Talking with the Toothcop

In the first episode of this series, we talked about what a corporate integrity agreement is. In the second episode, we covered focusing on compliance. In this episode of Talking with the Toothcop, we are going to walk through an actual corporate integrity agreement. If you're caught in the OIG's crosshairs, this is just one example of what you might expect.

NOTE: These are NOT confidential and are public documents on the OIG website.

Outline of This Episode

• [2:15] A pediatric corporate integrity agreement
• [9:27] Reach out to us for support
• [12:02] Compliance Bootcamp 2021

A pediatric corporate integrity agreement

This CIA was executed in August 2016 with a three-year term (a CIA is typically a five-year term). The CIA stipulated that the dentist and all employees and contractors (including billing) had to establish a compliance program that included:

• Posting a notice in their office that patients could see—within 60 days of the effective date—that provides the OIG hotline number as a confidential means to report fraud or abuse.
• They had to include three hours of training and education for the practitioner and all covered entities within the first reporting period. That may only be satisfied by taking courses provided by the CMS Medicare Learning Network. It must include a billing, coding, and claims submission course and a medical record documentation course. New employees had to receive three hours of training within 45 days of being hired.
• An independent review organization was hired to conduct a review of the doctor's coding, billing, and claims submission to CMS.
• Ineligible persons include anyone barred or suspended from participation with federal healthcare programs (this shows the importance of continued exclusions checks). Doctors had to prove that they had checked and tracked that their employees were not on an exclusion list.
• For the purpose of this CIA, an overpayment meant the amount of money a doctor had received in excess of the amount due and payable under any federal healthcare program requirement. If an overpayment was identified, they had to repay it to the appropriate payer within 60 days. They then had to take steps to prevent overpayment from happening again. Any paid claim had to be supported with proper documentation.

This CIA didn't even flesh out all seven elements of a compliance program. Even if the situation is over, it's still a public record forever.

Get the help you need—now

Don't wait until you're in trouble to get help. Set up a compliance program to protect your practice so you don't end up on the chopping block. The prevention is worth it. Just because it hasn't happened doesn't mean it won't. If you'd like to schedule a call with me, call our office at 817-755-0035 to speak with Andrea and set up a Zoom call.

Resources & People Mentioned

• Closed Corporate Integrity Agreements
• CMS Medicare Learning Network

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

In the last episode, we talked about what a corporate integrity agreement is and what compliance programs should look like. In this episode of Talking with the Toothcop, we continue our series on corporate integrity agreements by looking at the OIG's Focus on Compliance roundtable discussion. If you participate with Medicare or Medicaid, you HAVE to pay attention to this.

Outline of This Episode

• [3:23] Corporate Integrity Agreements
• [5:21] The focus on compliance document
• [8:59] The board of directors
• [10:53] The role of the internal audit
• [11:26] Claims review requirements

Corporate Integrity Agreements

Just to recap, according to the OIG, a corporate integrity agreement is "Part of the settlement of Federal health care program investigations arising under a variety of civil false claims statutes. Providers or entities agree to the obligations, and in exchange, OIG agrees not to seek their exclusion from participation in Medicare, Medicaid, or other federal healthcare programs."

A CIA usually remains in effect for five years. If you don't agree to this, you lose the ability to participate in federally funded programs. If Medicare or Medicaid represent a large cross-section of your business, you could lose your business by losing the ability to work with them. It's a large reason why organizations agree to CIAs. CIAs have evolved into what they are today.

Focus on Compliance: The Next Generation of Corporate Integrity Agreements

In 2012, the OIG held a roundtable discussion with stakeholders with entities and organizations that were under an active CIA to get feedback. The goal was to tweak CIAs to make them more effective to organizations.

In this discussion, the CIAs required each participant to have a code of conduct setting forth their commitment to compliance. They also had to implement policies and procedures governing the compliance program and adherence to program requirements.

A code of conduct is a great foundation for a compliance program and establishing policies and procedures. Your written policies and procedures should address each of your risk areas. The OIG now leaves it up to the organization to identify what topics you need further training on based on the CIA. So they're moving away from an hours-driven training program to topic-driven. The government is responding to and taking feedback on some of their requirements.

The board of directors involvement

We do work with some dental partnership organizations and DSOs. CIAs require that the board of directors also receive training, reports from the compliance officer, and pass an annual resolution certifying the board is overseeing the compliance program.

