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Handling the HIPAA Complaint Desk – In the Trenches

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

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Handling the HIPAA Complaint Desk – In the Trenches

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

  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? • 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

  3. Complaints and Continuous Improvement

  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- 6-07 Lap top stolen compromised 26.5 million Veterans/Military

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