Friday, May 30, 2014

New Aerodigestive Program streamlines airway, nutritional care at Children’s

By: Dr. Tom Harris

Dr. Harris practices pediatric pulmonology at Children’s of Alabama, where he serves as medical director of the aerodigestive and pediatric bronchoscopy programs. In addition to his clinical work, he researches disease mechanisms in cystic fibrosis, and is an Assistant Professor at the University of Alabama at Birmingham.

With enthusiasm, I wanted to write about the Children’s of Alabama Aerodigestive Program, one of only a few nationwide. We developed this program to comprehensively (and efficiently) evaluate and manage the medical needs of children with complex airway and nutritional problems. The program coordinates pulmonology, ENT and gastroenterology subspecialties, along with other pediatric caregivers.

We created the program with the desire to avoid the fragmented care that often frustrates both patients and physicians. Patients come from a wide referral base (Tennessee, Florida, Mississippi, Georgia and throughout Alabama), often with complicated medical conditions or recurrent airway/feeding symptoms that have not been adequately addressed. We find that families (and referring physicians) are attracted to the idea of receiving coordinated subspecialty care. 

The key to the program’s success is our collaborative environment. Team members include:

· Dr. Brian Wiatrak, director of pediatric otolaryngology (ENT), who has provided a wealth of experience in airway management, as well as key support for the concept and creation of the program.

· Dr. Nicholas Smith, a pediatric ENT physician, recently recruited to Birmingham from Cincinnati Children’s Hospital, site of the nation’s first aerodigestive program, to add leading edge expertise in airway surgery.

· Dr. Brian Kulbersh, a pediatric ENT, providing expertise in laryngeal cleft pathology and repair. ·

. Dr. Reed Dimmitt, director of Pediatric Gastroenterology, with expertise in eosinophilic esophagitis clinic, gastroesophageal reflux disease, and a passion about feeding intervention and nutritional support.

· Beth Crawford, MSC,CCC - SLP; a speech-language pathologist, who provides evaluation and treatment of speech, language and swallowing dysfunction. She is certified in VitalStim neuromuscular electrical stimulation, and offers the full range of evaluation and treatment for swallowing disorders.

Another key member of the team is Ashley Chapman, RN, our aerodigestive coordinator. She puts families at ease, sets up coordinated appointments and ensures important follow-ups. We attempt to coordinate doctor appointments and patient evaluations all in one day.

In addition, Children’s will soon open one of the nation’s few intensive feeding programs. The program is developed and directed by a clinical psychologist—Dr. Michelle Mastin who headed a similar program in Michigan. Dr. Mastin’s comprehensive team includes the trans-disciplinary care of speech and language pathology, occupational therapy, clinical nutrition, social work, psychology and medicine. These experts work on changing the learned barriers children sometimes face with feeding. For example, even after the anatomical reasons for swallow dysfunction have corrected, comprehensive trans-disciplinary behavior modification may be necessary to overcome aversions and relearn how to eat.

To date, the aerodigestive program has served nearly 200 patients from our referral base. Most rewardingly, many referrals come “word of mouth” from families who have been well-served by our program and then, in turn, refer their friends.

A brief overview of some common medical conditions we treat includes:

· Croup
· Tracheostomy
· Subglottic stenosis
· Feeding aversion
· Aspiration related lung disease
· Noisy breathing
· Obstructive sleep apnea
· Vocal cord dysfunction
· Swallowing dysfunction
· Tracheomalacia
· Laryngomalacia
· Tracheoesophageal fistula
· Esophageal atresia
· Gastroesophageal reflux
· Eosinophilic esophagitis
· Dysphagia

As part of our evaluation, patients are sometimes referred for a joint endoscopy, which includes direct laryngoscopy bronchoscopy, flexible bronchoscopy and esophagogastroduedenoscopy (EGD). That procedure is performed under the same anesthesia to further coordinate care and limit unnecessary risk.

Sometimes surgery is required. Sometimes a patient needs medical management. Sometimes it’s rehabilitation. And other times, the child may just need to outgrow the condition. This coordinated care helps take away uncertainty, and allows us to confidently care for children.

