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Add Custodians To Your PIA

Posted on December 28, 2020 by Meghan in Blog

Add Custodians To Your PIA

Congratulations! You have expanded your practice and recruited a new healthcare provider to your team. Now you also need to add a custodian your PIA.

To do this, you need to orientate the provider to your practice including the policies and procedures to protect the privacy, confidentiality, and security of the personal health information and inform the Office of the Information and Privacy Commissioner (OIPC).

When the new healthcare provider is a member of a regulated health profession as defined by the health privacy legislation in Alberta, the Health Information Act (HIA), the provider also has responsibilities as a custodian.

HIA Definitions:

Custodian

A health service provider; specifically, a member of the following regulated health professions: Optometrists, Opticians, Chiropractors, Midwives, Podiatrists, Denturists, Dentists and dental hygienists, Registered nurses, Pharmacists, and Physicians (and others).

Affiliate

An employee of a custodian or as designated by the custodian, for example medical office assistant, receptionist.

The incoming custodian must ensure that the reasonable safeguards to project the administrative, technical, and physical safeguards of the personal health information are implemented in the practice. This includes ensuring that they have reviewed the current privacy impact assessment (PIA).

The lead custodian also has an obligation under the Alberta Health Information Act (HIA) to inform the Office of the Information and Privacy Commissioner (OIPC) when there are changes to the organization management of the clinic.

 

How To Add Custodians To Your PIA

In Alberta, the lead custodian in a clinic must update their PIA regularly and inform the OIPC when there are significant changes to their PIA.

One common trigger for informing the OIPC  is the addition of a custodian to the practice. Often, this PIA amendment can be as simple as a letter to the OIPC.

  1. The lead custodian or privacy officer will prepare an amendment to the previously submitted Privacy Impact Assessment when new custodians join the practice. Often a letter to the OIPC signed by the lead custodian is sufficient.
  2. The PIA amendment must include how the custodian has been made aware of the current PIA and how they are meeting their requirements to enter into an agreement with information managers as defined in the Health Information Act section 66.
  3. The lead custodian will submit the PIA amendment to the OIPC for acceptance.
  4. The new custodian must acknowledge that they have been informed of the Health Information Privacy and Security Policies and Procedures and the submitted PIA and agree to follow these practices. The new custodian will sign the letter to the OIPC and attach it to the PIA amendment from the lead custodian (in step #1 above) to the OIPC for acceptance.

 

Routine Onboarding Of New Employees

Before the new custodian is granted access to patient health information, your computer network, and your electronic medical record (EMR), you need to ensure that new custodians are aware of your Health Information Privacy and Security Policies and Procedures, PIAs, and information manager agreements, including the information management agreements with Alberta Netcare Portal, patient records management, EMR vendor, billing vendor, and/or others.

You should have a written policy and procedure ‘When a New Physician / Custodian Joins Your Practice’ to guide you when onboarding new custodians. The procedure should include the forms below and template letters to the OIPC. These templates are also available to members of Practice Management Success.

Add custodians to your PIA
Do You Need Help With Your PIA?

Did you enjoy this article? If you’d like to look at similar posts, visit these links:

Top 3 Agreements Your Healthcare Practice MUST Have (and why)

What Is a PIA?

How Do You Declare as an Affiliate?

Podcast – Close, Move, Merge Your Practice | Episode #090

Alberta, amendment, custodian, dental, Health Information Act, medical clinic, OIPC, PIA, Privacy Impact Assessment

Who Is Doing The Recalls In Your Dental Practice?

Posted on October 30, 2020 by Meghan in Blog

Who Is Doing The Dental Recalls In Your Practice?

If you have an appointment schedule with a lot of openings, you might need a dental recall program.

If you have an appointment schedule with a lot of openings, you might need a dental recall program.

If you don't have many recall appointments in your schedule, you might need a dental recall program.

If you want to add additional or your first dental hygienist, you might need a dental recall program.

If you have patients that haven't seen you for a long time, you might need a dental recall program.

What 

Joanne Williams of U R DU Appointments is my guest on this episode of Practice Management Nuggets For Your Healthcare Practice!

She will share how a consistent dental recall program will help a dental practice improve dental care and increase your revenues.

Joanne Williams' #1 Tip to Dentists and Practice Managers

Be consistent with your patient recall program!Click to Tweet

 

My Favorite Takeaways From The Podcast

Joanne shared her extensive experience in the dental industry including these nuggets:

  • Don’t rely on digital automated dental recall system.
  • Patient management platform not just recall automation.
  • Expert tips on how to understand practice management software and statistics.
  • Don’t make this common mistake when assigning staff to implement a patient recall program!
  • A personal contact will maximize the patient recall success rates.

Featured Guest: Joanne Williams

U R DU Appointments

Joanne Williams brings 20 years of experience managing a dental clinic in Calgary Alberta. Patient management within a digital environment is one of the strengths the U R DU appointment services. A good patient dental recall program is the heartbeat of the dental clinic. 