The board's responsibilities result in more engaged board members, which assists in the allocation of resources to mitigate risk. An engaged board motivates executives and healthcare providers to commit more fully to compliance.

I spend a lot of time working actively with boards and compliance committees and I see this. It takes a few meetings to see people get why it's necessary. Once things click, I become more of a silent presence and less of the person leading the charge. This is how it should be.

What is the role of an internal audit? Why is it so important? Listen to learn more!

Claims review requirements

Most CIAs require the provider to conduct a discovery sample of 50 paid Medicare claims randomly selected from those submitted by the provider during a specified 12-month period. If the error rate is 5% or greater, the provider must conduct a full sample systems review—which is far more involved.

When an organization is under a CIA, they have to maintain an error rate of less than 5% in their audits. Based on my experience, this is difficult to accomplish. I've been doing record audits for over 10 years and the average error rate is north of 15%. Why? Because auditing processes aren't in place and people don't go back and check for mistakes.

The average dentist thinks they don't make that many mistakes, but unless you do audits and have definitive proof, you don't know. If you're playing the Medicaid/Medicare game, you've got to know that your error rate is below 5%.

You're not expected to have a full-time compliance officer in place—but you are required to have auditing and monitoring processes in place. So if you're a small dental office, you must pull and audit at least 50 coding and billing records a year.

Need help with this process? Send me an email and I'll share some samples of overpayment lists.

Resources & People Mentioned

• TWT Episode: The 7 Elements of Dental Compliance Programs
• Focus on Compliance
• HHS Compliance Resources
• LIVE Compliance Training

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

This episode is the beginning of a series about corporate integrity agreements. One of the important elements that is part of a corporate integrity agreement is implementing a compliance program. Why is it so important to have a compliance program? What should it consist of? How can a compliance program save your practice? Find out in this episode of Talking with the Toothcop!

Outline of This Episode

• [2:40] Corporate integrity agreements
• [4:41] Compliance program guidelines
• [6:48] Why you want to implement a compliance program

What is a corporate integrity agreement (CIA)?

A corporate integrity agreement addresses a specific issue while attempting to accommodate or recognize the elements of compliance programs. A CIA typically lasts for five years with a certain amount of requirements attached. What are those requirements?

• The organization must hire a compliance officer and appoint a compliance committee
• They have to develop written standards and policies
• They must implement a comprehensive employee training program
• Retain an independent review organization to conduct annual reviews
• Establish a confidential disclosure program
• Restrict employment of eligible persons
• Report overpayments, events, ongoing investigations, and legal proceedings
• Provide implementation reports to the OIG on the status of compliance activities

A large part of demonstrating compliance is creating a compliance program. What should that consist of?

Compliance program guidelines

The OIG provides compliance guidance documents for the healthcare sector, including dental practices. Regardless of what sector of healthcare you're in, these compliance guidelines center around 7 elements of compliance:

1. Conduct internal monitoring and auditing processes
2. Implement written policies and procedures
3. Designate a compliance officer and compliance committee
4. Conduct effective compliance training and education
5. Respond promptly to violations and take timely corrective action
6. Develop effective lines of communication
7. Enforce standards through well-publicized disciplinary guidelines

A corporate integrity agreement is agreeing to create a compliance program—with the added bonus of a babysitter, the independent review organization.

The best way to learn is from others' mistakes, right? It's less painful and less costly. Compliance programs are NOT cheap. The government wants you to feel the pinch. They expect you to invest time, money, and effort into compliance.

Why you want to implement a compliance program

Long before the OIG came out with guidance, the US Judiciary came up with federal sentencing guidelines that existed for different types of crimes. Chapter 8 deals with healthcare fraud. The OIG compliance guidelines come directly from these US Federal Sentencing Guidelines.

If an organization gets busted for something—but has a reasonably effective compliance program in place—it can reduce fines and penalties up to 90%. When an organization is busted, the government's first ask after an audit is the highest amount. It can be millions of dollars. If you can reduce that by 90%, it can take $1 million down to $100,000. That's a big deal.

That is where your return on investment comes in. An effective compliance program will pay off. But it's also my goal that our clients never realize this investment. These are systems that you need to implement. When it comes to compliance, there's no such thing as "Set it and forget it."

