How a Disaster Contingency Plan Can Help Your Practice
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by Marianne Harper
The headlines jump out at you ... a Category 4 hurricane is sitting off the coast of your state wielding its fury. Your practice is in the path of the storm, and you are very worried. Mother Nature is in charge at this point, and she leaves you feeling helpless. However, there is a way to prepare your practice should the worst happen.
If you believe that because you do not live in the path of hurricanes or tornadoes, you shouldn't have to worry about practice risks, think twice. Here are some risks that can lead to disaster for your practice:
- Natural disasters in the form of hurricanes, earthquakes, floods, tornadoes, ice storms and blizzards, or wildfires
- Human risks such as terrorist attacks, civil unrest, or theft
- Technological problems such as those resulting from hackers or viruses
Dental practices can and should be prepared now with a disaster contingency plan. In preparing your office for HIPAA compliance, you will be required to have just such a contingency plan in writing.
"The HIPAA Security Rule 164.308(a)(7)(i) identifies Contingency Plan as a standard under Administrative Safeguards. Contingency Planning means the overall process of developing an approved set of arrangements and procedures to ensure your business can respond to a disaster and resume its critical business functions within a required time frame objective. The primary objective is to reduce the level of risk and cost to you and the impact on your staff, customers, and suppliers."
There are six areas that need to be addressed in a disaster contingency plan: preparation for disaster, assessment once the disaster has occurred, notification of staff and patients, paper file recovery, alternate location, and resumption of business at the original or new location.
Preparation for disaster
Preparation is undoubtedly the most important aspect of the contingency plan. Without preparation there is no plan, and no plan will leave you lost and without resources to resume your practice in a reasonable period of time. The preparation phase will mitigate the risks, and it will need to involve the following:
• Daily computer backups — Off-site backups are the preferred method of backup, because the off-site location is almost always in a different area than the practice's location and not subject to the same natural disasters. Backups must be done daily, and these backups must be checked every day for errors. The cost of the off-site backup service is not high and provides a much better situation than backup tapes that need to be stored in another location. Alternatively, if your only backup is on some form of portable media such as tape, these will need to be taken to a safe location. Plan on where that will be and who will be responsible for it. We have all heard about thefts of such data and you need to be aware that you are liable for the loss of that data should it be lost or stolen.
HIPAA's ruling on this states, "Should a covered entity experience loss of EPHI via portable media, the entity's security incident procedures must specify the actions workforce members must take to manage harmful effects of the loss. Procedures may include securing and preserving evidence; managing the harmful effects of improper use or disclosure; and notification to affected parties." You will be obligated to report the loss to all patients who are in your database, and the cost of this would be considerable.
• Documentation — Prior to any event, you will need to have available:
- An equipment inventory list that also includes phone numbers of all hardware, software, and media vendors. This list must be kept off-site for safekeeping.
- Photos or videotapes of the office and its equipment should be made and also kept off-site.
- Lists of the telephone and cell phone numbers of the doctor and staff should be kept by the doctor and all employees. Copies of this list should be laminated and updated periodically.
- Recovery plan duties should be divided between the doctor and staff.
• Insurance coverage should be checked annually to be sure that it is adequate.
• Miscellaneous supplies — A schedule should be posted to record periodic checks on supplies of plastic bags, batteries, pails, plastic sheeting, mops, sponges, and personal protective coverings such as disposable gloves and eye protection.
• An alternate site must be determined where doctor and staff can meet to work on recovery plans.
The following must be included in your contingency plan for when disaster is imminent:
- Move any nonfixed equipment away from windows when hurricanes are near.
- Raise moveable equipment to a higher level when floods threaten.
- Cover computers and related equipment in plastic.
- Shut down and unplug all computers.
- If a battery backup unit such as a UPS is used, unplug it.
- In the event of an evacuation, disconnect the server unit only and take it to a safer location, if possible.
- Take all software CDs to a safer location. These should be kept in a fire-proof safe at all times.
- Cell phones need to be fully charged.
- Automobiles should be filled with fuel.
- Make paper copies of the schedule for the next five days and include patient phone numbers. These should be given to several employees and the doctor. The schedules will be used to communicate with patients to alert them as to the status of their appointments, if possible.
- Put all important files in locked cabinets.
- Close all office doors.
