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Practice Management & Allied Staff News & Materials

Practice Management Matters - Jan/Feb 2010

February 1st, 2010

Question:
One of our referring dentists wants to send X-rays via e-mail, however identifying information is provided on the X-ray and their e-mails are not encrypted. Is this a HIPAA violation?

Answer:
Electronic communication of protected health information (PHI) between providers is permitted using secure electronic messaging. Secure electronic messaging is the transmission of electronic messages via a system that has the capability of securely encrypting the messages from point of entry into the messaging system until delivered to the intended recipient in such a way that only that intended recipient can decrypt them. Some messaging systems can send both secure and unsecure electronic messages; messages sent via such a system are deemed secure only when encryption is employed for those messages. Additional information can be found at the Web sites below.

http://hipaa.yale.edu/guidance/emailconfidentiality.html
http://www.cms.hhs.gov/EducationMaterials/Downloads/SmallProvider4final.pdf
http://luxsci.com/blog/what-hipaasays-about-e-mail-security.html
http://www.cms.hhs.gov/SecurityStandard/Downloads/SecurityGuidanceforRemoteUseFinal122806rev.pdf

Question:
Can we use bleach to disinfect in the office?

Answer:
For many years it was recommended that health care facilities use 1:10 or 1:100 bleach-to-water mixture to clean patient rooms because it was the best at killing infectious organisms. Now manufacturers have produced EPA-registered quaternary ammonium (Quat) or other low-level or intermediate-level disinfectants. Many facilities have switched from bleach for routine disinfection because Quat is less toxic for environmental services employees and it eliminates the process of mixing chemicals, says Linda Dickey, RN, MPH, CIC, APIC, member and assistant director of epidemiology and infection prevention at the University of California, Irvine (CA) Healthcare. OSHA requires that health care facilities routinely disinfect work surfaces and equipment after each shift and immediately after contact with blood or other potentially infectious materials. However, each facility must determine its own cleaning schedule. OSHA simply requires a documented cleaning schedule that includes the area, surface, required disinfectant, and frequency. The CDC's Guideline for Disinfection and Sterilization in Healthcare Facilities, 2008 is a primary resource for guidance on what disinfectants to use and how often to clean particular areas of your facility. Noncritical areas such as exam tables should be cleaned with disinfectant after every patient, particularly because of the risk of introducing MRSA into the environment. Other low-risk surfaces such as floors can be cleaned daily unless there is a spill; walls and ceilings can be disinfected annually. For more information, please visit: http://www.cdc.gov/ncidod/dhqp/pdf/guidelines/Disinfection_Nov_2008.pdf and www.osha.gov.

This question and answer was adapted and copied with permission from HCPro. Copyright 2009, OSHA Healthcare Advisor, November 2, 2009. http://blogs.hcpro.com/osha/

Question:
How long do I need to keep my drug inventory logs?

Answer:
According to Title 21, part 1300 of the Drug Enforcement Administration's (DEA) Diversion Program, there is a two-year mandate for keeping your drug inventory logs. Your state may have different regulations for maintaining these records. You must abide by whichever regulations are more stringent. For example, Illinois requires five-year retention of drug inventory logs. Since this is longer than the DEA mandate, in Illinois you need to abide by the state law. To obtain more information on Title 21, contact your state or regional DEA Diversion office. To access DEA applications and forms and to find your state or regional office, please visit www.deadiversion.usdoj.gov.

Do you have any practice management questions that you would like addressed in Practice Management Matters? Please contact Beth Hayson at 800-822-6637 ext. 4357 or bhayson@aaoms.org.

For answers to some of the most frequently asked practice management questions, visit the Practice Management FAQ.