Maura Cash – Policy & Procedure Changes When Implementing an EHR | This Week in Surgery Centers
Here’s what to expect on this week’s episode. 🎙️
When it comes to implementing an EHR, there are a lot of steps to consider – internal buy-in, vendor research, implementation, training, support, and the list goes on. One often overlooked step is updating your Policies & Procedures.
Maura Cash is the VP of Clinical Strategies here at HST Pathways, and she is here today to walk us through which policies and procedures need to be updated, which need to be created, and why it matters. A few highlights:
➡️ When you switch from paper to electronic – any policy or procedure you have that is associated with the care of a medical record will need to change.
➡️ Your existing policies and procedures will need to be updated – permissions and access, chart completion process, the release of records, and emergency plans, to name a few.
➡️ You will need to create new policies and procedures – remote access, hardware, downtime, HIPAA violations, and more, depending on your facility.
➡️ Keep your staff heavily involved and informed – they need to sign each new or updated policy and procedure and understand how they will be utilized.
➡️ Don’t feel like you need to create everything from scratch – turn to your state associations, colleagues, ASCA, and other industry experts who have already done this for samples.
Find the full episode on Apple Podcasts, Spotify, or YouTube to hear all the details.
Episode Transcript
welcome to this week in surgery centers if you’re in the ASC industry then
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you’re in the right place every week we’ll start the episode off by sharing an interesting conversation we had with
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our featured guests and then we’ll close the episode by recapping the latest news impacting surgery centers we’re excited
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to share with you what we have so let’s get started and see what the industry’s been up to [Music]
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hi everyone here’s what you can expect on today’s episode when it comes to implementing an EMR there are a lot of
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steps to consider internal buy-in vendor research implementation training support
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the list goes on but one often Overlook step is updating your policies and
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procedures more cash is the vice president of clinical strategies here at HSC Pathways and she is here today to
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talk us through which policies and procedures need to be updated which need to be created and why it matters
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in our news recap we’ll cover celebrities who are joining the price transparency fight news from the White
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House on covid-19 vaccines Walmart Health’s latest move and of course and
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the new segment with a positive story about a teenager from Maryland who is making a big difference in her community
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and just a reminder we are taking next week off due to the ask a conference in Kentucky from May 17th to the 20th so
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our next episode will Air Tuesday May 23rd and if you will be at aska make
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sure you stop by HST Pathways Booth to say hello and join us for a quick interview so you can be on an upcoming
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podcast episode we will be at Booth 519 it’s a big Booth right in the middle of
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the floor so please stop by I would love to see you all and that is it for me hope everyone enjoys the episode and
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here’s what’s going on this week in surgery centers
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[Music] hi Maura welcome to the show
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hi thanks for having me I personally am so excited to have you on today if anybody is not watching on
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video you can’t see the big smile on my face but today we have a surgery center
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Legend clinical expert or manager celebrated nurse my sometimes therapist
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and a great friend Mora cash can you give our listeners a little bit
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of info about you and your experience in the ASC industry
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sure I’ve been a nurse for 45 years sometimes hard to believe but in the ASC
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industry for over 20. started out as a staff nurse just like everybody does and
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worked my way up I’ve always been fascinated with
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electronic health records and um and with computers in general and was
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able to apply that to my progress and my leadership eventually of of an ascor so
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um yeah it’s it’s been a fun ride and one of the great things about nursing is that you can learn new skills and then
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apply them to nursing to create better patient care and outcomes perfect yeah and that’s a great segue
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because given your background you are no stranger to the implementation process for ehrs and it seems like one area that
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is often overlooked is the process of reviewing the policies and procedures surrounding medical records so let’s
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pretend this is brand new information to some of our listeners why do existing
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policies and procedures need to be reviewed and updated prior to implementing an EHR what do they
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currently lack that this needs to take place great question so when a center switches
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or is thinking about switching to an electronic health record the policies and procedures that used to apply to the
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manual paper world will absolutely have to change any of those procedures
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associated with the care of the medical record they’re very different when an EMR comes into view so what to look at
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first so review your current manual or have a group of Staff do it which in
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my opinion is even better and have them tag every page that has to do with a
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chart that’s the first step and that could be done now even if you aren’t planning on
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an EHR for the next year or so then I would look at access and
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permission so you can no longer like just lock up your charts in a room and
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say okay they’re safe no one can access them but let’s be honest when you have paper
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charts a lot of people could have looked at that no one would have known that
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anyone was looking at that chart but now you could truly Safeguard your patients Phi and be able to show an audit log of
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who accessed what when make sure each user and non-user of the