Assessment involves checking out the damage to the building's structure and to nonstructural components such as equipment and furnishings. Access to utilities such as electric power, heating and cooling, ventilation, and telephone must be determined. Be prepared with names and phone numbers of inspectors who can help with the process of determining if the practice can be reopened in that location. The insurance company must also be contacted.
Notification is the next step in the plan. The doctor will notify the staff of the results of the assessment. A meeting will need to be scheduled either at the site of the practice or at the designated alternate location. Employees will be instructed to perform their assigned duties. If the office setting is determined to be unsafe, a sign will need to be posted at that location advising patients of the closure in addition to any information about an alternate setting. Set up a remote call forwarding with the phone company to reroute phone calls to the alternate location.
Paper file recovery
Paper file recovery is essential, if possible. Try to separate the legible from illegible files. Dry out all possible records. Do not destroy any patient records; rather, store the ones that will not be usable in sealed bags and keep them for at least three years for patient protection. Dry out, if possible, all accounting records and calendars.
Your plan for choosing an alternate location needs to include many steps:
- Be prepared to make a lease arrangement.
- Advise staff members of the change.
- Contact the dental supply and equipment vendors of the new location in order to set up practice.
- Contact the computer hardware and software vendors to start reinstallation of software and the data from backup files.
- Determine all office equipment that will need to be purchased, such as phones, faxes, copiers, etc.
- Determine all other supplies that will be needed.
- Either rent or purchase furnishings.
- Route phone calls to the new location. Leave an outgoing message on an answering machine advising patients of the status of the situation and the location of the alternate location.
- Once computers are operational, notify patients of the start date for the new location and the address.
- Notify the bank and post office of the situation and location.
- Contact the accountant/CPA about the situation.
- Place an ad in the newspaper to alert patients as to the changes and request that they contact the office.
Resumption of business
The final step involves deciding whether to return to the original practice location or not. Once this decision has been made, patients will need to be informed.
Although this contingency plan is long and detailed, it is the only way to be truly prepared. Once you have set up your plan, be sure to review it on a regular basis in addition to testing it. This can be done at staff meetings. We have often heard the expression "Don't mess with Mother Nature." We do need to respect her, but with a good disaster contingency plan in place, we are not helpless and we can rest more easily at night knowing that we are prepared.
Marianne Harper is the owner of The Art of Practice Management. Her areas of expertise are revenue and collection systems, front-desk systems, and dental-medical cross-coding. She is a well-respected speaker nationally, has been published in dental journals, and is the author of "CrossWalking — A Guide Through the CrossWalk of Dental to Medical Coding." Harper is a member of The Academy of Dental Management Consultants and the Speaking Consulting Network. Her Web site is www.artofpracticemanagement.com.
References available upon request.
A tornado roared through downtown Atlanta on the evening of March 14 while the 96th Thomas P. Hinman Dental Meeting was being held at the Georgia World Congress Center. The tornado caused extensive damage, resulting in the meeting being closed before its scheduled March 15 completion. Following are three eyewitness accounts from meeting attendees about the storm and its aftermath.
By Annette Wolfe, RDH, BS, Professional Services Specialist, D4D Technologies, LLC
Some of my colleagues from D4D Technologies and I were having dinner with Dr. Tony Soileau and people from Ivoclar Vivadent and Henry Schein. We were five short blocks from the Omni. A couple of us were discussing how nice it was that we had finished dinner early enough to be able to go to our hotels and get a good night's rest. It was about 9:30 p.m. as we started to leave the restaurant. Dr. Soileau began walking to the Omni Hotel since it was such a nice evening. Here are Tony's exact words:
I had dinner Saturday night with the sales team from Henry Schein Dental, Ivoclar Vivadent, and D4D Technologies while at the Hinman Meeting. We had a great meal, and when it ended I decided to walk back to the hotel. The Omni was only five blocks from the restaurant and it was a perfect evening. The temperature was kinda cool with a slight breeze — not a cloud in the sky. After I had walked two blocks, I felt some very large raindrops fall on me. At this exact time a cab stopped at a red light next to me where I was waiting to cross. I told him I would give him $10 to take me the remaining three blocks so I wouldn't get soaked. He agreed so I got in the cab. We went one block and stopped at the red light. Before the light turned green the cab started getting pummeled by debris and ice/hail. Then we saw large pieces of tin, trees from the park, and trash flying across the road in front of us. Then the light pole holding the red light just flew away. We had no idea that we were in direct line of the tornado. I saw other cars quickly turn around and go back out of harm's way, but for some reason my driver put his head below the seats and just pushed the gas pedal with his hand. The next thing I knew we were moving forward, then sideways. The noise was amazingly loud. Then as quickly as it started, everything stopped. I felt the cab being pushed back over and become upright. I crawled out of one of the broken windows. I then spent the next few hours in the basement of the Omni Hotel because another storm cell was coming our way. Finally I got to walk up nine flights of stairs to my room to get an hour of sleep. And I thought the weather for Chicago Midwinter was always the worst!
