2022 Risk Management Resolutions
It’s that time of year again – time to take stock and reflect upon where we have been and where we are headed. Physically, you may have traveled far less in the last 21 months than ever before, but you have, nonetheless, been on quite a journey!
Many of you have likely made changes to the way you practice. You may have decided to give up the expense and hassle of working in an office in favor of practicing telemedicine from your home. You may have elected to cut back on your hours or to close your practice entirely and join a group. You may have realized that there are particular conditions you have a special interest in treating or types of patients and situations you want to avoid going forward. Even if you haven’t made dramatic changes yourself, you’ve no doubt been reminded of the unpredictability of life and practice.
As you look forward to 2022, here are a few New Year's Resolutions from PRMS® Risk Management to consider:
- Get control of your charts. Those who have temporarily given up office space or relocated completely may have been forced to make hasty arrangements for their charts. If you’ve left part of them behind as you work out of a temporary space, or have boxes stuck in your basement, now is the time to get a handle on them. Make sure you know where all charts are located, determine whether older charts may be destroyed, and ensure everything you keep is securely stored. For additional information see “Retaining and Discarding Psychiatric Records” and “Medical Record Storage Company Agreements.”
- Determine who your active patients are. Since the onset of the pandemic, a number of your patients have likely fallen out of treatment due to relocation or changes to their financial situations or health insurance plans. You’ve likely also have had a few patients who saw you remotely for a visit or two but didn’t follow through with treatment. In order to ensure that there is a clear understanding between yourself and the patient as to the status of your relationship, consider sending them a letter to either confirm their decision to end treatment or make them aware that their chart will be closed if you do not hear from them within a given timeframe. Sample letters may be found in “Termination of the Physician-Patient Relationship.”
- If you are unable to see patients in person at your current practice location, consider making arrangements to borrow space from a colleague in the event a face-to-face visit is needed at some point in the future. During the PHE, the DEA has waived the Ryan Haight Act's requirement for an in-person visit prior to prescribing a controlled substance; however, it is anticipated that this requirement will be reinstated once the PHE has expired. Many states follow this rule as well, but others may have a state requirement in effect for an in-person visit. Beyond the need to satisfy prescribing requirements, there may also be other patients for whom you believe an occasional face-to-face appointment would be beneficial. If you do not have a colleague with extra space, consider seeing if your local hospital can accommodate you.
- Develop a contingency plan to allow someone to either take over your practice during your unexpected absence or shut it down completely in the event you are not able to return. For more information see “Initiating My Contingency Plan.”