s time. This instability inhibited our invoice processing speed, and our invoice backlog for indexing on any given day soon reached more than 2,000. It wasn’t uncommon for invoices to sit in our indexing queue for a number of days or even a week.”

This backlog was a big problem, given the importance of image indexing to the overall invoice payment process. For example, even if all the invoices were scanned into the system, nobody could tell what vendor the invoice was for or whether the invoice was for $5 or $5 million until this information was manually entered into an index file. This index bottleneck, and the lack of information that resulted, wreaked havoc with Alltel’s ability to receive the early payment discounts it established with vendors.

“We receive a 2% discount off each invoice if we pay the vendor within 10 days,” says Smith. “Because of the index backlog, we were missing out on more than 60% of these discounts. Plus, since we didn’t have any information on an invoice until it was indexed; there was no way for us to prioritize payment of higher-value invoices in the system. In other words, the 40% we would pay early could mostly be low-value invoices, while multimillion dollar invoices sat in the queue. The net result was we were losing roughly $900,000 per month in early payment discounts.”

OCR AUTOMATES INDEXING PROCESSES
In October 2006, Alltel’s VP of procurement discovered just how much money the company was throwing away on missed early payment discounts and developed a task force aimed at getting the company’s AP processes back on track. This task force consisted of Alltel managers in accounting, finance, and procurement. After several meetings, Alltel decided that it needed to deploy an OCR solution that would help automate the invoice indexing process and reduce the company’s dependency on temporary workers. Beginning in February 2007, the company evaluated two OCR vendors and ultimately selected Brainware A/P-distiller OCR software in May 2007 (see sidebar below).

“I limited the number of vendors in the evaluation process because it was important for us to get the solution deployed quickly and start recouping more early payment discounts,” says Smith. “I didn’t want to waste a lot of time interviewing more vendors than I needed to. I found a solution that I thought was a great fit for us in Brainware and initiated the project.”

Alltel provided Brainware with a sample set of 100 invoices that were representative of the invoices the company received at the time. Based on these invoices, Brainware’s implementation team created a one-to-many learn set in the software that would allow the company to automatically process 180,000 invoices from 5,500 different vendors annually. A one-to-many learn set is a feature in which the software makes current data capture decisions based on the historical data provided by previous documents. For example, the software will scan an entire invoice document until it identifies a specific term, such as ‘invoice number.’ Then, based on the trends the software recognized by scanning past invoices, it will begin to look to the left, right, top, and bottom of this term until it locates a series of digits resembling an invoice number. It will then extract this information as the invoice number and electronically route it to a human operator for verification.

AUTOMATED INVOICE PROCESSING REDUCES LABOR, RECOUPS DISCOUNTS
Alltel implemented its Brainware solution in September 2007, and the system changed the company’s entire front end process. For example, Alltel no longer needs to print and prep the electronic invoices it receives. A/P-distiller integrates with the company’s electronic mailbox and retrieves and classifies electronic documents every 10 minutes, seven days a week. A/P-distiller then identifies and extracts pertinent invoice information (e.g. vendor name, vendor number, invoice number, dollar amount) from each electronic invoice and scanned invoice image and automatically creates an index for each file.

Speed Forms Processing With Automated Data Extraction

TCO/ROI?

Implemenation cost?

Time of implementation?

No doubt manual forms processing is inefficient, however the service bureau model should also be weighed against the cost and return of a premise solution. kmcqueen@FVTECH.com

This financial need analysis organization implemented an automated data extraction solution that reduced its need for temporary worker hours by more than 50%.
OpEd, January 2009
Written by: Sarah Howland

Financial Aid Independent Review (FAIR) was founded in 2001 to provide objective, comprehensive financial aid need analysis to private and parochial schools. The organization provides and processes forms that help schools best allocate financial aid funds to families that have the most financial need. FAIR doesn’t make the allocation decision for the school; the company provides financial aid forms to the school, which are distributed to parents to complete (the form includes financial information and requires submission of proof of income). Parents mail the form to FAIR where it is processed, and FAIR provides the information to the school within three weeks of receiving the form.

FAIR processes approximately 30,000 financial aid forms (the organization has one form for private schools and one for parochial and has created 10 customized forms for schools that have requested such) for more than 445 schools each year, and 85% of the forms are processed between March and June. Until recently, this process was completed by manual data entry. When applications were received, the data from them was manually keyed into FAIR’s proprietary software. In addition to its four full-time employees, FAIR needed to hire six to eight temporary employees during the peak months to complete an additional 1,700 to 2,000 hours of data entry. According to Dwayne Wolterstorff, executive VP at FAIR, the organization got to a point where they were having a lot of trouble finding reliable data entry help. “Even paying $15 per hour, it was difficult to find stable help,” he says.

