July 12, 2012
Are your Policies and Procedures a stagnant document that sits in a binder on a shelf in the practice just satisfying a HIPAA requirement, or are they a dynamic part of how you conduct your business each and every day? I hope you say the latter but, if not, your P&Ps can become an effective way for you, the Practice Manager, to manage the practice day-to-day.
While the terms Policies and Procedures is often used together, there is a distinct difference in what each term means. Policies refer to the set of rules that govern the way you run your practice. They determine whether you charge a patient for a missed appointment, how you handle collections for past due accounts, as well as govern how practice employees request time off, are compensated for overtime, etc. Procedures are the step-by-step instructions for how every practice process is conducted. If it’s been a while since you’ve documented a procedure, it’s time to review your procedure manual to determine if it’s out of date. The following is a basic outline of how to document a process.
Step 1: Start by jotting down the high-level, major parts of a process. There may be three, four, or more main steps.
Step 2: Break down each of the main parts of Step 1 into sub-parts. In this step you’re actually getting into the detail of what form or screen to use, what to fill in, where to put it when it’s completed, who to notify upon completion, etc.
Step 3: Document the details identified in Step 2. Include screen shots from an applicable computer program or an actual form that must be completed. This is the part of the process where you want to be thorough in capturing all of the details. Make sure to include visuals whenever possible.
Step 4: Communicate the procedure to all practice staff who are involved in the process. If appropriate give each of them a copy. You may also want to collect feedback, particularly if it’s a highly technical process that others in the practice have more familiarity with. You may even ask the technical experts to work together to document a process.
Step 5: When the procedure is final, add it to the full Policies and Procedures document.
P&Ps provide a guideline to ensure that everyone working within a particular process follows the same steps each time to obtain consistent results. They ensure that policies such as collections or missed appointments are applied consistently from patient to patient. P&Ps are often the basis of a good training program for new employees. They can be especially useful when a particular procedure isn’t performed frequently and there’s a possibility some of the steps may be forgotten from time to time.
Policies and Procedures are a solid foundation for any thriving business. In a Medical Practice they’re critically important for the protection of patient information required by HIPAA and, if you’re attesting to Meaningful Use, satisfaction of Measure #15. Policies and Procedures can protect you in the event of patient complaints, audit inquiries and lawsuits.
If you’re attesting to Meaningful Use, Core Measure 15 requires that a security risk assessment be conducted on your Electronic Medical Record system. Once you determine your risks and vulnerabilities, you must also update your practice Policies and Procedures. Even if you’re not attesting to Meaningful Use, a security risk assessment of your EMR is required by HIPAA. Practice Manager Solutions can help you. We have a great deal of expertise in performing security risk assessments and the resulting P&P updates. Contact us at firstname.lastname@example.org or call us at 1-866-492-0481.
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