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• Instructions for setting up instant messaging technology (e.g., with chat messenger apps) that enables staff to communicate without a wireless network or cellular data connection.
• Instructions for securing records of patients undergoing diagnostic testing and a list of out- standing diagnostic studies requiring follow-up.
• Guidelines for maintaining HIPAA compliance. Although the HIPAA Privacy Rule is not suspended during a natural disaster or other emergency, the Secretary of Health and Human Services may waive certain provisions of the Privacy Rule, and the Office of Civil Rights may issue notifications of temporary enforcement discretion (e.g., see notifications related to COVID-19).
• Copies of certificates of insurance for your medi- cal malpractice coverage and all product lines (such as general liability, cybersecurity, and employment practices) or instructions for con- tacting your agents or insurers directly to obtain proof of coverage and policy terms. These docu- ments will be necessary if you are forced to temporarily relocate your practice or procedures or convert your delivery of care to a virtual format.
• Steps to follow upon returning from evacuation to ensure continuity of care and operational readi- ness to resume office functions.
Once your plan is in place, reevaluate it regularly and update all information—including disaster poli- cies and procedures, contacts, insurance coverages, and legal documents.
When Disaster Strikes
Planning today makes accomplishing the following tasks more feasible during a disaster:
Communication
• Stay current on emergency directives from state and local governmental disaster relief and recov- ery entities.
• Contact staff immediately to determine return-to- work time frames as permitted.
• Notify external vendors and business associates of your practice interruption and targeted resumption of operation.
• Implement virtual staff briefings at the beginning and end of each day.
• Create temporary phone, fax, and answering services if necessary.
• Establish patient telephone triage. (See our article, “Telephone Triage and Medical Advice.”
• Establish telehealth services as capabilities permit. (For more information, visit our “Tele- health Resource Center.”
• Implement temporary controls to ensure HIPAA compliance.
Medical records
• Determine the extent of damage to, or loss of, patient records and filing systems.
• Attempt to restore all damaged charts and rele- vant business records, and document inventory findings.
• Check the websites of your state medical board and federal agencies, such as the Department of Health and Human Services and the Centers for Medicare and Medicaid Services, for specific guidance pertaining to lost or damaged records.
• Document all efforts to restore and protect existing records.
• Reconstruct lost charts at the next patient encounter with the notation that the record is a re-creation.
• Contact your insurance carrier for restorative services and/or claim procedures.
• Reestablish a filing system and temporary storage if necessary.
• Obtain legal guidance for patient notification during recovery efforts.
• Contemporaneously date and initial all late entries and duplicate information in context of recovery efforts.
Computers and systems
• Contact computer service vendors to ensure integrity and recovery.
• Verify insurance coverage for repair or replace- ment costs and losses.
• Evaluate applicable warranties and consider contracting with an information technology restoration service.
• Inventory and document hardware and software.
• Document the type and extent of both lost electronic and paper data.
• Ensure data backup and periodically test compliance.
• Reestablish filing systems and internal programs.
Medical office building
• Notify the building owner and your property insurance company regarding damage.
    SEPTEMBER/OCTOBER 2020 | WWW.OCMS-MI.ORG
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