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The HIPAA Journal is the leading provider of HIPAA training, news, regulatory updates, and independent compliance advice.

HIPAA Compliance in Multi-Site Medical Practices

The challenge of HIPAA compliance in multi-site medical practices is that different sites can have different approaches to governance, risk management, and HIPAA compliance – making it difficult for employees working in different sites to comply with each site’s policies and procedures. One way to overcome this challenge is to use multilocation HIPAA compliance management software to standardize policies and procedures.

It is not unusual for healthcare organizations to operate across multiple sites. Even smaller medical practices can have separate offices for primary care, outpatient surgeries, and medical specialties. In such circumstances, it is often the case that each site conducts separate assessments for facility risks, clinical risks, emergency planning, etc., and develops its own policies and procedures to mitigate the risks and respond to incidents.

However, what might be assessed as a risk in one location might not be assessed as a risk in another. For example, if a multi-site medical practice has separate offices for psychiatry and podiatry, the psychiatry office will likely include behavioral health in its risk assessment, whereas behavioral health is unlikely to be a factor in a podiatry office’s risk assessment. The difference between the risk assessments will result in each office developing different policies and procedures.

How Different Policies and Procedures Becomes a Challenge

Different sites having different policies and procedures is not necessarily a challenge provided the policies and procedures are sufficient to comply with each site’s regulatory requirements AND the same employees work at the same sites all the time. When having different policies and procedures does become a challenge is if employees move from site to site and have to comply with different policies and procedures in each location, increasing the challenge for staff in health organization multilocation compliance

The challenge of having to comply with different policies and procedures at each location is not only that the policies and procedures differ in content – increasing the risk of employee non-compliance due to having too many policies and procedures to remember – it can also be the case that compliance with the policies and procedures is monitored more/less stringently and that sanctions for non-compliance are unequally imposed.

Standardizing Compliance in Multi-Site Medical Practices

The way to overcome the challenge of compliance in medical office multilocation compliance is to standardize policies and procedures across the medical practice. This means that every site has the same (for example) HIPAA compliance policies, the same HIPAA training, and the same sanctions policy for employee non-compliance. The same standardization principle can be applied to OSHA compliance,  CMS’ emergency preparedness training, and many other regulatory compliance obligations.

While this may mean there are more policies than necessary in some locations – for example, policies and procedures relating to behavioral health risks – standardizing compliance in multi-site medical practices will also standardize how compliance is monitored and non-compliance is sanctioned. This will enable employees to focus on their functions without the distraction of having to think about which sets of rules apply in the location where they are working.

Using Software for Multi-Site HIPAA Compliance Management

Medical practices have to comply with multiple sets of regulations and standards, and because the regulations and standards frequently change, a secondary challenge of compliance in multi-site medical practices is ensuring that all policies and procedures are up to date and employees are trained on the updated policies and procedures. This secondary challenge can be overcome with multi-site compliance management software.

Multi-site compliance management software works by one centralized system administrator entering details of updated policies and procedures and training requirements, and each location manager being alerted to the changes. The software can then be used to monitor which sites have acknowledge the changes and which employees have received refresher training. The process keeps multi-site medical practices on top of healthcare regulatory compliance.

Medical practices that are experiencing the challenges mentioned above, or Organized Health Care Arrangements that want to standardize policies and procedures within the group, are advised to speak with a software vendor to arrange a demonstration of multi-site compliance management software. By evaluating the software in your own environment, you will be able to determine whether the software can overcome the challenge of compliance in your multi-site medical practice.

Author: Steve Alder is the editor-in-chief of The HIPAA Journal. Steve is responsible for editorial policy regarding the topics covered in The HIPAA Journal. He is a specialist on healthcare industry legal and regulatory affairs, and has 10 years of experience writing about HIPAA and other related legal topics. Steve has developed a deep understanding of regulatory issues surrounding the use of information technology in the healthcare industry and has written hundreds of articles on HIPAA-related topics. Steve shapes the editorial policy of The HIPAA Journal, ensuring its comprehensive coverage of critical topics. Steve Alder is considered an authority in the healthcare industry on HIPAA. The HIPAA Journal has evolved into the leading independent authority on HIPAA under Steve’s editorial leadership. Steve manages a team of writers and is responsible for the factual and legal accuracy of all content published on The HIPAA Journal. Steve holds a Bachelor’s of Science degree from the University of Liverpool. You can connect with Steve via LinkedIn or email via stevealder(at)hipaajournal.com

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