With so many changes to daily lives and schedules due to COVD-19, healthcare practices are also changing. I think that these experiences have probably advanced telehealth, virtual care, and digital health initiatives ten years in the space of six weeks.
If you have been experiencing a whiplash headache from the speed of the changes to your practice management, you are not alone!
I am committed to help you with policy, procedure, and privacy impact assessment templates and resources to support you as you implement remote working and virtual care for your patients.
Use these policy and procedure and privacy impact assessment templates to help you provide virtual care while remote working and maintain reasonable safeguards to protect the privacy and security of personal health information.
If you are moving into remote working and virtual care or telehealth, it’s important that you have anticipated the risk to privacy, confidentiality, and security of patient information and have planned appropriate safeguards to prevent harm.
Patients don’t always know to ask questions about the risks of using new virtual care technology. Custodians and clinicians have a responsibility under the Health Information Act to inform patients about any additional risks to their privacy and health information while using technology in new ways. You could include this in your workflow when the patient appointment is made and the receptionist provides this information. Immediately prior to the on-line consultation, the clinician may review the collection consent and respond to questions from the patient before beginning the clinical encounter.
You might also have a legal requirement in Alberta to submit a privacy impact assessment to the Office of the Information and Privacy Commissioner.
If your healthcare practice is implementing remote working or virtual care, you need to notify the OIPC.
Health information is sensitive information. Reasonable efforts must be made to ensure that identifying and sensitive information is protected from unauthorized access, loss, or damage during and outside work hours. What a custodian may consider is reasonable efforts during a pandemic may be different than reasonable efforts from normal circumstances.
In Alberta, section 64 of the Health Information Act (HIA) requires custodians to prepare a privacy impact assessment (PIA) and submit it to the Office of the Information and Privacy Commissioner (OIPC) of Alberta prior to implementing a new administrative or technical process in a healthcare practice.
During the pandemic, the OIPC of Alberta requests an email now to outline your implementation plan. Then, promise to follow-up with a Privacy Impact Assessment submission in a few weeks.
Remote Working and Virtual Care Policy, Procedure, and PIA Templates
Templates are a time-saving tool for anyone looking to move into remote working, telehealth or virtual care solutions. Your on-line course includes instant access to checklists and resources to help you select the best virtual care options.
The policies and procedures templates will help every clinician thinking of authorizing some (or all) of your staff to remote work from home and / or provide virtual care while ensuring the privacy and security of health information.
The templates are delivered to you inside the on-line course management platform called Ruzuku. The instructions and the templates are delivered in 6 lessons. The instructions in each lesson will take you less than 5 minutes each to read.
Then, you download the templates from Ruzuku to your computer and modify each template with your clinic-specific information. Editing the MS Word templates will take you about 3 hours. I can’t estimate the amount of time that you will require to read the templates, gather information and making decisions about your remote working and virtual care project.
As you build your policies and procedures and the supporting documents, you will copy and paste them into the key sections of your PIA.
Virtual Care Workflow
There are many ways to implement virtual care or telehealth in your practice. A common workflow process includes:
Schedule the Patient Appointment – Reception
Schedule the patient appointment in the EMR.
Telephone or send a secure email to the patient with the
- Appointment confirmation and instructions on how to use the video conference solution;
- Collection notice; and
- Privacy Officer contact information.
Request the patient to sign or verbally consent to the use electronic communication.
Time of Appointment – MOA
Receptionist / MOA initiates the video conference call with the patient.
Ensure patient can connect and hear the audio / see the video or shared screen.
Verify the patient identity.
Invite the clinician to join the video conference / make host of the call.
Notice of Collection / Consent – Clinician
Review the Notice of Collection and Consent and respond to any questions.
Confirm that the patient is in an appropriately private location.
Document Patient Encounter – Clinician
Confirm the patient’s understanding of the assessment and plan.
Arrange to send any prescriptions to pharmacies and any requisitions or referrals to the patient or the appropriate office/facility.
Complete the clinic note in the patient record.
Is Remote Working and Virtual Care Here To Stay?
Many practices are finding benefits to having flexibility to allow staff to work from home to accommodate illness, child care disruptions, and business continuity planning. Many patients are finding that they appreciate the convenience of accessing health services without parking, time off of work, or child care struggles. Sometimes, both clinicians and patients are discovering that this new modality has inspired a better understanding of the patient's home environment and creates opportunities to improve care and treatment.
I don't think we can put this genie back in the bottle. Remote working and virtual care will become a new normal – for some practices – at least on a part-time basis. Consequently, I recommend that you take the time needed now to get the procedures and safeguards right so that we protect the privacy, confidentiality, and security of health information, allow our clinicians to work to their full scope of practice, and provide the appropriate care and treatment in a way that is convenient for all parties.
I'm here to help you.
Take advantage of this offer to access the templates that will help you implement remote working and virtual care solutions in your practice.
Not sure if remote working is right for your healthcare practice?
Check out the The Practice Management Success Tip, Remote Worker Privacy and Security Checklist, which will help you:
- Determine if remote working is appropriate for your employees.
- Identify what clinic / business resources need to be provided to the employee remote worker.
- What reasonable safeguards need to be implemented to protect the privacy, confidentiality, and security of personal (health) information.
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