Do you even know what’s in there? Do you have the time or interest to learn about the requirements given that you have a busy practice to run and a staff to manage? Do you even have anyone on staff who you trust to do this for you? If the answer to these questions is “No,” you would be wise to take the following advice:
- Don’t waste your money on an off-the shelf Compliance Manual: Most of the manuals you can buy are so generic and cumbersome that you cannot practically apply them to your practice. Take, for example, “The ADA Practical Guide to HIPAA Compliance.” It’s a great resource – no doubt – but it is not meant to be your HIPAA Compliance Manual. It even includes the following words of caution:
Do not simply copy or download the sample HIPAA Policies and Procedures or forms contained in the manual and adopt them as your own. You must first conduct your written risk assessment, and then you must develop policies, procedures and forms that are appropriate for your practice.
You’d be surprised at how many times I’ve gone into a practice, asked the dentist or office manager for the HIPAA Compliance Manual, and been handed “The ADA Practical Guide to HIPAA Compliance.” Typically, the pages are stuck together because it has never even been opened.
- If you aren’t willing or able to understand all the requirements and implement them, hire a Compliance professional to help: If you’re a general dentist and have diagnosed the need for a patient to have a complicated root canal, you likely wouldn’t perform the procedure yourself, right? The patient would be better served and your risk of malpractice would be reduced substantially if you referred the patient to a specialist. The same applies to compliance. Your core competency is dentistry and running the practice; a Compliance specialist’s core competency is understanding the applicable rules, drafting policies and procedures for your practice, and helping the practice comply with them.
- The Compliance professional you retain should set you up for success by giving you a system and process for implementing the requirements: Lots of Compliance professionals can give you hardcopies or digital versions of manuals, policies and procedures. But do they take the time to explain to you what’s in there? Do they give you tools and a schedule to accomplish all of the required compliance tasks? Do they provide you with a system to keep records of your compliance activities so that you can get credit for what you’ve done? Most importantly, do they take your calls and/or get back to you promptly when you have questions or need advice ASAP? If the answer to these questions is “No,” it’s time for you to retain a new Compliance professional.