The majority
of medical offices today move their patients around the office to maximize time
and flow. It is completely normal for a patient to move from the check in desk,
to the outer waiting room, to the inner waiting room, to the lab, back to another
waiting room, to the exam room, on to various testing rooms, to chat in the
doctor’s office, then to check out. At minimum, that is seven stops for a
normal visit! Every provider and manager should move through the practice,
mirroring the patient’s route, to determine if each stop is HIPAA compliant. It
is easy to overlook small breaches when setting up the flow in the office. See
the practice through the patient’s eyes to help prevent breaches from
happening.
Most
practices have the outer waiting room under control. It is widely known that
sign in sheets are allowed, and that calling the patient by name is permissible.
However, problems can arise at the check in desk. Are stacks of charts visible
to patients standing at the counter? Can they read the schedule the front desk
is using to monitor patient flow? Stand on the patient’s side and look. What can
you see? What needs to be turned over or moved from view? A great deal of
information passes through this area. It is also highly visible to every person
that comes into the office. Because it is extremely busy, it is often the spot
that PHI is left where anyone can see it.
The layout of
modern practices often includes workstations in the hall, near the “inner
waiting area.” Patients are brought back to wait, and then the nurse moves to
the station to look at charts or a computer. When you sit in this area as a
patient, can you see what the nurse is doing? How easy is it to read the screen
or chart that is open? When the provider is finished at the station, are they
leaving behind items that contain visible PHI? Are they signing out of the
computer so that nothing but a screen saver is visible? If the screen can be
seen while in use, a privacy filter should be employed. No charts should ever
be left within a patient’s site line. There is often not a lot to do, and
looking at a readily available chart may appeal to some people as a way to pass
the time. Even the most sensitive patient may glance at the name and any other
stickers on the outside if the chart is where they can read it.
Many offices
today do their own testing. This involves moving patients in and out of testing
rooms with equipment. These machines often have their own data entered on patients,
as well as computers. Sit in the patient’s chair. What do you observe? Is there
anything within the patient’s reach if you leave the room and they are left
alone? Keep in mind that screen savers or ways to shield testing equipment
screens should be used.
Physicians
often bring their patients into their personal offices at some point in their
visit. When you sit on the opposite side of your desk, is there any PHI
noticeable? There should be no stacks of charts, no schedules, no tests or
results, and no communication from other doctors. There should also be a
privacy screen on the computer and a screen saver should pop up whenever the
computer is not in use. Don’t bring your patients in to put them at ease, and
then show them that you are displaying private information for all to see.
Other
problems are widespread throughout offices. Paperwork such as routing slips,
charts and insurance information are left out. If you still use a system of charts
on doors, make sure they are always turned around. Many practices post
schedules at various spots around the facility to keep things running smoothly.
Make sure that those are not where the curious eyes of patients can read
them.
Wander around
the office and just look. Observe what patients are looking at while they are
visiting the restroom, waiting for lab work, or waiting in line at checkout. A
great deal of the patient’s time in your office is spent sitting and waiting.
Remember that fact when you are looking at how your office is handling PHI.
What seems obscure to you may be obvious when a patient has nothing else to
look at. Walk in your patient’s shoes to troubleshoot the spots where your staff
is unknowingly exposing PHI and putting you at risk for a complaint. It only
takes one patient noticing one thing. Be the patient and see what they are
seeing when they move around your office. You may be surprised by what is
slipping through the cracks.
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