FAIR decided it was time to move to a data capture solution to automate the data entry process. It was understood when the company was founded that it would at some point move to document imaging. Therefore, the forms FAIR uses were created in text box format (so they could use a template-based imaging solution) to ease the transition from manual methods to electronic. Wolterstorff compared three vendors’ solutions he had worked with in previous positions and chose ABBYY FormReader 6.5 data capture software, along with two Canon DR5010C scanners. “I chose ABBYY’s product because I believed it was the most user-friendly, and because many other vendors use ABBYY’s OCR (optimal character recognition) engine,” says Wolterstorff. The solution would eliminate the need for data entry, because when a form is scanned on the Canon scanner, the FormReader 6.5 software can extract the necessary data based on a template. A template is created for each form, directing the software where to look for data on the form. The extracted data from the form is automatically sent to FAIR’s SQL Server 2005 database.

To install the solution, Wolterstorff purchased two Dell computers to set up as scanning workstations. He then installed FormReader 6.5 on each of the computers and connected the Canon DR5010C scanners. ABBYY designed the first template, and Wolterstorff created the other 11 himself. During the creation of templates, only slight redesign of the forms was necessary since FAIR had planned ahead for scanning and automated data capture. Each template took about one day to create. “I purposely installed the solution during our slower period so I’d have ample time to create the templates, familiarize myself with the solution, and train the other employees before the busy season began,” says Wolterstorff. He took two months to get used to the solution himself and write a training document before providing one-on-one training to the other employees.

Automated Data Extraction Reduces Labor Needs
Now, when forms arrive at FAIR, they are opened, sorted into bundles of 25, and placed in ‘to be scanned’ cabinets. This is done so that, at a glance, employees can easily count the number of forms needing to be scanned. Employees opening mail cross-stack income verification information that comes along with the forms (these documents are scanned in for electronic filing, but aren’t read by the ABBYY software). The Canon scanner allows a bundle of 25 forms to be scanned in about 20 seconds. Once the forms are scanned, employees verify the data extracted by FormReader. After the scanning and data verification process is complete, employees review the information against the income statements received with the forms. With the automation of data extraction, employees are able to process three times as many applications in one hour than they did with the manual data entry method. As a result, FAIR has been able to decrease the number of temporary workers it needs to hire from 1,700 to 2,000 hours to between 500 and 750 hours during its busy period.

A Document Management Case Study: Procter and Gamble

This is an interesting article, I would love to know the cost of this project. If you don’t have the CapX budget of a P&G, consider outsourcing this type application and amortizing the cost into a transactional model. The ROI can be more compelling when outsourcing then implementing an inhouse solution with less risk. IRR can be eye opening. Kevin

Procter & Gamble rolls out an electronic document management system, including document management software and secure signature initiatives to accelerate R&D, meet regulatory compliance requirements and save money. The challenge for Proctor & Gamble was to create a document and records management system that could handle the volume of workflow and security issues that arise when you become a compliant organization using accepted digital signature standards.

Despite state-of-the-art IT systems and sophisticated business processes, the volume of paper that assaults the typical enterprise is overwhelming. And nowhere is the problem worse than for companies developing drugs and over-the-counter medications. Regulatory issues, R&D and potential litigation stack up to an avalanche of documents and files.

“Paper is extremely cumbersome and unwieldy,” says Kay Bross, senior public key infrastructure specialist for Procter & Gamble. “Plus it’s expensive and time-consuming to manage.”

As a result, Cincinnati-based P&G is attempting to eliminate paper and migrate to a system that allows it to store R&D information electronically, while managing secure digital signatures. The consumer goods giant—with $76.5 billion in 2007 sales and a portfolio that includes Crest, Tide, Gillette, Pampers and Charmin—aims to gain greater control of documents, reduce administrative oversight, trim costs, accelerate R&D initiatives, and improve tracking and signature compliance.

About 320 employees are now using P&G’s system, which runs on Adobe LiveCycle software and employs two-factor authentication. The company hopes to roll out the application to more than 4,500 workers by the end of 2009.

“The idea is to create a searchable archive of PDF files and a common set of tools for the enterprise,” Bross explains. “People must be able to use the system globally and have access to key documents on an instantaneous basis. Seamless interaction is essential.”