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chart have the access that they need but not all permissions to all people so a
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lot of people think I just need um my users to have access and then you
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look at well no because my billers will have to look at the operative report and
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somebody else might have to look at in medical records would might have to look at that entire chart so even though
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they’re not users of the chart they have a part in that process and therefore
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will need permissions and access so it’s no longer just a locked medical records room it’s how when and who will have
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access to that got it so um I would also look at your
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chart completion process what are the consequences So currently a lot of places say the chart has to be
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completed 30 days and if it’s not they get this reminder and that reminder and then finally they can’t schedule cases
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or whatever but make sure you have consequences
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for your chart completion if it’s not done make sure you can live with the consequences that you have and make sure
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that somebody is still assigned to to monitor those short completions and and
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have everything done in accordance with your bylaws so make a policy and procedure about chart completion that
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you can live with and make sure that at least two people at your Center at all times know how to do that so one person
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is Never Enough right and then uh then I would look at release of Records right now they have to sign a
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release they have to go in they have to get copies of that paper chart someone sometimes has to go retrieve it from
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somewhere to get back to get copies of that paper chart those policies and
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procedures all completely change when you have an EMR so what you’re going to
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want to do for release of records and of course the cures acts clearly states everyone is entitled to free and
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immediate access to their medical records make sure you know how you’re going to do that
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will you print it out and hand it to them will you send it to them electronically
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um via email will it get forwarded to their Physician’s office like what is your new policy procedure going to be so
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I would definitely look at that that’s going to come up pretty quickly and um storage and retrieval of the old
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records I wish I could say that problem instantly resolves itself when you go to an EHR
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it won’t so you still have to say what are we going to do with those old charts are we going to scan them into our new
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system and keep them in storage are we gonna who’s gonna be responsible for retrieving them so even though that
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policy might be there it will definitely have to be tweaked to meet the needs of
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your EHR and who is responsible for this again have two people with the permissions to
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accomplish the new procedures of policies that you set into place and if someone leaves your employment for
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whatever reason theirs or yours make sure you replace them with somebody confident who can then have those
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procedures uh have those permissions so you wanna make sure somebody is in charge of of
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assigning permissions and removing permissions again it’s all about access
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okay sure thank you that is a great
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comprehensive list um with in your experience what are some challenges that surgery centers will
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face so they have their list of things right that you just listed um things they have to change but what
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are some of the challenges they might face while while trying to roll these out
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yeah sending out policies and procedures for staff to sign I mean it’s a constant
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thing you update a policy you send it around everybody signs that they send it back unfortunately
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this is a totally new process to everyone and it can’t just end with
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here’s the updated policy read it thank you you’re done now sign off on it it’s
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a really good idea to make sure that they understand how they will utilize that policy and
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procedure and that it will get the results that you want accomplished so
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even though you wrote a great policy procedure um that you have to show them how to
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follow it so uh let them practice um let them work through a training
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environment and run your policies your new procedures through a training environment to make sure that they’re
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going to work before you push them out there’ll be a lot of ruffle feathers no one likes change
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um especially people who are really good at their job and they’ve done it for a long time and all of a sudden you’re
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saying all those skills that you’ve used to complete this in the past are
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relevant anymore the people are still relevant and while their jobs will
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change they don’t disappear so um it change is not all bad right I would
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encourage you to to own the change let some of these experts
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in the field already explain to them what their new role is going to be and let them own that change and be the the
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Catalyst to teach everybody else about it yeah and it’s interesting because I feel like whenever we’re talking about
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implementing anything new we always talk about the importance of having the staff buy-in and keeping them in the loop and
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involved you know before we even get to this point so that when we do get here and we are introducing new policies and
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procedures nobody’s caught off guard everybody you know to a level expected this to some degree so yeah that makes
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perfect sense so we covered existing policies and procedures that need to be changed and