Resources & People Mentioned

• LIVE Compliance Training
• Compliance Guidance for Individual and Small Group Physician Practices
• Compliance Program Guidance for Third-Party Medical Billing Companies
• TWT Episode: The 7 Elements of Dental Compliance Programs

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

Emergency medical kits are essential for dental practices—but most have a kit thrown under a cabinet that's stocked with expired medications. Scott Sankary is the Co-Founder at Protect It First Aid & Safety, a company striving to change this unsafe practice. They supply emergency products and monitor expiration dates to keep customers in compliance. What do they offer to dental practices? How is their solution better than their competitors? Find out in this episode of Talking with the Toothcop!

Outline of This Episode

• [0:35] Scott Sankary with Protect It Dental
• [5:47] Protect It Dental's EMK series
• [8:11] How to become a customer
• [14:34] Their subscription-based program
• [21:58] How are they different?

Protect It Dental's Emergency Medical Kits

Protect It Dental is best known in the dental world for their emergency medical kits—their EMKs. The kit itself is made of white metal, weighs approximately 9 pounds, is 15.5" by 6" by 10.5", and has a handle. It's well-marked as an emergency medical kit. It can be wall-mounted or stored on a countertop. They also have a grab-and-go magnetic wall mount. It's well organized and everything has a customized slot. There is also a product key on the inside door. The kit is designed to bring order and calm to a chaotic situation.

They have four kits to choose from, each with seven essential medications, consistent with ADA and GADA guidelines.

• EMK #1: This is the basic and most popular kit. It includes two diphenhydramine vials, two epi ampules, 1 albuterol, 1 adult EpiPen, 1 EpiPen trainer, 2 naloxone vials, nitroglycerin tablets, glucose, aspirin, ammonia inhalants, a CPR mask, and 2 syringes. If you don't work with kids or seniors, this kit will work for your practice.

• EMK #5: This is the same kit, except the nitroglycerin tablets are replaced by nitroglycerin spray—which is best practice for elderly patients who have swallow reflex issues. If you work with seniors—but not kids—this kit could be a good choice for your practice.
• EMK #10: This is the same as kit #1, plus a pediatric epi pen. If you see kids in your practice but not seniors, this is the kit for you.
• EMK #15: This is the same as kit #1 + a pediatric EpiPen + nitro spray. If you see both kids and seniors, this is the kit for you.

How to become a customer

Protect It Dental allows you to buy a kit, onboard existing medications (using proprietary technology), or purchase individual medications a la carte. But to get the full benefit of their program, you need to sign up for auto-replenishment. The problem is that so few people are willing to commit to sign-up for auto-replenishment because they're worried about cost.

Those that don't buy a kit and use the EMK onboarding wizard can ease into it. If you choose to onboard an existing kit, their site will walk you through the onboarding process, which will only take 10–15 minutes. The drugs get entered into the Protect It system so you're set to get replenished on the medications as they expire or are used. You'll receive a notification saying it's time to order and you simply pay as you receive replenishment medications.

If you're set up for auto-replenishment, you receive products 30 days before their expiration date. It comes with a postage-paid disposal bag to ship to their third-party destruction source.

The subscription-based program

Protect It Dental is now offering one-year or two-year subscription options. If a dentist chooses to continue to a second year after the first, they convert them to the two-year pricing and so on.

When a customer purchases a kit, all meds and supplies are pre-loaded into their system and management is simple. The subscription program solves everything. They receive a new kit for a single monthly payment. As items expire, new ones arrive and old ones can be disposed of.

Even if drugs are used—and not just expired—the replenishment is also included in the subscription program. They made it easy and cost-effective to acquire a new kit and enroll in the auto-replenishment program. You shouldn't have to worry about expiration dates and constant monitoring—Protect It can do it for you. The solution makes it really easy for dental practices to say "yes."

The dentist's investment is being protected. Patients are being protected. Some of these medications are life-saving. This subscription is eliminating apprehension and providing dentists with quality care. This is hard to compare to other options out there.

What sets Protect It Dental apart?

Protect It Dental is privately owned and there to serve the dental practice—not a shareholder. They're small, innovative, and high-tech. They have in-house developers and custom programming to fit their business. What they do is driven by conversations with customers and prospects. They're a small business supporting small businesses. Their pricing is customer-friendly and they have a genuine desire to help people.