At the same time that was happening, I was still with some of my group back at the restaurant. We were going to walk to our hotels (some were staying at the Omni and a couple of us at the Sheraton). (Just a note: I had tried to get a room at the Omni, but couldn't get in. I was disappointed and on a waiting list for cancellations. There were no cancellations, so I ended up at the Sheraton. This morning I sent an e-mail to the person at travel services, thanking her for putting me at the Sheraton. I told her I do prefer a room with a window.) Anyway, we were ready to walk to our hotels when the rain started. The wind then kicked up and blew one way and then another. It was incredible to watch. Then debris started flying down the street. A man came into the restaurant bleeding from flying debris. The storm ended as quickly as it began. A second later, everyone was on their cell phones. Word was out quickly that the storm was a tornado and that it had hit the Omni and convention center. We were so worried about Dr. Soileau, as we knew he was headed right for the storm. We heard the sirens going off and saw flashing lights from the emergency vehicles. Glass, debris, and dry-wall pieces were everywhere. We walked toward the Omni, but couldn't get in. It looked like a war zone around the area — like a bomb went off. We were walking around for quite some time when we heard another storm was on the way. The people I was with went to the Sheraton with me and waited things out for a while in my room. Two of them who were staying at the Omni finally walked back to the Omni and were allowed in. We spent the next morning walking around taking pictures and talking with people. We tried to go into the convention center, but nobody was allowed in. We finally had to go back inside our hotel when another tornado was sighted heading for Atlanta. My friend who was in the Omni lobby was led to the basement. Some large hail fell, but that tornado didn't hit Atlanta. There were (I think) two people killed by a tornado in a town further east. It is truly a miracle that nobody was killed Friday night. I spoke with people who were staying at the Omni. One slept in her room without a window. She said she was so exhausted when she could finally got to her room (about 2 a.m.) that she fell asleep on the bed away from the window. She slept until the next storm hit (about 6 to 6:30 a.m.). I heard a story of one person who had the window blown out of her room and a chair flew out. The pictures I sent that Gavin Sternberg took describe the scene better than my words. If you would like more pictures, let me know. But I think I sent the best ones.
The people around me kept extremely calm, considering the situation. I did talk to a couple of people who were at different restaurants when the tornado hit. They told me some people did panic — one lady was sobbing. A couple of people were injured when they were running to shelter from flying glass and debris. Our "early" evening ended around 2:30 a.m.
Stunned on Saturday in Atlanta • By Ted Anibal, Assistant Editor, Dental Economics®
Jennifer M. Riggs is the front desk coordinator for the Peachtree Smile Center located at 2045 Peachtree Road in Atlanta. She was scheduled for an 8:30 a.m. continuing education course on Saturday, March 15, at the Thomas P. Hinman Dental Meeting held at the Georgia World Congress Center downtown. Riggs had not listened to news broadcasts that morning nor heard any warning sirens when the tornado hit on Friday night. She discovered the devastation firsthand as she approached the downtown area and was repeatedly detoured by police barricades. Riggs never made it to the GWCC, and became very concerned about her office and the safety of her co-workers. As she was attempting to navigate the downtown streets strewn with broken glass and debris, a friend called Riggs' cell phone to check on her safety. At that point, Riggs pulled into a church parking lot near the State Capitol and wept as she was finally overcome by the extent and severity of the tornado damage. Riggs reported that she made it out of the downtown area safely and confirmed that her office and co-workers were safe. On Monday, March 17, Riggs was on the job fielding phone calls from patients who sustained injuries or damage to their homes and had to reschedule their dental appointments.
Editor's note: My follow-up call to Mrs. Riggs' office revealed that the patients who rescheduled on Monday did so because they work downtown and needed to remain at work to complete the cleanup and disaster recovery work in their offices. There were no reported injuries or damage to their homes. — Ted Anibal