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:
Handling the HIPAA Complaint Desk – In the Trenches Cathleen Casagrande, Privacy Officer Frederick Memorial Health Care System 240-566-3877
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? Voicemail 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
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
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
Investigating the complaint Communication with customer… Empathy- goes a long way Assure follow-up, set date to call back Assess retraining needs
Types of complaints High Risk Examples- Inappropriate disclosure of PHI by an employee Test results sent to wrong patient Quick response!!!!!
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
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
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.
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- 6-07 Lap top stolen compromised 26.5 million Veterans/Military