The second rung of the ROPE (Rule Overload Prevention and
Elimination) Ladder deals with teaching your systems — and
the “Rules” that shape your systems — in a way
that both conveys knowledge as well as motivation and enthusiasm.
But this can't happen without properly written policies and
procedures taught in a way that fits an employee's position or
level of responsibility.
Writing Well
Write policies and procedures in a way that makes training
easier. When policies affect reimbursement requirements, HIPAA
(Health Insurance Portability and Accountability Act) or other
rules, they should be crafted with an eye not only toward daily use
as a compliance reference but also as a training device. The policy
manual is what employees refer to daily, so it should also become
their source training document.
Effective policies have two components: a policy statement
followed by procedural instructions. As an example, let's look at
charges to patients for copying their records. An effective policy
might look like this:
Policy: Records Copying Fees — State law permits us
to charge patients a fee for copies of their records up to certain
limits, plus sales tax and postage as applicable. Section 164.524
of the HIPAA Privacy Regulation states that a patient may be
charged a reasonable, cost-based fee for copies of medical records
plus postage. It does not specify a maximum authorized charge.
Procedure: Records Copying Fees — In light of these
rules, we have adopted the following procedure: When a patient
requests a copy of his or her record, we will charge 65 cents per
page for the first 30 pages and 50 cents for every page over
30.
If the records are not on site and must be retrieved from
storage, a $15 clerical fee will be charged. The patient will be
given a completed copy of the records invoice form attached to this
policy and will be asked for payment in advance. Requests for
exceptions to this policy must be referred to the privacy
officer.
This is an effective policy for training purposes because it
explains the underlying mandates in clear terms and establishes the
validity of the rationale behind the policy statement. It tells
staff exactly how to handle patient requests for medical
records.
Tailored Training
Tailor training to your audience. Remember that the ROPE system
only requires training appropriate to an employee's position or
level of responsibility. Employees should be trained in functional
groups so that they are neither over-trained nor under-trained. And
while each employee may get a copy of the entire policy manual,
only those policies applicable to an employee's position need be
covered. (Of course, personnel should be encouraged to explore any
of your privacy policies if they are curious.)
Conversely, ensure that everyone who may work with financial
information or protected health information receive appropriate
training, from top leadership down to part-time staff and
volunteers. In some cases it may be prudent to include contractors
and business associates in certain sessions.
Neil Caesar is president of the Health Law Center (Neil B.
Caesar Law Associates, PA), a national health law practice in
Greenville, S.C. He is also a principal with Caesar Cohen Ltd.,
which offers compliance training, outsourcing and consulting, and
the author of the Home Care Compliance Answer Book.
He can be reached via e-mail at ncaesar@healthlawcenter.com, or by telephone at
864/676-9075.
The ROPE Ladder
Rung 1: Articulate the way you want things to run, and
note how they run now. Then, tweak your systems as necessary to
comply with “The Rules.”
Rung 2: Teach your operating systems to your
employees.
Rung 3: Implement a clear and simple method for dealing
with problems — identify them, report them, investigate them
and fix them.
Rung 4: Give your compliance staff resources to help them
keep up-to-date with internal and external changes that may
sometimes require you to refine your operating systems.
Rung 5: Monitor your operating systems to make sure they
continue to run as you intended.