Resources & People Mentioned

• Scotts Phone #: 817-800-9541
• Scott(at)ProtectItNow.com
• Scott Sankary
• Protect It Dental
• EMK Kits
• Onboard Existing Meds
• Individual Medications

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

Are you cultivating a culture of compliance in your dental practice? Are you careful about what you post on social media? Are you staying on top of X-ray machine maintenance? In this episode of Talking with the Toothcop, Andrea and I dive into some important compliance reminders you need to be mindful of—especially because OSHA is cracking the whip.

Outline of This Episode

• [3:21] It's time to create a culture of safety
• [4:59] A brief social media etiquette guide
• [6:22] OSHA is stepping it up
• [8:14] How to maintain your X-Ray machine
• [12:35] The topic of patient selection
• [15:18] What to do before administering Nitrous

OSHA is stepping it up

On March 12th, 2021 OSHA sent out a news release that said they launched a program to protect workers with safety concerns. OSHA is stepping up its enforcement efforts and protecting workers' rights to a safe work environment.

It's time to take this stuff seriously and step up your game. Don't look for loopholes—get this stuff done. We are seeing a shift under the new administration to enforce these things. If you get busted, it will be considered a serious violation. If you're willfully negligent, it could be up to a $150,000 fine for a single violation. They are out for blood.

A brief social media etiquette guide

I've gotten some questions about whether or not practices should post specific photos on social media. Before you post photos on social media, make sure you get signed releases from patients. Secondly, make sure anyone in the photo is wearing the proper PPE based on what the situation looks like—not what it is. We are still in a pandemic, so you better be wearing your respirator and other PPE whenever required. Rember, anything posted on social media can be evidence for anyone to use against you.

Maintain your X-Ray machine

There are things you need to do regularly to maintain compliance with your office's X-rays and to pass state inspection. I recently got a call from a client with an inspector in their office. I dropped everything to walk them through the situation. I talked directly with the inspector and directed her to the information that said what they were supposed to be doing. But it shouldn't have come to that. The office luckily didn't receive a fine but got slapped with a violation.

You have to use a multi-dimensional device or commercial device (i.e. a phantom or step wedge) with every sensor. You must test every sensor on every machine. The distance with the sensor and the cone head must be consistent every time you do the test to control variables. You have to do the same test with the same equipment with the same settings every single time.

What is the best way to do it? Listen to learn more! If you're still confused, shoot me an email if you have questions! I'm happy to help.

The topic of patient selection

Just because someone walks into your office doesn't mean they're your patient. They become your patient when you examine them and create a treatment plan for them (in Texas). If your first interaction is with the patient and some red flags come up, do not move forward. You can send them another dentist and go your separate ways.

But once you plan their care and present them with a treatment plan, you can only dismiss them with proper mechanisms (so you're not "abandoning" a patient). Listen to your gut feeling. These patients are the types that sue you or file state board complaints. You may have a huge compassionate heart—but you must protect it. Don't take on patients that you shouldn't.

Listen to the whole episode for more tips on creating a healthy work culture and a reminder of what you should be doing before administering nitrous!

Resources & People Mentioned

• The National Emphasis Program
• Risk Management and Record Keeping Course (w/Laura Diamond)
• X-Ray Dental Compliance Episode

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

If you fail to follow the infection control protocols that you KNOW will prevent the transmission of disease, you'll find yourself dealing with an infection control breach. In this episode of Talking with the Toothcop, India Chance, Michelle Strange, Andrea, and I wrap up our conversation on infection control breaches. We talk about posting on social media, the CDC's steps to evaluate an infection control breach, and things you can easily implement to prevent infections in your dental office. Don't miss it!

Outline of This Episode

• [0:35] Don't advertise your mistakes on social media
• [8:51] The CDC's 6 steps to evaluate an infection control breach
• [14:45] Your duty to report extends beyond saving your reputation
• [17:35] Get a fresh perspective on your infection control practices
• [25:16] Why you should implement video cameras in the dental office

Do NOT do this on Social Media

Michelle has seen dental professionals advertising their mistakes flippantly on social media. One person said they were reusing single-use items and just throwing them in their autoclave. This same person also wasn't wearing and using utility gloves when necessary. But when something happens in that person's office and they have a breach, anyone can look on social media and demonstrate a history of non-compliance. Why are they advertising their infection control breaches? Nothing is stopping someone from taking a screenshot and taking that to the state dental board.