All this has been personally and professionally rewarding for all of us. We are improving care for some of our most fragile children, and as a byproduct, our medical specialists are learning much from one another. A combined clinic is held the first and third Friday of the month to ascertain medical needs, and Ashley Chapman, our coordinator, walks the family through this process. Our team meets the first and third Wednesday of the month to discuss patients and develop personalized care plans, with airway and GI evaluations typically occurring that same day.

For more information about our services, visit our website at


Thursday, May 29, 2014

Chronic Obstructive Pulmonary Disease

By: Dr. Rick Player, MD, FCCP
Medical West, Internal & Pulmonary Medicine

Chronic obstructive pulmonary disease (shortened to COPD from here on out) is the term for a collection of lung diseases, including chronic bronchitis, chronic obstructive airways disease, and emphysema.

People with COPD suffer from long-term damages to the lungs (usually because of smoking) and have great difficulty breathing in and out. Their airways have narrowed, resulting in obstruction of the airways.

What we usually see in people with COPD are a persistent cough with phlegm, frequent chest infections, and a high amount of breathlessness when active. And generally, breathing is much more of a labored activity - wheezing is often a symptom. We don’t ordinarily see severe chest pains or coughing up of blood - those are found more commonly with more serious conditions such as lung cancer.

What causes COPD? Smoking, mostly. The more you smoke and the longer you smoke, the risk goes right up. This is because smoking causes irritation and inflammation of the lungs, leading to scarring. These scars lead to the airways being thickened and more mucus gets produced. The airways are thicker, and also less elastic. The combination of the more rigid airways and increased mucus results in blockage - making breathing difficult. Sometimes the tobacco actually kills lung tissue, causing emphysema.

Preventing COPD is mostly about reducing risk. First, don’t smoke. If you do, quit. Don’t be around cigarette smoke (which is getting a little easier with new laws and regulation). But also be sure that you are smart about what you are breathing in. Work in well-ventilated areas - if this is not an option, wear the proper protection (if you are painting or working in an industrial position).

Treatment of COPD - well there is no cure, but there are ways to slow down the progress. As mentioned, stop smoking. And generally all of the preventative measures above help slow progression. There are some breathing exercises you can learn, and some people use inhalers to help make breathing easier. Surgery in a small number of cases is also an option.

If we’re not breathing right, it can make life pretty miserable. Coughing up phlegm isn’t attractive, it’s painful, and generally is a bummer. Be smart about your breathing environment and what it can do to your lungs.

If you feel like you’re experiencing any of the symptoms of COPD, please contact your physician.

Best, Dr. Player

Thursday, May 22, 2014

Learn About the Mohs Surgery & Skin Cancer Center

By: Total Skin and Beauty (Gary D. Monheit, MD in photo)

Mohs micrography surgery is a specialized, highly effective technique for the removal of skin cancer. The procedure was developed in the 1930s by Dr. Frederic Mohs at the University of Wisconsin, and it is now practiced throughout the world.

Mohs surgery differs from other skin cancer treatments in that it permits the immediate and complete microscopic examination of the removed cancerous tissue, so that all “roots” and extensions of the cancer can be eliminated. Due to the methodical manner in which tissue is removed and examined, Mohs surgery has been recognized as the skin cancer treatment with the highest reported cure rate.

Some skin cancers can be deceptively large and far more extensive under the skin than they appear to be from the surface. These cancers may have “roots” in the skin or along blood vessels, nerves or cartilage. Skin cancers that have recurred following previous treatment may send out extensions deep under the scar tissue that has formed at the site.

Mohs surgery is specifically designed to remove these cancers by tracking and removing these cancerous “roots.” For this reason, prior to Mohs surgery, it is impossible to predict precisely how much skin will have to be removed. The final surgical defect could be only slightly larger than the initial skin cancer, but occasionally the removal of the deep “roots” of a skin cancer results in a sizeable defect. The patient should bear in mind that Mohs surgery removes only the cancerous tissue, while normal tissue is spared.

