By Mark Wright, OD, FCOVD,
and Carole Burns, OD, FCOVD
July 15, 2020
In reopening our offices, we all have implemented significant changes to minimize the risk to our patients, our staff and ourselves of either getting or transmitting COVID-19. In fact, during the pandemic and the reopening, risk management is the rule of the day.
Here is a risk assessment chart on determining how risky normal activities are during the pandemic. Click HERE , or the image below, to download an easier-to-read PDF of the chart.
Not all risks are equal. The CDC reports the risk of getting severely ill from COVID-19 increases as you get older and that 80 percent of all COVID deaths in the U.S. are in the population of people age 65 and older.i Our children are 40 years younger than we are (yes, we waited later in life to have kids). They’ve gone places and done things during the pandemic and reopening that we would not even consider, then, we have to consider the risk of them bringing COVID back to us. Risk assessment and risk management is what keeps us healthy, alive and functioning at maximum performance.
Beyond COVID-19, the heart and soul of patient care and practice management is centered around risk assessment and risk management. You cannot run every test on every patient so instead, risk assessment and risk management is how we proceed. What is risk assessment?
“Risk assessment, in the context of safety, refers to the identification of potential hazards in the workplace as well as the likelihood that they will occur. By extension, risk assessment should also involve the implementation of measures to reduce or mitigate those hazards.” ii
A good example of this in practice is the risk for glaucoma. Not every patient has the same risk for glaucoma. It is inappropriate to run an OCT or a threshold visual field test on every patient, so, screening tests are done unless there are signs, symptoms, or mitigating factors that demand more aggressive testing.
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A good rule of thumb is to conduct a comprehensive practice risk assessment, at a minimum, at least once a year. Risk assessments should also be updated every time a new piece of equipment, substance or procedure is put in place since they could lead to new hazards.
Here is a checklist to run at least once a year as you perform a full risk assessment of your entire office.iii Modify this list as needed.
PATIENT HEALTH & SAFETY
o Ensure COVID safety protocols are in place and being used
o Review all diagnosis and treatment protocols in the context of current published protocols
HIPAA PRIVACY RULES
To be HIPAA-compliant under the Privacy Rules we must make sure the following five steps are in place:
o Designate HIPAA Officers (Privacy, Public Information, Review, Security)
o Create privacy policies and procedures
o Train staff on the new privacy policies and procedures
o Implement privacy policies and procedures
o Notify patients about their privacy rights
HIPAA SECURITY RULES
To comply with the HIPAA Security Rules, we must make sure the following actions are in place:
o Create security clearances, access record maintenance and train staff on security.
o We must have documented access authorization policies and procedures created and implemented.
o The office must have locks on the doors and an alarm system.
o The Security Officer should review security logs inspecting for intrusions.
o The software system used in the office must be equipped with virus checking software.
o Computer workstations should be located where patients cannot access the terminal. If this is not possible, then they should be password protected.
o The Security Officer should review the internal auditing of the office software program examining access of protected health information.
INTERNAL PRACTICE THIRD-PARTY AUDIT
o Randomly audit 5-10 patient records per carrier per doctor to make sure what was billed matches the documentation in the patient record
SLIPS & TRIPS
o Inspect flooring
o Slip hazards
o Obstructions in hallways & exits
o Loose materials/debris
o Worn carpeting
o Cracked tiles
o Ensure deliveries are handled appropriately
o Check for sufficient lighting
o Confirm the office is cleaned every evening
o Do we have all equipment necessary
o Check high shelves for heavy items
o Check all mechanical safeguards
o Inspect cables and plugs for damage
o Inspect placement of extension cords
o Check all equipment has been calibrated on the appropriate schedule
o Check posture in the workplace
o Check display screen equipment is at appropriate level
o Check exit signs are well lit
o Check fire alarms every six months
o Check fire extinguishers are in working order
o Ensure everyone knows the emergency evacuation procedures and routes
o Annual meeting with insurance agents to make sure everything is appropriate and updated
o Malpractice insurance
o Slips & falls insurance
o Fire insurance
o Business continuity
o Flood insurance
o Doctor disability insurance
o Identify that all legal forms are in place and being utilized (e.g.: Informed consent for corneal foreign body removal)
o Annual meeting with practice attorney to make sure everything is appropriate and updated
o Annual meeting to make sure everything is appropriate and updated
o Credit card transactions
o Online Billing
o Succession planning
o Identify where is the written plan for what to do if the owner(s) die suddenly
o Identify where is the written plan for what is the plan for normal succession
o Identify where all the practice important documents are kept
o Space planning
o Location planning
o Number of doctors and staff planning
o Specialty care planning
o Identify where the written three-year practice growth plan is kept