India has never had a dental board inspection based on a post on social media. However, class action lawsuits immediately scour social media for breaches that could be used in their case. Anyone suing a dentist will look at social media and they'll tie-in infection control breaches to whatever the complaint is.

The CDC's 6 steps to evaluate an infection control breach

India recently saw a practice post a video on their YouTube channel (and Facebook). It was a training video with multiple practitioners learning how to do procedures. There were probably 15 people in the different operatories. The problem? There was an egregious amount of infection control breaches in the training. She was so shocked they posted it online.

The CDC outlines six steps to take when an infection control breach happens:

1. Identify the infection control breach: In the video India mentioned, they weren't using sterile water, only half of the people were wearing masks, and they reused single-use items in surgery.
2. Gather additional data: What was the timeframe of the breach? Which patients did it impact?
3. Notify key stakeholders: Notify infection control professionals, risk management, health departments, healthcare providers, etc.
4. Perform a qualitative assessment: Categorize your errors and identify risks.
5. Make decisions about patient notification and testing: What patients were impacted? What is the risk of transmission? Do you have a duty to warn patients and the public?
6. Figure out communication and logistical issues: How and when will you notify the affected patients? Inform them if they'll need testing done. Have a plan in place to answer media inquiries.

What will you implement to prevent these breaches from happening again? You have to show that you've done your due diligence. If you don't hire an infection control specialist, the CDC has checklists and even has an app. Do something to get ahead of infection control breaches and protect your staff and customers—and reputation.

Get a fresh perspective on your infection control practices

Sometimes, infection control coordinators are too close to the issues at hand. You may have no idea that you're a few degrees away from where you should be. But a fresh set of eyes can give you a completely different perspective. You don't have to hire one of us. But, you could work with another practice to trade a staff member or OSHA safety coordinator to do inspections.

India recommends that you get an admin without clinical experience to take the infection control checklist and do an inspection. They'll follow whatever is written down word-for-word. They don't have a bias because they're going off that checklist—not experience.

We all agree that a professional can complete the most accurate assessment. They can help you shift and pivot in the right direction. But no matter what, you need buy-in from the doctors and all other employees. How can you foster that buy-in? What can you do to give your staff consistent reminders? Listen to hear our thoughts!

Implement video cameras in your dental office

What about putting a video camera in the dental office? When I was a cop, having a body cam saved me many times. Quality control is so important—and the camera doesn't lie. A video that you can watch can help you understand context when something doesn't seem right. It's why I recommend dental practices put video cameras in operatories and sterilization areas. This can give you an added layer of quality control accountability. It can show you where you're weak and where things need to be addressed.

All of the major sports teams film the entire game. They watch it, look for areas to address, and learn and improve. Hospitals and doctor offices use these "extreme" measures. Having oversight won't hurt you—it will help you. Listen to this episode for our entire conversation around handling infection control breaches and learning what you can do better.

Resources & People Mentioned

• Level Up Infection Prevention
• Evaluating an infection control breach

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

What qualifies as an infection control breach? What is the easiest way to prevent them? In this episode of Talking with the Toothchop, India Chance and Michelle Strange return for a conversation about infection control breaches. We talk about what they are, why we can't ignore them, and how we can do our part to prevent them.

Outline of This Episode

• [7:05] What is an infection control breach?
• [13:11] Have written protocols in place
• [15:56] The most common infection control breach
• [21:30] Why training + preparation is important

What is an infection control breach?

A breach in infection control is when there is a lapse—a failure to break the chain of infection—that impacts patients and employees. You have to recognize that there was a failure and notify those who were affected.

In 2013, the dental board in Oklahoma exposed Dr. W. Scott Harrington for unsafe practices in his dental office. One of his patients contracted HIV from his unhygienic practices and up to 7,000 others were exposed to hepatitis B, hepatitis C, and HIV.

It's not always egregious or newsworthy breaches. It can be a corner that got cut. It can be something that got dropped on the ground. These protocols aren't just in place to protect patients, they're in place to protect staff as well. The bottom line is that the medical field doesn't mess around with infection control breaches—neither should dentistry.