Dr. Monheit is a leader in the dermatology community when it comes to skin cancer and Mohs surgery. He trained with Dr. Mohs and established the first center for Mohs surgery in Alabama. He has trained fellows for the past 20 years, and his graduates practice the surgery worldwide.

The Mohs Surgery & Skin Cancer Center at Total Skin & Beauty is a state-of-the-art facility with a dedicated staff for skin cancer removal via the Mohs technique, reconstruction and personalized patient care. With more than 2,000 patients treated a year, our center has the experience and expertise for predictable cures and quality care.

Friday, May 16, 2014

Bladder Cancer (May is Bladder Cancer Awareness Month)

By: Dr. Eric Brewer with Urology Centers of Alabama

Bladder cancer is a cancer that starts in the bladder, the body part that holds and releases urine. The exact cause of bladder cancer is uncertain. However, several things may make you more likely to develop it, including cigarette smoking, chemical exposure at work, chemotherapy, radiation treatment, and long-term bladder infection.

• Blood in the urine
• Painful urination
• Urinary frequency and urgency
• Weight loss
• Pain in the lower back and/or around the kidneys
• A growth in the pelvis

One of the physicians at Urology Centers of Alabama will perform a detailed history and physical examination, including a rectal and pelvic exam. Tests that may be done to look for bladder cancer include:

• CT scan: x-ray imaging that show detailed views of the abdominal and pelvic organs
• Urinalysis: office test used for finding blood in the urine
• Urine cytology: detailed microscopic evaluation of the urine looking for cancer cells floating in the urine
• Cystoscopy: visualization of the inside of the bladder with an endoscope
• Bladder biopsy: usually done in the operating suite, where suspicious areas are sampled to determine if cancer is present

Treatment depends on the stage of the cancer, the severity of your symptoms, and your overall health.

Superficial Bladder Cancer Superficial Bladder Cancer is in the lining of the bladder. Treatment usually involves removing the tumor through an endoscope. Subsequent treatment may include chemotherapy and/or immunotherapy treatments, which is medicine instilled into the bladder over a series of weeks. This helps to reduce the chance that the cancer may return. Routine follow up is needed to ensure that the cancer hasn’t returned. This usually involves repeat Cystoscopy in the office every 3-6 months for several years.

Muscle-Invasive Bladder Cancer
Muscle-Invasive Bladder Cancer is cancer that has grown into the wall of the bladder. If the bladder cancer has progressed, and has grown into the wall of the bladder, much more aggressive treatment is warranted.

Radical Cystectomy
Radical Cystectomy is complete removal of the bladder and is major surgery, usually involving a hospital-stay of up to a week. The lymph nodes around the bladder are also removed to determine if the cancer has begun to spread. If you are male, the prostate is removed along with the bladder or if you are female, the uterus and ovaries are removed, if not already done so.

Once the bladder is removed, there are two options for patients to choice:

Ileal Conduit is a small section of your small bowel is used to create an ostomy on your abdomen for urine to drain into a bag. This is the most common type of diversion and offers the lowest risk.

Neobladder is when a larger section of your small bowel is used to create a reservoir in which to hold your urine inside your body. It is attached to the urethra, and the patient continues to urinate much in the same way as you do now. While a more attractive option for some patients, it is not for everyone and comes with it’s own set of drawbacks. Ask your urological surgeon if this option is right for you.

Robotic Surgery for Bladder Cancer
At Urology Centers of Alabama the physicians continue to lead the forefront in Robotic Surgery for various urological diseases. They have expanded their robotics program to include the treatment of bladder cancer with Robotic Radical Cystectomy. The specially trained robotic surgeons are among the nations’ most experienced, with numbers that would rival most centers around the world. Robotic surgery offers many advantages including:

• Much less blood loss, resulting in very seldom need for blood transfusions
• Less pain
• Shorter hospital stay
• Better cosmetic result

If surgery is not an option, radiation & chemotherapy may be recommend by your doctor to kill the cancer. As with all treatments, side effects are possible. Be sure to ask your doctor the pros and cons to each option, to decide which is right for you.

