Compliance

Review documents for a new start

Some regulations may have passed below your radar in 2014. Don’t let those mistakes hurt you in 2015.

BY C. JOLYNN DOBSON COOK, RN

The start of a new year is a great time to make resolutions to improve. While others are vowing to engage in new experiences or swear off bad habits, you can make a resolution to be diligent about updating policies and procedures in your practice. In some areas, the winter months tend to be a little slower, leaving you extra time to review various documents for compliance.

Update your BAA

If you have not yet reviewed your Business Associate Agreement (BAA), the final date for updating it was Sept. 22, 2014. The key difference is with regard to subcontractors of business associates. For example, if a consultant advising your practice on EHR engages a subcontractor who may have access to protected health information, the BAA must state that the same HIPAA compliance that applies to the consultant also applies to the subcontractor. Additionally, the business associate is directly liable and subject to penalties for using or disclosing protected health information if unauthorized disclosure occurs. When the Final Rule was passed, any subcontractor employed by the business associate can also be held liable.

HHS considers a business associate “any person or entity, other than an employee of the covered entity (the practice/ASC for example), who performs functions or activities on behalf of, or provides services to, a covered entity that involves access to protected health information.” With the Final Rule changes, you are required to develop a new BAA to include this revision. For more information, go to www.hhs.gov.

OSHA injury log

Completely separate from HIPAA, OSHA also has a change in January 2015 that applies to physician offices and ASCs. For many years, practices and ASCs have posted an injury log from February through April. This is no longer required in many states as of Jan. 1, 2015. However, this may vary from state to state. For more information, go to www.osha.gov

Review policies, procedures

At least every two years, set aside time to review your practice’s policies and procedures. Many resources exist for those just starting out. Many times over the years, our policies and procedure guidelines have proven to be quite valuable. Not only do these documents provide guidance and direction for new staff, they continue to provide consistency and serve as a valued resource for new physicians and managers alike.

Forms and documents review

Last, but not least, the new year provides an opportunity to carve out time to review practice documents such as consents, test order sheets, financial agreements, and the many other paper or electronic forms used in your office and ASC.

A fresh start

Ophthalmic professionals deal with enough duties and responsibilities throughout the year and it’s all too easy to lose track or neglect necessary reviews. Use this opportunity to make a fresh start and focus time and attention to capturing important information in your documents. Making this your New Year’s resolution will help you and your team start 2015 off on the right foot. OP

C. Jolynn Dobson Cook is the administrator of the Laurel Eye Clinic and the Laurel Laser & Surgery Centers. A Certified Ophthalmic Executive and Certified Administrator Surgery Center, she is a registered nurse and also has a degree in Health Care Administration.