Have written protocols in place

All of us run into difficult conversations with staff about personal hygiene—even something that seems as silly as wearing nail polish and fake nails. It's uncomfortable. Plus, research has been done on how nail beds with chipped polish and artificial nails are perfect reservoirs for bacterial loads. It's why India and Michelle encourage dental practices to have written protocols in place for personal hygiene. It's less of a headache when you have a policy and it isn't just "anything goes."

Common infection control breaches

I think the most common infection control breach I see is with sterile processing. Michelle got a call from a dental office with a big sterilization breach that had to do with a malfunctioning sterilizer. They weren't doing the necessary prevention protocols.

India sees a lot of little small breaches like someone cutting corners or simply weren't sure they were doing things correctly (and they weren't…). But she agrees that the large breaches where patients must be notified seem to be with sterilization.

Michelle sees a lot of needlestick injuries. Michelle once witnessed a hygienist get punctured by a tip and was bleeding. Her reaction was "Oh I'll just wash my hands" and didn't get a medical follow-up. Luckily, she wasn't working with a patient. Her exposure could've been far worse, especially because a lot of dental practices don't take adequate medical histories.

Many dental offices don't use the health history section of their digital charting much—if at all. If you do have one of those injuries, you need to have a grab-and-go kit in place. You just grab it and head to get medical attention.

At LevelUp, they're training infection control coordinators to do that across the board. Regardless of the injury or hazard, they have a grab-and-go packet for medical attention. No one wants to have to dig to reference infection control protocols—have it ready.

Why training + preparation is important

When I do OSHA and infection control training, I talk about what an occupational exposure is as well as what steps to take after exposure. But I don't want you to have to remember the protocol. The sad truth is that if you know what to do, you've dealt with it too many times. You need to do a root cause analysis and find out why it keeps happening. Is it a systemic failure? Was someone just not paying attention? Was someone not wearing PPE?

More training needs to happen upfront before you even touch a patient so dental staff aren't questioning what to do if something happens. We need to do our part to train our staff with the correct protocols, infection control programs, standard operating procedures, etc. We need to have written policies, and reinforce a culture of compliance.

Dental practice owners need to understand the cost analysis with infection control breaches. Occupational hazards are so expensive to deal with. They don't know how much more it's costing them. Safety is good for business. Prevention is less expensive. It will save you time and money. We must shift the perspective in infection control breaches from the standpoint of reacting to one of prevention.

Tune in next week for the rest of our conversation about infection prevention!

Resources & People Mentioned

• Level Up Infection Prevention
• Evaluating an infection control breach
• Story on Tulsa Dentist

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

Why is the role of an infection control coordinator so important? How do you simplify safety so any dental office can appoint an infection control coordinator and properly train them? In this episode of Talking with the Toothcop, Michelle Strange and India Chance join Andrea and I to talk about the importance of having an infection control coordinator in your dental practice.

Outline of This Episode

• [2:17] The importance of an infection prevention coordinator
• [6:27] Who should fill the role of ICC?
• [11:41] Teamwork makes the dream work
• [21:00] How to communicate effectively with your team
• [29:21] Do you need an infection control coordinator?

Simplifying the role of an infection control coordinator

Let's face it—the role of an infection control coordinator can be overwhelming. Infection control and OSHA guidelines, rules, and regulations have a lot of nuances. When people are overwhelmed, they tend to do nothing. So India and Michelle created the Level Up Infection Control podcast + company to create a community of support and simplify the role of an infection control coordinator. They share step-by-step how-tos and useful information and take you as the listener on a journey as if they were training you in-person.

Who should fill the role of ICC?

India and Michelle note there are a few things to consider, namely—who is interested? Do they have time to give outside of their clinical hours? Who wants to do it? A clinical background is important, but you can't assign this role flippantly. They need great communication + problem-solving skills and can hold others accountable. You have to know your team members.

What if you don't have someone that wants to take on the role? At this point, India points out that it makes sense to pick a clinical team member. A lot of the protocols and systems deal with the clinical side. You need experience with that to successfully implement those protocols and mandates.

The infection control coordinator role itself and what you have to manage can be extensive at times. The key to infection prevention is that it must be implemented daily. You can't let things build up and only review once every three months. Patients are looking at dental practices. OSHA is following infection control and prevention closely. Regardless of who you choose, they need proper training.