From the moment she started her career in dentistry, Joanne Williams knew it would be an interesting and challenging one. With over 20 years of experience managing a dental clinic, she enjoys working and learning the management side of dentistry. After adapting to the introduction of technology to the industry and building systems for a new paperless environment, Joanne is ready to take on new challenges as a member of the U R DU team.

When not at work, Joanne retains her passion for communication and productivity. A passionate biker, gardener, and golfer, she is also a loving partner, mother, and grandmother. Outside of the office, there’s nothing she loves more than being out on the greens under a wide-open sky.

To find more, see https://urduappointments.ca/

 

Be sure to tune in to my interview with Joanne Williams

Who Is Doing The Recalls In Your Dental Practice | Episode #096

Listen To The Podcast Here

You may also be interested in:

Privacy Awareness in Healthcare Training: Dental Practices 

Improved Communication, Improved Dental Business 

#PracticeManagementNugget, dental, dental recall, dental recare, Joanne Williams, podcast, urdu appointments

3 Parts to Every Privacy Awareness Training Plan

Posted on June 15, 2020 by Jean Eaton in Blog, Clinic Manager / Privacy Officer, Employee, Established Practice, New Practice, Services

Reasonable Safeguards – the Myth

You may have heard the myth that the Health Information Act (HIA) is a big scary thing that will interrupt your routine, rob you of countless billable hours, impact all of your staff, turn your office inside out, and change the way that you run your entire business!

Myth Buster

The HIA provides structure and framework for reasonable safeguards that apply to any healthcare business.

One of the requirements of reasonable safeguards includes having a privacy awareness training plan.

     
Privacy Awareness Training

Click the >> arrow to play the video

Privacy Awareness Training

Your Privacy Awareness Training Plan should include learning objectives throughout the year, including

  • Orientation – Standardized training curriculum provided to everyone in you healthcare practice at the time of employment. This is often included during a new employee’s orientation period.
  • Specific – Privacy training that is more detailed and specific to the roles and responsibilities of that individual’s job in your healthcare practice. There may also be specific training when new software, technology, or procedures are introduced anytime throughout the employment.
  • Reward – Keep privacy awareness top of mind all year long. Recognize and reward when individuals follow privacy principles that also add value to your client satisfaction or business efficiency.

It is reasonable to expect regular privacy awareness training, especially at orientation, and a formal review annually.

What a Privacy Awareness Training Plan Can Do For You

When you implement regular privacy awareness training, you will see:

  • Privacy and security expectations clearly communicated among your team.
  • Team members demonstrate their commitment to privacy, confidentiality, security of personal health information.
  • Efficient practices that protect the privacy and save you time and money
  • Team members confidently and correctly handle personal health information using reasonable safeguards

Are You a Myth-Buster?

You can be a myth-buster, too, and implement privacy awareness training in your healthcare practice.

You can easily implement reasonable safeguards and meet HIA requirements to ensure privacy, confidentiality, and security of health information that saves you time, frustration and money.

If you need a little help, I have written a practical privacy awareness training course designed for the community health care practice. This is ideal for orientation of new employees and a refresher for the rest of us.

Privacy Awareness in Healthcare: Essentials

Understand basic health care privacy principles and how to handle personal information, use safeguards, and recognize and report a privacy breach.

Ideal for community-based health care professionals and staff, direct care providers, or anyone working with a health care, dental, or social services organization.

An effective privacy compliance program promotes organizational adherence to the Health Information Act (HIA), Personal Information Protection Act (PIPA) Alberta, Personal Health Information Protection Act (PHIPA) Ontario and the Personal Information Protection of Electronic Documents Act (PIPEDA) requirements. A compliance program is your first line of defense to promote the prevention of criminal conduct, and enforce government rules and regulations, while providing quality care to patients. All three training products help protect practices against privacy and security breaches, improper payments, fraud and abuse, and other potential liability areas through education.

Canadian Health Care Privacy Training Solutions

Corridor’s online training makes it easy for health care organizations to comply with provincial and federal legislation that mandates regular privacy training for all health care providers, staff, and vendors.

Select the training that best fits your needs:

NEW! Privacy Awareness in Healthcare Training: Dental Practices – Alberta

Dentists and dental practices in Alberta are required to have an ongoing privacy program to ensure the protection of private records and patient information. The appropriate collection, use, and disclosure of personal information is critical to maintaining privacy for patients that choose to trust in your practice. Accomplishing this important goal demands an up-to-date training strategy.

Privacy Awareness in Health Care Training – Canada

Includes detailed resources for each province and territory with key terminology and links to applicable privacy legislation. Resources are provided for our ten provinces: Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland & Labrador, Nova Scotia, Ontario, Prince Edward Island, Quebec, Saskatchewan, and three territories: Northwest Territories, Nunavut and Yukon. This new product is ideal for both organizations and vendors who provide health care services or have health care clients in more than one province.

Privacy Awareness in Health Care Training – Alberta 

Includes the mandatory privacy breach notification amendments to the Health Information Act (HIA).

