What if I told you that, in addition to performing your own day-to-day job functions, you also have to:
- Develop and implement for your office a comprehensive compliance program to comply with State Dental Board, CDC, OSHA and HIPAA laws and regulations; and
- Do it without additional financial or management support.
Would you be motivated and/or effective in this role? Probably not.
This is the predicament of many dental office Infection Control Coordinators (ICCs). The CDC expects each office to designate at least one individual who is responsible for coordinating an infection control program in the office and, in theory, someone on the clinical staff – usually a dental assistant or dental hygienist – is supposed to be able to coordinate an infection control program while at the same time performing his or her own clinical duties. In practice, however, the professionals assigned to the ICC role are asked to do things that they don’t have time to do, aren’t knowledgeable enough to do and aren’t empowered enough to do. Consequently – despite the best efforts of these ICCs – infection control programs fail.
It doesn’t have to be this way; if practice owners give ICCs the appropriate authority and support to do their jobs, their offices can be compliant. What does this authority and support look like?
- Authority: After designating a willing and able clinical employee to serve as the ICC, a practice owner should inform all clinical staff – including the dentists – that:
- the ICC speaks for the owner when it comes to compliance;
- the staff should follow the recommendations of the ICC; and
- the actions and words of the ICC – assuming they’re reasonable – have the full support of the owner.
A practice owner saying these words to staff goes a long way and helps establish a “Tone at the Top” that fosters a culture of compliance in the office.
- Support: A practice owner could buy OSHA and HIPAA manuals for the office and/or send the ICC and other clinical staff to outside courses; however, these resources are a poor bang for the buck because they only describe the applicable rules (i.e., the “What”) and do not help ICCs establish a process for implementing the rules in their offices (i.e., the “How”). Compliance is all about process and, without process, compliance programs not only falter but rarely even get off the ground.
A better solution would be to retain a third party compliance firm that can provide the office and, more particularly, the ICC with a ready-made compliance program and continually updated procedures. In this model, the ICC serves as the point person in the office for implementation but can look for direction and guidance from a team of experts who already know what has to be done and how to do it. With eyes and ears in the ground, the ICC also can issue spot and call in the compliance experts to provide education to clinical staff when needed.
By asking the ICC to be an implementer rather than a creator, an office is likely to have a much greater chance of success with its compliance program. Why? While most dental assistants and dental hygienists are well trained to handle the technical aspects of their clinical roles, few (if any) are trained to handle the administrative aspects of the ICC role, which include the following:
- Develop and maintain infection prevention and occupational health programs;
- Provide supplies necessary for adherence to standard precautions (e.g., hand hygiene products, devices to reduce percutaneous injuries, and personal protective equipment;
- Develop and maintain written infection prevention policies and procedures appropriate for the services provided by the facility and founded on evidence-based guidelines, regulations and standards; and
- Implement a system for early detection and management of potentially infectious individuals at the initial point of the patient encounter.
Source: U.S. Centers for Disease Control and Prevention. Summary of Infection Prevention Practices in Dental Settings: Basic Expectations for Safe Care. Available at: https://www.cdc.gov/oralhealth/infectioncontrol/summary-infection-prevention-practices/index.html. Accessed January 14, 2020.
With the exception of #4 above, these administrative requirements would be more effectively performed by a dental office compliance firm whose staff has the requisite legal and/or compliance training as well as the skillset and time to develop written procedures and processes that can comply with complex and ever-changing rules. If a dental practice owner retained such a compliance firm to be a resource to the ICC to help fulfill his or her designated responsibilities, such owner would be showing the ICC (as well as the rest of the clinical staff) that the ICC role is important, that the ICC has the requisite authority to implement a compliance program and that the ICC has the owner’s full support.