Having a Manual Alone is Not Enough

When you think of regulatory compliance think of a comprehensive new patient exam. What’s the connection? A new patient exam includes a thorough assessment ranging from the medical/dental history to full mouth probing, oral cancer screening and more. In other words, it’s quite multi-faceted and so is compliance!

Having a manual sitting on a shelf that has never been updated or worse yet was either never even completed (think customized) is like “watching” a fractured restoration in lieu of fixing the tooth. It’s far less than ideal and if not corrected (or repaired as in the case of a tooth), significant trouble lies ahead.

It’s easy to get fixated on obtaining a manual or a specific form or poster yet miss the big picture. Following any law or regulation is much more than having a manual sitting on a shelf or form or poster obtained perhaps from another office or downloaded for free.

Dentistry is both an art and science; there’s a certain balance in maintaining optimum oral health. Likewise, with compliance. It’s an art and science to fulfill legal requirements and the legal balance must be maintained on an ongoing basis. Maintaining optimum oral health requires knowledge of what needs to be done; think of proper brushing and flossing instructions, regular check-ups and cleanings. Compliance requires knowledge and understanding of what the statute, regulation or guideline mandates.

After acquiring knowledge, one must take action steps to implement the legal requirements. Action steps may include, but not be limited to staff education, creating individualized policies and procedures—after all no two patients are exactly alike and neither are two dental practices. Cookie cutter policies and procedures are less likely to pass an inspection.

Consider these examples. OSHA’s Bloodborne Pathogens Standard requires staff training upon hire and annually within one year of their previous training. Many dental staff incorrectly believe if they show proof of OSHA training from their last practice that will suffice for their new employer. This is not the case. As stated above, no two dental practices are the same. The HIPAA Security Rule requires covered entities (e.g. dentists) to conduct periodic security risk analysis. Mistakenly, simple checklists have been misrepresented as fulfilling the risk analysis requirement.

In addition, purchasing a generic compliance manual regardless of the source does not constitute optimum compliance and most likely will not safeguard against fines or penalties if your practice is audited. Take a risk—pull your manual down from the shelf. Does it contain the name of your practice? How about your logo or address? Now read the policies and procedures. Do they accurately reflect what’s being done in the office? Next check to see when the policies and procedures were last updated. Are there any revision dates note? Or at least documentation that the manual was reviewed within the past 12-months?

If your manual as well as your full compliance program (OSHA, HIPAA, Medicare/Medicaid, etc) didn’t pass that simple 3-point check, then it’s time to devote some time to the manual on the shelf.

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