I recently wrote a newsletter article on the importance of walking through the organization with “HIPAA Goggles” on as a way to see potential HIPAA issues that may be overlooked as we go about our jobs on a daily basis. Our brains typically call to our attention things that are different or out of place; the more we walk past something, the less likely we are to notice it because our brains adapt and accept the presence of the item as normal. Unless we take the time to specifically look for potential HIPAA issues there is a high probability we will walk past the computer screen that is public facing, or the med cart in the hall with the computer screen up showing PHI without even noticing them. If we are used to conversations in the hallway that include PHI we may not even realize they are happening all around us.
HIPAA walk through audits are an effective way to refocus and see what we may have been missing. The key to conducting a HIPAA walk through audit is to actually walk through the building, department, location, etc. with a checklist in hand. Organizations may try to couple a HIPAA audit with a safety review, or as part of a fire drill but unless the sole purpose of the walk through audit is to “see” and identify potential HIPAA violations, the audit likely won’t produce the desired result. Using a written checklist ensures the person doing the audit wears those “HIPAA Goggles” and deliberately looks for the potential issues on the list.
A comment I often get from providers who do HIPAA walk through audits on a regular basis is “the staff know the questions I am going to ask and the answers to give so what good is it to ask them to name the privacy officer?” To that I say, it is time to change the questions! I recommend having a couple of versions of the checklist so each time an audit is completed the focus is on different potential issues. The goal is to see new things each time an audit is completed in an effort to continuously improve the level of HIPAA compliance.
If you are looking for help on how to conduct HIPAA walk through audits check out the resources on www.cp-hipaasolutions.com for checklists and how-to modules.