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updated but what about ones that will need to be created brand new and from scratch what does that look like
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yeah so um I mean I can give you a few but every
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Center is a little bit different and they’re gonna stumble upon something and go we don’t have a plan for that
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so um what what the first one I suggest is um
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remote access will you let your users access the system from home or from their office
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who in the physician’s office will be allowed to have access
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what are the exceptions to that rule you’re going to have them you’re going to have somebody who’s on extended leave
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who has a chart that’s incomplete how are you going to get them if even if you don’t allow remote access are you going
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to have exceptions to that policy including um you know what are you going to do if
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somebody is let go from your Center for whatever reason and they have incomplete records how will you get those records
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complete what is your process for that and really policies and procedures are just about you know the policy is the
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main goal and the procedure is the process that you follow to accomplish your goal so really keep that goal in
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mind but make sure that you give everybody a little room to use their
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um their Common Sense their years of practice their expertise and their field
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so remote access is definitely one the other one that people don’t think of and
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it always kind of surprises me a little is the device someone has to handle the device and the
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hardware you have cleaning you have storing you have charging you have setting it up you have the firewall you
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have access you have BYOD which kind of a new term CHR bring
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your own device so you’re going to have doctors who want to bring in their iPad
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with ehrs nothing is stored on the device everything is stored in the cloud so having them bring their own device
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into the center is really not a security risk as you might think as long as they have the same firewalls and protections
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up but you need to address that because it is going to come up and you want to make sure that your policies around it
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and then the biggest new policy I think that comes out of this is
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downtime nobody likes to talk about downtime sure but there are many reasons why your
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assistant could go down your Wi-Fi could go down the building across the street could be
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having work done and somebody’s digging up the road you have to have a backup plan for what happens in downtime where
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are your paper charts who is the go-to contact person the main person what is
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your process who do you call first who do you call second who do you call third who communicates that to all of the
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staff if you decide to go to paper and you’ve used paper charts and the crisis is now
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over how much of that information gets posthumously entered into your EHR to
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keep your report straight and keep your information straight so um it’s really important to add that section to your
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emergency plan what to do just like you would for a tornado or a hurricane what
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to do with downtime on your electronic health record and the last one I would suggest is around HIPAA we’ve all heard
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HIPAA you understand hippo we understand patience uh health information needs to
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be protected but with an electronic health record you can actually
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prove it you can actually run Audits and say no one who shouldn’t have had access
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to this chart has accessed this chart and you need to run those Audits and you
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need to come up with a policy and procedure how you’re going to run those audits how often you’re going to run
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those audits are you going to run it when you have a high profile patient is
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that going to be your standard that you follow and most importantly what are you
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going to do when someone accesses a chart that they should not have access people
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are curious a couple of years ago George Clooney was in a in an accident and he
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was in a hospital and a bunch of nurses accessed his chart and it was audited
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and found out George insisted that these nurses not be fired
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and I think that was really nice of him but in this day and age when Staffing is
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so hard to find and recruiting is impossible
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maybe you don’t have a one and done policy here maybe your policy if someone
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accesses a chart that they shouldn’t be is that they go to a training class for
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HIPAA and they get another chance right and then you monitor them success
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successively um but make that a policy outline your
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procedure make sure everyone knows what the consequences are because you’re
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gonna have to enforce them sure so we’re okay so just to sum sum it up
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looks like we’re looking at four new policies the remote access the devices and Hardware the downtime and and HIPAA
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yeah and that’s probably just skimming the surface sure depending on how in-depth your policy and procedures are
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now but I would definitely create those yeah yeah and in the process of creating
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the new ones and updating existing ones which members of the team
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um do you typically suggest bringing in to be part of this committee and in process
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yeah so honestly in my experience it was just me on the weekends getting there
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trying to create policies and I do not recommend them at all
