This week we have letters, HIPAA, a Practice Management Gem, more HIPAA, questions, answers  -  Here's one to start with:

In a recent conversation, I was asked about efficacy of different disinfectant solutions.  The goal was to find something that would be effective against HIV, hepatitis B and C, and the other viral, fungal, and bacterial organisms that are a concern for us.  The intent was to use this solution not only for cleaning surfaces but also for immediate disinfection of instruments, even before taking them on to the ultrasonic cleaner and then to be autoclaved.  Based on the descriptions in the catalogs or on product labels, the glutaraldehydes and other solutions shown are not very immediate, and don't claim to be effective against all organisms, or don't specify all those that they affect.

Several years ago, I asked a similar question of the WA State Department of Health's OSHA expert, who contacted the Centers for Disease Control for an answer.  He reported back that   he was advised that a 10% (or 20% if not re-mixing daily) bleach solution "kills everything instantaneously".   So our office protocol evolved to include briefly immersing all used instruments in a container of bleach solution before doing anything else with them.  This way, if an instrument is dropped, or someone gets a stick while scrubbing, all organisms have already been neutralized.  The bleach solution is also what we spray on (non-porous) surfaces for cleaning.

Of course, bleach also can ruin clothes, carpets, etc., if it is spilled or splashed, so not everyone is enthusiastic about that approach.  Can anyone offer information about alternatives to bleach with comparable speed and efficacy and less potential for staining or discoloring whatever it touches?

  ~ Gayle

From:  Deb B., PMA
re:     "Enjoyable reading; Wish more would utilize website"

Enjoy coming in to work, and finding informative e-mail
waiting.  Wish more people out there who need questions answered would utilize this site.  Doesn't take much to ask the question, or long to have it answered.  Keep up the good
work, and let's get those fingers moving!

Deb B. PMA
Dr. Mark Aldrich, DPM

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From:  Sandra Lohrentz, PMAC
re:      ASPMA Annual Meeting
(Edited)

"....I was also wondering if you would list the ASPMA 40th Annual Meeting on your FootZine. I am sure you have received all the information via your Journal or the flyer that was sent several weeks ago. I would appreciate this. Thanks."

Sandra

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See the "Calendar" listing below for ASPMA meeting information and a link to more details via the APMA web site.

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From:  Linda  Casella
re:      Region III Meeting

I just wanted to let you know that the Region III meeting was superb and I was pleased to have a meeting with Hal Ornstein.  He was so kind and so very helpful.  The information that he gave me has already paid off and we are putting more plans into effect.  Thanks, Hal, for giving me some valuable help and taking time out from your busy schedule.

Linda Casella
Region I

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In response to last week's letter from Sharon Hockinson regarding billing software, and the recommendation given to contact FoxMed, I received a note which is here in edited form:

"Please contact the person you recommended..... FoxMed and caution them.  We were not happy for many reasons. ....difficult to articulate here.  We are now getting new software after just converting to FoxMed."

August 6-10, 2003
APMA-ASPMA Annual National Meeting (ASPMA 40th Anniversary)
Marriott Wardman Park Hotel
Washington, DC
Additional info: Sandra Lohrentz, PMAC
2124 S. Austin Blvd., Cicero, IL, 60804
Phone (708) 863-6303 or (888) 88-ASPMA
APMA 2003 Meeting Information Page:
http://apma.org/anmeet/meet03a.htm

FootZine's "Calendar" page is found at http://www.footzine.com/FZ_4.htm

Now that we have crossed another HIPAA milestone, Privacy, we need to turn our attention to the next phase, Security.  While the privacy requirements lend themselves well to boilerplate policies and procedures requiring only minor adjustments for your practice, Security will be a horse of a different color.  The security requirements are very specific to your practice.   Writing policies and procedures to deal with security issues in your practice will require much more thought and effort, and we should start addressing these new requirements now.

With privacy, most offices only had to take their existing way of doing business and put it in writing, print up their NPP, display it in the waiting room, post it on their web site and hand them out to the patients; done.  Security, on the other hand, will require much more.  In the next few articles I will cover some areas of concern and how to address them.

Security is going to get into areas that most practices have never thought of and don't even have a foundation to work from.  Security will deal with the physical facility, the computer system, computer-user procedures and practice contingency plans, among others.