Thursday, May 15, 2014

Affordable Care Act (ACA) or Obamacare

By: Bill Cockrell with Cockrell and Associates, LLC
It’s the start of the mid-term election season and the political ads are out in full force. Of course, the health care world is one of the leading issues as in the Affordable Care Act (ACA) or Obamacare. Many ads focus on repealing the ACA to save the wasted money and get millions of jobs back. In the right environment, this plays well to the voters. Just like the idea of high quality, low cost medicine should. Up front I’m not saying all is right with the ACA. In my first blog for the Birmingham Medical News well over a year ago, I pointed out there were things I disagreed with, and things that I thought made sense, in the ACA. And I still stand by that belief.

I still believe that paying for the ACA was not well thought out. There are plan levels (gold, bronze, etc.) which make sense in the Olympic medal categories but not necessarily healthcare and confusing elements (i.e. the “review panels”) that are creating problems. The general public certainly understands it less than those of us in healthcare. Many get their information from sources that don’t always have accurate information. For example, I have a friend who tells me a large hospital in Birmingham is refusing to take “Obamacare”. Not true of course but symbolic of popular belief.

Despite all the rhetoric, the ACA is not going away. Through March 28, 2014, Rand Corporation (an independent survey organization) showed that there was a net gain of 9.3 million individuals who had picked up health insurance. These were not just from the ACA but new Employer Sponsored Insurance (ESI) and Medicaid in addition to the exchange options. On the negative side for the ACA only 1/3 of the first 3.9 million were previously uninsured. As usual though, statistical surveys, while they deal with data, can always be picked apart because of question design, survey size and other elements.

Assuming that the 9.3 net gain, many of whom are voters in the 24 – 26 age range who picked up insurance as a result of the ACA, is accurate, and remembering we had around 130 million voters in the last presidential election, that’s enough voters to easily swaying the popular vote either way. Adding in things like the data from the non-partisan economic experts at CMS, as reported by the Associated Press on June 6, 2014, which shows that for four years ending in 2012 spending for hospital and physician care grew more rapidly than in the previous four-year period and out of pocket spending by individuals increased. Medicare spending itself barely increased, but that small increase was tied to one-time cuts to nursing homes and only small increases in pharmaceutical spending as a result of several major drugs becoming available in generic form.

So, if most of the data above is correct, we are still faced with the fundamental issue of healthcare costs continuing to increase at an unsustainable rate. Once again, how do we maintain high quality at a lower cost? It comes back to that pay for performance discussion that is being held in the halls of payers every day. Medicare continues to look at changes independent of the ACA such as Value Based Performance measures, for example. If we as healthcare industry members don’t figure out how to address these issues ourselves, we can then take what is given to us. Either we create our own version(s) of accountable care organizations (or whatever name we want to give them) or we have it done for us. One of the options to replace the ACA is the use of vouchers. Vouchers mean someone has a certain amount of money to spend, which should mean they look for the best value. That sounds like a high quality, low cost plan.

So, whether the ACA goes away, stays, or is modified (which is really the best bet), we’ve got to deal with the same issues: Cost, quality and a willingness to deal with data and outliers. We are spending a lot of time on short term issues (avoiding penalties, accepting short-term penalties, etc.) and not long term fixes. Either that changes or we take what we get.

Monday, May 12, 2014

Benefits of Seeing a Nurse Practitioner

By: Jenna Bosch, CRNP with Norwood Clinic, Inc.

Nurse practitioners are masters-level prepared nurses who are able to generate medical histories, perform physical examinations, order diagnostic tests, diagnose medical conditions, and treat patient conditions. They are specialized according to their education and training. For example, a family nurse practitioner can see patients that range from pediatrics to geriatrics.

Most nurse practitioners have completed a bachelors degree in nursing, plus a masters degree in his or her specialty. Nurse practitioners in Alabama work in collaboration with a physician who oversees patient care.