Privacy Awareness in Health Care Training – Ontario

Specifically covers all legislation and rules specific to the province of Ontario including the Personal Health Information Protection Act (PHIPA).

Refresher: Privacy Awareness in Health Care – Alberta

A quiz-based review of Corridor’s full Privacy Awareness course. The Refresher starts with an initial quiz to assess knowledge on the topics and information covered in the full course. Based on the quiz results, one or more of eight Refresher topic quizzes must be completed, each focusing on a specific subject area. The Refresher also includes access to the original course content.

 

Privacy Awareness in Healthcare: Essentials

Grab your on-line course from Information Managers and Corridor Interactive

for just $30 per individual 3 month subscription now!

Click Here to Grab Your On-Line Privacy Awareness Course Now!
Alberta, Canada, Corridor Interactive, dental, Health Information Act, Ontario, Personal Health Information Protection Act (PHIPA), PHIPA, PIPEDA, privacy awareness training, reasonable safeguards

Improved Communication, Improved Dental Business

Posted on November 5, 2019 by Jean Eaton in Blog

Would you like to increase your dental business practice revenue immediately?

Maybe you have a need to maximize efficiencies and create your dream team.

Dr. Angela Mulrooney believes that when you focus on communication with your customers and create consistency in your dental practice, you will increase your revenue and reduce your working hours.

Angela Mulrooney is the Business Doctor, and today she is my guest expert.

Meet Dr. Angela Mulrooney

Angela Mulrooney is published author, a retired dentist, and a dental practice coach who resides in Calgary.

Angela Mulrooney discussed how communication with patients and your team and a marketing strategy can improve your business.

If you would like to transform your dental practice and maximize the potential within the practice so that you can focus on spending more time with patients, giving them the best care that you possibly can while trying to level up everyone's skills in the practice as well, be sure to tune in to my interview with Dr. Angela Mulrooney, Improved Communication, Improved Business Episode | #081.

Don’t Miss This!

Angela has a generous offer for you to get a complimentary 1 hour strategy call to discuss your practice.

Listen to the Practice Management Nuggets Podcast For Your Healthcare Practice Here.

#PracticeManagementNuggets, #SocialMediaGuru, Angela Mulrooney, business, coaching, dental, dental business My Business Doctor, dentist, marketing

Does a Dentist Need a PIA?

Posted on May 22, 2018 by Jean Eaton in Blog
Have you ever said…

“If only I had someone to ask!”

Each month, we discuss your questions about practice management, human resources issues, clinic management best practices, procedures, resources, practical privacy tips, and more in Practice Management Success membership.

 

In this Q&A, we're talking about: Does a Dentist Need a PIA?

If you are a member of Practice Management Success, login and join me now on the webinar. The replay will be available in your membership area.

I’ve had a dental practice for 10 years. Do I need a PIA?

 

In Alberta, the Health Information Act (HIA) was proclaimed in 2001.

Dentists and dental hygienists were named as a designated health professional under the HIA in March 2011.

A custodian as defined by the HIA is defined

1) as a member of a Regulated Health Profession

2) the Health Profession is named in the HIA as a custodian

3) the individual is acting as a custodian

There is a ‘grandfathering’ period when custodians who were already in practice at the time are not required to submit a privacy impact assessment (PIA). The dental practice, of course, must meet all of their dental college requirements including appropriate privacy and security policies, procedures, and reasonable safeguards to protect the privacy, confidentiality, and security of personal health information.

If  (when) you have had any changes to your practice, you need to complete a PIA. For example, since 2011, have you had any changes to:

  • administrative practice, for example, changes to billing practices, third party contractors, moving to a new location, etc.
  • information system, for example, computer network changes, remote backup, or practice management or EMR software
  • practices relating to the collection, use, disclosure of personal (health) information
  • new or changes to your current information flow (for example new projects, stakeholders, Netcare)
  • legislation (i.e. research)
  • any new risks to the privacy of health information
  • custodians, for example custodians (including dentists and dental hygienists) leaving or joining your practice

The PIA is a process that assists custodians to review the impact that an implementation of a new administrative practice, information system, or change to existing practices or systems relating to the collection, use and disclosure of individually identifying health information, may have on individual privacy.

A PIA describes the information flows in the project, identifies the legal authorities that allow for the flow of information, assesses potential impacts on and risks to privacy and identifies mitigation strategies to minimize the risks.

The process is designed to ensure that the custodian evaluates the new practice or proposed change to ensure technical compliance with the HIA as well as assessing the broader privacy implications for individuals.

Often, the Privacy Officer of the dental practice completes the Privacy Impact Assessment.  However, the custodian or CEO is responsible for the Privacy Impact Assessment.

Privacy principles and legal authority determine compliance obligations.

If you don't have a PIA already for your dental practice, and you were in practice prior to 2011, you probably will need a PIA soon. If you opened your practice after 2011, or are just planning your practice now, you need a PIA.

For more information about PIA's, pop over to our resource page here:

Tell me more about PIA's

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