While many have accomplished the privacy portion of HIPAA without conducting a Gap Analysis, with the security portion a gap analysis will be essential for the following reason: Privacy compliance required little or no expenditure in order to be compliant.  Security, however, may require investing quite a bit of money in software, hardware and facilities upgrades.  By conducting a Gap analysis you can identify areas needing attention and then work out a long-term plan to address these issues.  The key to compliance here is that you are pro-active; you have identified and are working toward mitigating the problem areas.  That being said, you are still responsible if there is a breach in your security.  The difference is in the amount of your liability.  If you have identified problem areas and have a plan to address them you are in much better shape than if you are caught with a security breach and you have no idea that there is a problem and no plan in place to address it.  Again we come back to our favorite HIPAA slogan: MITIGATION.  HIPAA is all about making reasonable efforts to reduce the risk of having PHI falling into the wrong hands.

By: Raymond F. Posa, MBA
Technology Advisor to the American Academy of Podiatric Practice Management
President, R. Francis Associates

Any questions or comments can be addressed to Mr. Posa by E-mail: Rposa@Rfrancis.com
Or visit WWW.NJHIPAA.COM

You can review previous installments from Mr. Posa at
http://www.footzine.com/FZ_H.htm

Mary Kay Ash, founder of Mary Kay Cosmetics, said that her secret to success was to make believe that every person you’re speaking with is wearing a sign around their neck that says “Make me feel important!”.  One of the most basic human needs is to feel valued.   The goal of the doctors and assistants in our practice is to make each and every patient feel that they're special and number one.  This may appear colloquial and elementary but is not done in most practices. 

With this in mind, much of our practice’s effort and focus is on not just satisfying patients but wowing them.  This begins with training of our staff on phone etiquette and making our expectations clear.  Our guidelines include answering on less than three rings, identifying your name in your greeting, asking permission to put a patient on hold, thanking them for holding and asking at the end of the call if they have any questions or need help with anything else.  When coming into the office they are welcomed with eye contact and a smile from the receptionist.  If we are behind schedule, they are told and kept apprised of the wait.  A variety of magazines are kept current and a small television is in the reception area with a local news channel.

When entering the treatment room we always shake a patient’s hand and enter with an enthusiastic smile.  I’ve always been quite amazed how patients are so impressed by rudimentary people skills.  Patients assume that we provide quality medical care so it’s the people skills that give us the competitive edge.  When presenting to a patient we always say “we want you to know what you have, why you have it and what the options are to take care of it.”  This statement and the presentation then given is so comprehensive that our patient’s perception is that care above and beyond has been provided.

When confronted with an angry patient we approach it with the philosophy that a problem is an opportunity dressed in work clothes.  Patients expect that if they have an issue or problem with a practice, a battle will ensue.  Confronted with a problem, we then focus on listening skills.  We listen to the complaint with our eyes, ears and heart and repeat it back in a way to let the patient know we understand their concern.  What most angry patients are looking for is an “I’m sorry”, which is simple to deliver.  All efforts then focus on addressing the problem and the patient is later contacted to be sure there has been a resolve.

Previous "Gems" can be found on their own pages of the FootZine.com web site, at
http://www.footzine.com/FZ_90.htm

The Question:

APMA has sent a notice to members that new information and samples of forms, including a revised Authorization form, and a Spanish translation of the Compliance Notification form, have been added to their web site's HIPAA section.  I thought we had everything we could possibly need prior to April 14th.  What do you know about this?

The Answer:

I could not look at the new form because I don't have a password to the APMA site.

What I can tell you is that if a practice has patients that it knows do not understand English, they must provide the NPP and forms in the patients' language. The way we need to think about the NPP and related forms is that they are legal documents. In order for them to be valid in court the person signing must understand the document.

From our own HIPAA consulting, we have found the need for other forms not included in the APMA handbook.  Remember that the handbook is a guideline, it is not the be-all and end-all. Any practice relying solely on the handbook is probably not in compliance; the information in the handbook needs to be modified.  I have been telling all the doctors using this book to please read the very first page.  Kevin West clearly states that this handbook does not make you compliant; it is only a start.

We really need to stress this to people.  Too many just think that with this book they are done.  It is not until practices get audited they are going to realize this is not the case.

By: Raymond F. Posa, MBA
Technology Advisor to the American Academy of Podiatric Practice Management
President, R. Francis Associates
Any questions or comments can be addressed to Mr. Posa by E-mail: Rposa@Rfrancis.com


Email your HIPAA questions to: gaylepmac@footzine.com

It's hard to say it any better than Deb B.  -  Your input is welcome, whether a question of your own or a bit of help for someone else.  When you need a break from the sun (or the yard work), come on in, sit down  -  and write!

~  Gayle

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