Patients seeing a nurse practitioner can benefit in several ways. The nurse practitioner may be more readily accessible than the physician who may have limited time to see patients. Nurse practitioners can see patients for anything from sinus infections to diabetes.

Nurse practitioners have prescriptive authority for a variety of medications. They have training that is built on patient education, and they can aid in healthy lifestyle decisions. Patient education is an important aspect of care, and leads to better understanding and increased medication compliance.

In conclusion, nurse practitioners are highly qualified and compassionate individuals who are important resources in the medical field.

Thursday, May 8, 2014

Managing the Risks of Treating Chronic Pain with Opioids

By Jane Mock, Risk Management Specialist Medicus Insurance Company, A NORCAL Group company

Physicians need to be especially careful when managing chronic pain with opioid medications. Medical practices often seek risk management advice when they suspect a patient is misusing prescription medications, is not complying with treatment, or when the patient is making unreasonable demands for more opioids. If a patient suffers harm as a result of opioid medication use, a physician may find himself the target of a lawsuit alleging negligent treatment of chronic pain.

How Does the Management of Opioids Create Potential Liability?
Claims against physicians for negligent treatment and/or management of opioid medications frequently arise from the following:

• Prescribing opioids without performing any diagnostic examinations
• Prescribing an excessive quantity of opioids
• Prescribing additional narcotics when not indicated
• Failing to consider, screen for, or suspect narcotic addiction, and failing to refer the patient for treatment of drug addiction   
• Negligent monitoring
• Failing to consult or refer to a pain specialist

Is the Story Clear?
The physician might think that he or she has managed a patient’s pain appropriately, but if the medical record documentation does not reflect that, defense of care is difficult. Examples of poor documentation include:

• No indication that the treating physician reviewed the patient’s prior medical records or studies
• No physical exam results
• No quantitative assessments of the patient’s pain
• No indication that the treating physician discussed the risk of opioid addiction
• No pain medication agreement
• No evidence of assessment of effectiveness of the pain medications
• No rationale for the physician’s medication choices
• No copies of narcotic prescriptions

Risk Management Tips
Clinicians can avoid reaching a point of crisis by applying a risk management approach to treating chronic pain.

Perform and document a comprehensive history and physical examination of the patient.

• Complete all indicated diagnostic exams and tests.
• Use an objective, comprehensive pain assessment tool.
• Evaluate the patient for his or her risks of abusing medication.
• Request copies of prior medical records. Base the treatment plan on the patient’s individual needs.
• Document differential diagnoses.
• Consider and try both pharmacologic and non-pharmacologic pain treatments.
• Manage patient expectations and educate patients about physical dependence, tolerance, and addiction. Document this discussion, as well as a plan of action to address physical dependence.
• Document clinical decision making and rationale for one treatment choice over another.
• Have patient sign a pain management agreement, if indicated.

Re-evaluate and document the patient’s level of pain and response to treatment at each visit.
• Consider having the patient keep a pain diary.
• Note the effectiveness and patient compliance with various treatment modalities
• Document the patient’s response, changes to the treatment plan, and your clinical rationale.
• Document the name of the drug, dose, frequency with which the patient has been taking the medication; reported effectiveness; and the impact on the patient’s daily activities.
• Communicate with other providers who are treating the patient.
• Strongly consider utilizing your state’s prescription drug monitoring program
• Utilize and refer to specialists when appropriate.
• Be familiar with local resources that can provide assistance (e.g., pain clinics, teaching hospitals).
• Obtain second opinions when indicated.
• When choosing not to pursue clarification of a symptom or complaint, document the rationale.

Be aware of signs of drug abuse or misuse.
• Set limits with patients; consider using a therapeutic pain medication agreement.
• Do not provide narcotic refills unless the patient comes in for re-assessment.
• Evaluate the appropriateness of the requests in light of the prescription provided.
• If you suspect substance abuse, carefully document details of the situation and discussions with the patient in the patient’s medical record.

