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Dental Consultant Tip: HIPAA Contingency Plan

Dental Consultant Tip: HIPAA Contingency Plan

Of all the HIPAA rules and regulations that we will be discussing in upcoming articles, in my mind, having a contingency plan is easily the most critical.

In dentistry, we use various terms like data backup, disaster recovery, and practice continuity, but they all mean the same thing: you need to have a solid backup of your critical practice data.

Of course, dental practices can and should have backup plans in place, for mostly reasons that go well beyond HIPAA compliance: any practice that loses their critical practice data would most likely not recover from that, and a practice that doesn’t have a way to get up and running quickly from a disaster will also suffer tremendous losses to the bottom line.

However, in this article, we need to discuss the five components on a HIPAA contingency plan. For those of you who want a reference, it’s HIPAA Rule 164.308 (a)(7):

Data Backup Plan: The actual wording from HIPAA is that you must “establish and implement procedures to create and maintain retrievable exact copies of electronic protected health information”. Hopefully, most of you already have this in place. The plan though should ensure that you are actually backing up all the ePHI (electronic Protected Health Information), That you have stored the backup in a safe and secure place, and that you backup frequently enough for your environment, which basically means daily for dental offices.

Disaster Recovery Plan: It’s not enough to have a plan to back up the data, you actually need to prove that you can restore that data should there be a disaster such as fire, flood, or theft. Also, HIPAA basically requires that the data be in more than one place, such as locally and offsite.

Emergency Mode Operation Plan: If you are running off a backup, the need for HIPAA compliance is still very much intact. Is that data encrypted? Does everyone have access to the data that can be monitored? Do you have other security measures in place to protect the data

Testing and Revision Procedures: Here’s the sticking point that I estimate 95% of dental offices aren’t doing: you MUST test the backups on a regular basis. And, revise your existing contingency plan as needed.

Application and Data Critical Analysis: That’s a mouthful! Basically, it means figuring out which data needs to be restored first (practice management data, for example), and which can be restored later (existing images).

So, what’s the best way to back up your data? I recommend a two-pronged approach. First, an “image” of your server, this is a snapshot of the entire server: programs, settings, data, everything. The beauty of an image is that you can restore an entire server in a matter of minutes. I normally recommend putting this image on a Network Attached Storage (NAS) device, which allows for backups every 15 minutes and rapid recovery. Of course, having this image locally won’t help you if the office burns down, so you need to also have an offsite backup. A cloud backup is the easiest and most secure way to handle this.

Dental offices should always have a backup and disaster recovery plan in place, but thanks to HIPAA, it’s now the law!

There’s no time like the present to reevaluate how you are backing up and protecting your patient data.

Dental Consultant Tip: HIPAA Breach Notification
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There is the good, the bad and the ugly of dental practice management, but many dentists will still tell you the probability is your dental consulting will work if you and your consultant are on the same page. It stands to reason that if a dental consultant had little value, worth or benefit that consultant could not stand up to harsh economic realities for long.  A veteran dental consultant is also a "personal coach" who shold bring management wisdom based on "in the trenches" experience along with systems and protocols to that have been successfully implemented in other practices. Top dental consultants talk and network with each other. They pay attention to what systems work and don't across many dental practices. 

Systems

New Patient Phone Call

Insurance Processing

New Patient Experience and Patient Education

Financial Arrangements

Scheduling

Confirmation

Unscheduled Treatment 

Reactivation

Daily and Weekly Checklists

General Policy Manual 

Staff Accountability

What gets monitored, gets managed. It is as simple as that. The only way to monitor what gets done is with daily stats especially for your weak areas. For example, one employee should be specifically responsible for calls to patients who are unscheduled, overdue for re-care or need reactivation. Other staff can and should help in coordination with the accountable employee.

Leadership

What most practice owners are lack in knowledge is not how to book an appointment, but rather how to be an effective leader. The best systems in the world are useless if the staff do not comply. Good leaders know how to get staff to willingly follow through and comply. 

Questions To Ask 

  1. Do you and/or your staff have to travel or does the consultant come to you?

  2. Is the program mostly one on one consulting versus seminars or courses with multiple clients in attendance?There are advantages to both.

  3. If the dental consulting is one on one who will actually deliver the consulting? I recommend knowing who your specific dental consultant will be prior to signing on the dotted line.

  4. Is program based on a specific dental practice management system? You want to avoid cookie-cutter programs. Ensure the program will be tailor-made to fit your practice's specific needs.

  5. The cost (including travel expenses and downtime) is certainly not the only factor, everything else being equal, it is still a major factor to consider. It's unwise to pay too much, but it's worse to pay too little.  

 

Top Dental Practice Mangement Consultant

Shane Blake DDS Coudersport, PAMy name is Kevin Tighe. I am Cambridge's CEO and Senior Consultant. Before joining the Cambridge team I was in charge of setting up workshops for large nonprofits throughout the United States and Canada. During that time, I was fortunate to receive mentoring from several world-class business consultants, including a dental practice management guru, which led to a position at Cambridge as their seminar organizer. In time, I began crisscrossing the country delivering seminars myself for the better part of a decade. Subsequently, I moved up to senior consultant and eventually owner.  Contributing writer to Dental Economics/DIQ, JADA, AGD Impact and Dental Town Magazine.

  

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