Signing On

The migration from paper to pixels has flummoxed more than a few companies. The task can involve major changes to workflow and create enormous challenges related to approvals and compliance.

At P&G, any possibility of slowing an already complex R&D process and interfering with the approval and introduction of a product could wreak havoc on the bottom line. For example, a successful over-the-counter medication can generate sales of upward of $1 million per day.

Typically, researchers, clinicians, quality-control staff, marketing specialists, and dozens of other internal P&G staff and external partners must exchange and share documents. In the past, storing all those documents meant stuffing filing cabinets internally, producing microfiche, managing indexes and renting warehouses to store reams of documents off-site.

“Digging through all the records is a long, laborious process,” Bross notes. “If a court case comes up, the process of pinpointing a document and pulling it out is extremely time-consuming and painful.”

Not surprisingly, the perils of paper have exacted a toll. In the past, some indexes weren’t entirely accurate, and manually searching for a particular section of a document—or associated documents—devoured even more time. And outsourcing records management had its own problems. In one instance, a London warehouse operated by an outside service provider burned to the ground, and P&G permanently lost hundreds of boxes of records.

Although P&G has considered migrating to an electronic record-keeping system for the last several years, Bross and other executives felt that key pieces weren’t in place at that time. After all, the company had to ensure that it could authenticate digital signatures and build signing and storage processes into its everyday workflow.

In addition, P&G’s legal department wanted to be sure it had a legally enforceable signature on file. Designing an electronic system with paper backups was too expensive and didn’t offer an adequate return on investment.

Then, in 2005, all the pieces began to fall into place. That’s when P&G embraced the pharmaceutical industry’s SAFE (Signatures and Authentication for Everyone) BioPharma Association standard. It was established to help companies go paperless and still interact with regulatory authorities on a global scale. The initiative not only focused on ways to manage digital signatures, it also created a method to confirm the identity of the signer.

SAFE “was the only digital signature approach that offered an identity-proofing scenario,” Bross says. “It provided a legally enforceable component within the overall liability framework.”

P&G’s IT and legal departments examined the initiative and agreed that it met the company’s business needs and risk requirements.

Today, once a digital signature is added to a file, an auditor can examine it in a tracking bin or view a validation report. It’s immediately possible to view all the activity related to the document.

“You simply right-click on the signature and view the entire audit trail,” Bross explains. “The signature can also be exposed and appended as a last page of the file so that it can be shared appropriately on an external basis, such as in a court of law or if there were a sale of the product.”

Assembling a workable solution required more than the ability to verify digital signatures, however. In 2008, P&G turned to IT integrator Cardinal Solutions to implement Adobe LiveCycle Reader Extensions and Adobe LiveCycle PDF Generator, which would function with P&G’s eLab Notebook program. The software handles the managing, reviewing, approving and signing of the huge volume of R&D information, including Word, Excel and PowerPoint files.

Instead of using paper notebooks to record experiment information—along with numbering each page, signing it and having a witness sign—researchers could use word processing programs, spreadsheets, presentation software (such as PowerPoint) and similar tools to generate project notes and other documentation.

After a researcher has collected all the data, LiveCycle PDF Generator creates a PDF document and prompts the person creating the file to add a digital signature. The system requires the use of a USB token for authentication. At that point, LiveCycle Reader Extensions embeds usage rights within the document. If a reviewer lacks a SAFE BioPharma digital signature certificate, the software prompts the person to obtain one.

The result is a system that saves time and money. Researchers no longer have to spend several hours a week archiving paper files from their experiments. In addition, P&G is able to quickly retrieve large volumes of data that may be needed for communication with government regulators, outside partners or buyers. An initial study of the eLab notebook showed that it produces a 5 percent to 10 percent productivity increase.

What’s more, P&G projects that it will achieve tens of millions of dollars in productivity gains using the system. The typical employee will save approximately 30 minutes of signing and archiving time per week, Bross says.

Although the software installation and systems integration phases have gone smoothly, P&G has had to face some of the challenges that pop up with any new IT initiative. The biggest hurdle has been getting employees—particularly those who are attached to paper—to accept the new workflow and learn how to use the eLab application.

“Not everyone initially trusts the system, and not everyone wants to change the way they work,” Bross says. “We have had to face some change-management issues and provide training.”

Nevertheless, P&G is marching forward with the paperless solution. And others in the organization are taking notice, including the marketing department for German operations. It has turned to digital signatures for authorizing instructions on how products should be displayed in stores.

Bross expects P&G to roll out further electronic document and signature initiatives in the months ahead. “This is a hugely efficient way to do business,” she concludes.