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um the more people you involve the more ideas that you hear the easier the
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process will be and the more buy-in you’ll get from the staff because they assisted in creating it so I would make
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sure I had an I.T person a medical records person a representative from each of the clinical areas of care and
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business office represented from the non-clinical if you can get a physician
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representative more power to you that would be fabulous but um even if you can’t maybe a PA maybe
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someone from their office who’s willing to sit in who who you know is a really strong
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EMR player for their office system that might be somebody of Interest
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you’re making policies and procedures that affect both the users and the
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non-users of the chart so you need to make sure you incorporate those people into your committee if you can create a
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committee to do that sure yeah maybe you can’t see the committee Erica
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um there are so many resources online in your associations in blogs
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um that abound in your community uh other people you’ve networked with those
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are the people that you can reach out to and say you know we’re a small Center we all
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wear a ton of hats and I just need some help on this input and your vendor
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should be able to hook gaps up with some people who are using the system now who you could get gained from their
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experience as well yeah that’s a great call out and I I also feel like on ask a connect I see stuff about policies and
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procedures all the time people are always asking hey what do you guys have for this you know specific policy and uh
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people are more than welcome more than happy to share so absolutely yep that’s
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a great call out and let’s say somebody does not take the time
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um wouldn’t be any of our listeners but let’s say somebody doesn’t take the time to update and create new policies and
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procedures what are the implica implications of of getting this wrong and not doing that
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you’re gonna have some chaos you’re gonna have some initial chaos that you can avoid
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um uh at the last minute somebody’s gonna say who’s setting up users how do
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I get in I don’t have the right permissions uh why do I have access to that I need access to that I need this I
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need that oh my gosh this isn’t working right what do I do if you don’t have uh
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some policies and procedures um instead of coming up with this
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through through each record you that day day by day by day you’re gonna have
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another issue another issues so um that that first
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three weeks of your EHR go live um will be much more chaotic
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for for you as the um as the team lead in charge of the EHR
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but also for all of your people who are not only now learning a new system but learning all the new policies that that
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need to be put into place on the fly to handle some of these issues so um I
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would I mean if you don’t have some of these things in place beforehand
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um you will have a much more difficult go live and yeah if your next
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accreditation survey is coming up in within three to four months of starting
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an EHR you’re really going to want to make sure that those policies match because
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um they’re going to read that we lock the medical records room at the end of
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the day and it’s always banned by this many people they’re going to say oh where’s your medical records oh yeah we’re electronic
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now we don’t have one so sure that doesn’t usually fly with surveyors
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um especially if you’ve been on an EHR for several months so uh I would get certain things absolutely down and then
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it’s okay to say it’s a work in progress um I’m working on updating a lot of our
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policies and procedures we just went live a month ago two months ago they will understand that as long as they know
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that you know you’ve got to update these and that you’re in the process of doing it and that’s okay they they uh they do
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have a real understanding that this is a continued process it’s not a one and
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done kind of thing sure yeah yeah makes sense and again I don’t think you know I
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feel like everybody probably understands they have to do a little something in this Arena but probably you know it’s
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good to have a reminder of of the depth of it and and what you need to do so thank you Maura I have one final
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question for you we do this every week with our guests what is one thing our
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listeners can do this week to improve their surgery centers
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okay well if I’m sticking this topic um I would have to say to have policies
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and procedures that are not just for surveys and are not just an exercise on
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paper um you don’t want to set yourself up and your team up for failure so sitting down
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with your team and listening to them having that heart to heart and not just about EHR policies if they say to you
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this policy this procedure is not what we’re doing we can’t do this we don’t
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have the time to boost the resources to do this we don’t have the the
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environment to do this in change your policies make sure that your
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policies are yes same for the patient absolutely
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geared towards positive outcomes but also they need to be able to be followed
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by the staff that are expected to deliver care to the patients and or