Monitor the patient’s non-compliance.
• Enforce the pain management agreement, when indicated.
• Document the patient’s action or inaction that led to termination or discontinuation of pain medications and rationale for the decision.
• Contact your medical professional liability insurer’s risk management department for guidance relating to terminating a patient from the practice.


Copyright 2014 NORCAL Mutual Insurance Company, parent company of Medicus Insurance Company. All rights reserved. This material is intended for reproduction in the publications of NORCAL-approved producers and sponsoring medical societies that have been granted prior written permission. No part of this publication may be otherwise reproduced, edited or modified without the prior written permission of NORCAL. For permission requests, contact: Jo Townson at (800) 652-1051, ext. 2270.

The information contained in this document is intended as risk management advice. It does not constitute a legal opinion, nor is it a substitute for legal advice. Legal inquiries about topics covered in this document should be directed to an attorney. Recommendations contained in this document are not intended to determine the standard of care, but are provided as risk management advice. Recommendations presented should not be considered inclusive of all appropriate risk management strategies or exclusive of other strategies reasonably directed to obtain the same results. The ultimate judgment regarding the propriety of any specific procedure must be made by the individual physician/healthcare provider in light of the individual circumstances presented by the patient.

Friday, May 2, 2014

Kidney Stones 101: Prevention is the Cornerstone

By: Dr. Andrew Strang 
with Urology Centers of Alabama

She is pacing around the room, her face fixed in a grimace of severe pain as waves of nausea wash over her. This is the classic picture of a person passing a kidney stone. When a stone rolls out of the kidney and begins the journey down the ureter to the bladder, you are in for quite a ride.

The back pain and nausea are caused by the stone blocking urinary output from the kidney. This blockage results in spasm of the ureter. The pain and nausea can be truly debilitating. I have had women tell me they would much rather go through natural labor again than pass another kidney stone. After suffering once with renal colic, most people are eager to learn the basics of kidney stone prevention.

Kidney stones are caused by the accumulation of crystalline material in the urine. The southern United States is known as the “Stone Belt” due to the high prevalence of kidney stones in this area. The reason for this is multifactorial but is thought to be attributable to the warmer climate resulting in widespread dehydration.

The most common type of kidney stone is composed of calcium oxalate. People who form kidney stones usually (but not always!) have a family member with the same tendency. Although there is no way to change this genetic tendency, altering what you eat and drink can reduce or stop the formation of stones.

The most basic thing you can do to prevent kidney stones is increase your daily fluid intake. Since most people do not measure their 24 hour urine output (goal=2.5 liters of urine a day), I usually tell patients to use their urinary color as a rough gauge of hydration status. If your urine is dark yellow that indicates concentrated urine and dehydration. If your urine is clear, you are well hydrated. When you are well hydrated, the substances that form crystals in the urine are less likely to aggregate and form a stone.

In addition to water, lemonade is beneficial due to the high content of citrate, a natural stone-preventing substance. In addition to staying hydrated, a low sodium diet of less than 3300mg of sodium per day is essential. By lowering your salt intake, you reduce the amount of calcium lost in the urine that can form a stone. Limiting your protein intake to less than 8 oz a day is also helpful in preventing stones. Eating too much protein per day can lead to lower citrate levels in the urine, a natural inhibitor of kidney stones.

Although most stones are composed of calcium, you do not need to reduce your daily calcium intake. A normal calcium diet contains between 800 and 1200mg of calcium (natural sources preferable to supplements like Tums). In addition to preventing osteoporosis, calcium binds with oxalate in the gut and allows for natural elimination through gut. Cutting back on calcium intake will actually lead to an increase in oxalate absorption and stone formation. Foods rich in oxalate (Tea, Chocolate, Nuts, Spinach, instant coffee, etc) should also be consumed in moderation.

Several prescription medications are available to alter the urinary chemistry. These medications are recommended once a complete metabolic workup has been completed. This evaluation usually consists of blood work and a 24 hour urine test. A metabolic cause can be found in over 97% of patients with stones. The most common abnormality found on metabolic workup is spilling too much calcium into the urine (i.e. hypercalciuria).

