Safety

Use discretion in the waiting room

Ambulatory Safety Monitor, February 17, 2005

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Compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) is as important in the waiting room of your ambulatory surgery center (ASC) as it is in the operating room.

The waiting room is the front door to protected health information (PHI), which means you must enforce security measures to protect your facility and the privacy of the patients you treat.

Although HIPAA does not prohibit calling out patient names in the waiting room, names alone can reveal health information, especially in a highly specialized facility. For instance, simply having your name associated with an oncology unit or a fertility clinic can reveal PHI.

ASCs must take care to protect patient privacy at all costs. Assess alternatives to calling out patient names if identifying patients by name may reveal sensitive information or damage a patient's reputation.

"Typical of HIPAA, each facility must assess its risk," says Chris Apgar, president of Apgar & Associates, LLC, in Portland, OR. Facilities need to maintain a level of appropriateness and use good judgment, he adds.

In a small town, where most everyone knows each other, calling patient names in a waiting room is not releasing PHI and is not a violation of HIPAA. Calling patient names in a family practice, a dentist's office, or an internal medicine waiting room also complies with the privacy rule, says Kate Borten, CISSP, CISM, founder and president of the Marblehead Group, Inc., in Marblehead, MA. And calling names is unlikely to reveal patient information in a busy, loud waiting room.

But saying anything more than the patient's name can become problematic. "Offices have an obligation to be subtle with any information that can reveal anything about a patient's condition," says Borten.

Solutions to waiting room risks

Consider the following options when restructuring your waiting room policies:

  • Use a sign-in sheet. One inexpensive solution is a sign-in sheet you can leave in the waiting room. Cover the top of the sheet with another piece of paper that patients can slide down to cover their names. Some facilities use sign-in sheets with separate stickers for each patient. Patients write their names on the stickers and bring them to the receptionist, eliminating the ability of other patients to read names on the sign-in sheet.

 

  • Call patients by first name only. This protects you when calling patients to an examining room, Apgar says. However, remember that some patients may share first names or may take offense to the informality of using first names only, says Borten. Use the first initial of the last name or add a title such as Miss or Mister to the first name to avoid confusion and appease patients.

Calling out names is ultimately okay, but when a doctor calls after a patient, "Wait, John Smith, I'll write you a prescription for . . ." the doctor is violating HIPAA. "It's one thing to call out a name," says Borten. "It's another to reveal personal information."

  • Assign each patient a number. This would be appropriate in a fertility clinic or any other facility with highly sensitive treatment. A number is far less revealing than a name.

Keep track of the numbers in a secure database. When you give patients numbers for the first time, ask for questions and answers that you can use in the future if patients forget their numbers. The questions will help ensure that you provide the correct number to the correct patient.

  • Distribute pagers. Some facilities use pagers that light up or vibrate when it's time for a patient to see the doctor-similar to what restaurants use to notify patrons when their table is ready, says Borten.



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