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Handling the HIPAA Complaint Desk – In the Trenches Cathleen Casagrande, Privacy Officer Frederick Memorial Health Care System 240-566-3877.

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Presentation on theme: "Handling the HIPAA Complaint Desk – In the Trenches Cathleen Casagrande, Privacy Officer Frederick Memorial Health Care System 240-566-3877."— Presentation transcript:

1 Handling the HIPAA Complaint Desk – In the Trenches Cathleen Casagrande, Privacy Officer Frederick Memorial Health Care System

2 How do you accept complaints? Pros and cons of each… Oral – do you become the scrivener or do you use recording technology of some sort? Voic Electronic Mail or other computerized submission mechanism Snail Mail or other paper submission Function outsourced to a third party who handles, logs and tracks complaints, develops background facts and routes to correct party(is) for follow up

3 Complaints and Continuous Improvement Complaint (early warning) Investigation, fact Finding, root cause analysis Document complaint and disposition: was this an isolated incident or is there a weak link in your compliance program? Shore up any weaknesses, retrain, watch for success/failure

4 Investigating the complaint … Screening complaints to separate viable from the non- viable – and prioritizing the extreme high risk complaint Hearsay versus original “sourced” complaints Interview original source Evidence – the facts and only the facts – what do you collect? How do you record your findings? Can you retrieve it? 6 years of documentation required

5 Investigating the complaint Communication with customer… Empathy- goes a long way Assure follow-up, set date to call back Assess retraining needs

6 Types of complaints High Risk Examples- Inappropriate disclosure of PHI by an employee Test results sent to wrong patient Quick response!!!!!

7 Challenging Complaints Examples: Family discord, divorce and more…… Numerous calls, inappropriate requests? These tend to be the most difficult, time consuming… supported by HHS yearly complaint data

8 Type of Complaints Environmental- No requirement to retrofit offices Overhearing PHI, sign –in sheets Quick fixes- Employee lower voices Use background noise Review check-in set-up

9 Complaints involving Office Practices Review key items with medical practice involved…A few Examples Review of complaint Audit completion, password verification Safeguards in place -Anti-Virus, faxing, BAA’s etc.

10 HIPAA in the News Media coverage…. Brittany Spears ’08 UCLA 19 employees /physicians investigated for accessing record 13 fired, 6 pending George Clooney-’07 40 employees accessed record 27 suspended VA Case Lap top stolen compromised 26.5 million Veterans/Military


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