One hundred percent of people who pass a stone never want to experience that misery again. Staying well hydrated and making some basic dietary changes can significantly reduce your chances of forming a kidney stone.

Thursday, May 1, 2014

Continuing the Discussion: Moving Toward HIPAA Compliance

By: Susan Pretnar, President KeySys Health, LLC.

  Previously, I discussed the inadequacy of answering ‘yes’ or ‘no’ to a checklist of HIPAA Privacy and Security requirements and assuming that simply finishing that task will provide your practice or company (if you are a BA) some level of PHI privacy and security protection. There is a serious disconnect in the industry between the need or desire to comply with one requirement of HIPAA, or HITECH Meaningful Use, and the need to implement a risk management program. A comprehensive risk management program should assure compliance with all HIPAA/HITECH rules. If effectively implemented, a risk management program actually offers you a fighting chance to reduce your risk of improperly handling or securing a patient’s protected health information. Simply completing a risk assessment, without acting on the results, reduces none of your risk, including your risk of non-compliance with HIPAA or HITECH.

HIPAA security compliance means that covered entities and their business associates can demonstrate that they have well established business practices in place that are appropriate to their level of risk and complexity. The risk assessment is simply a stimulant to launch an honest examination of the maturity of your security risk management efforts and indicates where changes are needed. Having a program ‘in place’ means your policies and procedures are documented, the appropriate staff has been trained on them, and you have not only implemented the procedures as defined, but also have a process for monitoring their effectiveness.

The point of risk management for healthcare is to safeguard PHI. How many of the recommended security controls do you have documented and fully implemented in your business? If you have checked ‘no’ to a significant number of control requirements on whatever risk assessment instrument you are using, or have never completed a risk assessment, you probably do not have an ongoing risk management program in place.

A recent HHS press release (March, 28, 2014) announced that their free risk assessment checklist can be accomplished online at the participant’s own pace. It includes a summary report in case you need evidence of your assessment for an auditor. HHS is careful to point out that using their instrument does not guarantee compliance with the risk assessment requirement. Almost as an aside, HHS mentions this one significant fact:

  “Your “yes” or “no” answer will show you if you need to take corrective action for that particular item. There are a total of 156 questions.”

HHS, through the Office of Civil Rights, clearly intends to audit based on the corrective actions that you have taken, not on whether you have answered 156 questions. Very few healthcare entities will not have gaps in their programs. Can your checklist provide a prioritized blueprint for needed corrective action based on your vulnerability to gaps in your privacy and security controls?

Understanding and appreciating the value of investing in risk management is akin to understanding the value of investing in liability insurance. It is a cost of doing the business of healthcare that helps you maintain patient trust, secure your reputation, avoid financial ruin, and incidentally, demonstrate compliance with HIPAA/HITECH.

I highly recommend the videos provided by OIG Attorneys under their HEAT Provider Compliance Training Initiative. While mainly focused on reducing fraud and abuse, two videos in particular address fundamental pillars of any compliance program: Compliance Program Basics, and Tips for Implementing an Effective Compliance Program.


My next posting will discuss how to use the risk assessment to formulate a risk remediation plan, as HHS says, to ‘take corrective action’. It’s the next move toward compliance.

bio: Susan Pretnar, President KeySys Health, LLC. More than 30 years experience in the health care industry includes extensive development work in Information Systems, as well as executive management responsibilities for multiple large business operations. Ms. Pretnar’s knowledge of electronic medical record applications and responsibility for a major electronic clinical data repository and network required understanding both state of the art software solutions and multiple telecommunications protocols. Ms. Pretnar applies her knowledge of the health care industry, and extensive project planning and system implementation experience to create innovative, simplified and cost effective risk management solutions that accelerate an organization’s ability to protect its data and infrastructure, reduce risk and be compliant with security and privacy regulations. KeySys Health, LLC. provides the people, processes, and technology needed for all phases of the risk management program development lifecycle. Our mission is to provide a blueprint for a covered entity to implement and efficiently manage a HIPAA Security Risk Management Program.