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bills to the patient and or medical records for those patients they have to be able to follow those
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policies and if you can have a heart-to-heart with your staff that says hey you guys look at these 10 policies
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and tell me if we’re not really doing any of this stuff because if you’re not really doing it
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and it’s really not a policy and procedure that’s uh that’s what I would uh
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recommend to everybody because we are all about keeping our staff happy
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keeping them in their jobs that they’re doing and what what can better let these
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people know that they’re valued uh than hearing them and listening to them and making the changes that make their job
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easier sure thank you Maura that is wonderful advice and I’m so appreciative of your
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time and expertise and thank you for coming on the show today thank you for having me it’s been a
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pleasure [Music] as always it has been a busy week in
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healthcare so let’s Jump Right In rapper Fat Joe recently joined the transparency
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fight and testified before Congress about the need for Health Care price transparency
24:49
during his testimony Fat Joe shared his own experience with skyrocketing health care costs and called for greater
24:55
transparency in pricing he stressed the importance of patients having access to clear and accurate pricing information
25:02
before receiving treatment so that they could make informed decisions about their care he also spoke about the
25:08
challenges faced by low-income and minority communities in accessing affordable health care and how price
25:14
transparency could help to reduce those disparities now fat Joe’s testimony
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comes at a time when health care costs are a major concern for many Americans and there is a growing push for greater
25:26
transparency and pricing across the industry now we are all very familiar with this and we have talked extensively
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about the no surprises act and treating your patients like consumers I always like to use the air played analogy you
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know would you ever get on an airplane not knowing how much it would cost no
25:46
you purchase it up front you’re it’s very clear um imagine getting off the plane not knowing how much it costs or
25:52
maybe having a ballpark and then in the coming weeks you’ve received separate bills from the airline the pilot the
25:58
flight attendant um of course you would never accept that so but this is what we expect of our
26:04
patients so as patients continue to struggle with Rising costs and lack of access to Affordable Care Advocates hope that
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increased transparency will help to level the playing field and make Health Care More Equitable for all so it’s
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great to see someone like Fat Joe using his platform to raise awareness about such an important issue the more voices
26:26
the better so we’ll be keeping an eye on this story as it develops and we hope to see more progress in the fight for
26:31
healthcare price transparency in the near future big news from the White House the Biden
26:39
Administration has announced that it will be ending kobit 19 vaccination requirements for federal employees
26:45
contractors International Travelers and CMS certified facilities at the end of
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the day on May 11 2023. so depending on when you’re listening to
26:57
this the requirement might already have been lifted the decision comes as the country
27:03
continues to progress in the fight against kovid with vaccination rates steadily increasing in case numbers
27:08
declining the Administration has emphasized that vaccines Remain the best tool for ending the pandemic but that
27:15
the time has come to shift Focus towards encouraging vaccination versus mandating
27:20
vaccination so under the new policy again federal employees and contractors will be
27:26
encouraged to get vaccinated but will not be required to do so um and you know those 6 000 or so CMS
27:33
certified surgery centers will also no longer be subject to vaccination requirements
27:39
um and as you can imagine the announcement has marked plenty of debate uh with some criticizing the decision as
27:45
premature and risky however others see it as a positive step towards encouraging more people to get
27:50
vaccinated voluntarily in our third story Walmart Health the
27:57
retail Giants Healthcare division is expanding its services in Oklahoma the
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move comes as part of Walmart’s broader strategy to expand its Healthcare footprint and offer affordable
28:08
convenient health care options to more people Walmart health clinics offer a range of
28:13
services including Primary Care Dental Behavioral Health Services as well as
28:18
lab and x-rays the company aims to provide high quality Care at a lower cost than traditional Health Care
28:25
Providers making it an attractive option for many consumers now the expansion in Oklahoma will see
28:32
Walmart Health opening new clinics in the cities of Tulsa and Broken Arrow and
28:37
at just adding to the existing clinics that are already in the state and their goal is to open more than 100 new
28:43
clinics across the country over the next few years as you can imagine the expansion of
28:50
Walmart health is seen as a potential disruptor in the healthcare industry um given their scale and resources it
28:57
really allows them to offer services at a lower cost than traditional providers
29:03
A major concern being the potential impact on small independent providers in
29:08
the areas where Walmart helps does choose to operate so this is a story that I’m particularly interested in as
29:16
we talk about price transparency and Rising costs of care and couple that with social determinants of Health
29:22
including the transportation story that we’ve reported on last week the more accessible options the better
29:29
for our overall population Health but I do understand completely the impact this might have on the smaller providers so
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we’ll be keeping a close eye on how these clinics go and where Walmart Health decides to go from here
29:43
and to end our new segment on a positive note Emily batnagar is a 19 year old
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from Maryland and she has donated over 15 000 books to Children undergoing
29:54
cancer treatment via her book drive for love and Buttercup her father was diagnosed with stage four
30:01
thyroid cancer in 2019 also happy to report he is alive and well now
30:08
um and she just couldn’t imagine children going through the same experience so she decided to organize a
30:13
book drive for Pediatric cancer patients to bring joy to their lives into their day now it’s been almost two years that
30:21
she started her first book drive and she has been able to collect and donate over 15 000 books to local hospitals in the
30:28
DC area and if you would like to support check out her Instagram at for love and
30:34
Buttercup and that news story officially wraps up this week’s podcast thank you as always
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for spending a few minutes of your week with us make sure to subscribe or leave a review on whichever platform you’re
30:47
listening from I hope you have a great day and we’ll see you again in two weeks after ASCA
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[Music]
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