Teamwork makes the dream work

Getting things done comes down to delegation. If you're the infection control coordinator, you don't have to implement the whole program yourself—you can delegate. But the bottom line is that you chose to go into healthcare. You have to find the time.

Michelle and India concede that it is a lot of time on the front end as you create processes, systems, and standard operating procedures. But as you start to become unconsciously competent you start to just "do it." Creating a team approach where everyone knows their roles, will save you time.

Developing unconscious competence

How do you develop unconscious competence? How do you foster a team approach to infection prevention? Michelle shares that she once strolled into a room after a patient and threw the instruments that were used in the ultrasonic. But she got distracted and forgot to turn it on and run it. A new assistant pointed out that she forgot to turn it on. If she hadn't said something, Michelle would've created a breach in infection control.

You have to have a team that notices and comes alongside to help you if something is missed. You have to keep each other accountable to keep your patients safe. The moral of the story is that you have to have an infection control coordinator role, but it is a team effort to implement an infection control program. If you're committed to a team approach, each person helps to carry the load.

India emphasizes that infection control isn't just about protecting the patient—it protects you as the clinician as well. This role protects every single stakeholder in a dental practice. It's not your job to be the sheriff. But you must deliver the information in a way that is supportive, encouraging, and promotes change.

So how do you tactfully but firmly let someone know it's time to make a change? How do you communicate with people that don't like change? How do you motivate them to be changemakers? Keep listening to hear India and Michelle share their thoughts.

Resources & People Mentioned

• Level Up Infection Prevention
• Level Up Infection Prevention (podcast)
• A Tale of Two Hygienists (podcast)
• OSAP Infection Control Coordinator Role

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

Dr. Lisa Kane is to New England what I am to Texas. She is THE compliance guru. She practiced dentistry for 20 years before switching to consulting. After years of dealing with migraines from leaning over patients, she made the move—which she's done for the last four years. She's always loved the business side of dentistry and it was the perfect fit.

Outline of This Episode

• [0:21] Dr. Lisa Kane joins the Toothcop
• [3:50] Compliance, education, PHI, & civil rights
• [7:58] What people misunderstand about consultants
• [9:44] What Dr. Lisa Kane offers with consulting
• [12:43] Are peers receptive to her feedback?

Compliance, education, PHI, & civil rights

Dr. Kane spends her time opening people's eyes to regulations they need to follow. Before the COVID pandemic, no one took infection control and OSHA guidelines seriously. In Massachusetts, whatever the CDC says you must follow. In Texas, the state board requires the use of N95 respirators. It's been hard educating people on the science behind these regulations and that it is actually for their health.

At the same time, there's an intersection between protecting one's health and protecting their civil rights. I worked with a hygienist who is hearing impaired and reads lips. When a patient is wearing a mask, she can't communicate. Where is the line between protecting oneself and overcoming civil rights issues? Where is the intersection between conflicting regulations? Sometimes, there's no good answer.

What people misunderstand about consultants

People don't always understand that Dr. Kane is there to help. She doesn't go into a dental office and bark orders like a drill sergeant. She's sure to point out that the process is a conversation. She is sharing the regulations and what you need to do and it's up to the dentist to make decisions for their office. She's giving them protocols and walking them through the things that are daunting.

If someone comes into your office, you have to keep them safe. You don't want to say "I didn't have time" when faced with consequences for not keeping a patient safe.

What Dr. Lisa Kane does

Dr. Kane typically starts by running an infection control or OSHA class for a practice. Then she walks through the dental office and recommends board regulations (OSHA and CDC) to implement. She does a lot of explaining with staff (i.e. why they need to wear gloves) and helps them brainstorm how to do things safely.

She can also help implement monthly protocols, run safety meetings, keep OSHA handbooks up-to-date, and more. She does a lot of fit testing for masks as well. She has partners that offer CPR and HIPAA training.

Are peers receptive to her feedback? Dr. Kane can say that she has been in their shoes and knows what it's like to have to juggle this stuff. Whereas I was a cop, and was the enforcer of rules. Dr. Kane finds that people are appreciative of her experience and that she can form a connection with practice owners. They know that she knows what she's talking about.

Want to learn more about Dr. Lisa Kane and what she offers? She just launched a newsletter that will highlight protocols and why you need them. Check it out! And be sure to sign up for our email list to stay up to date on the latest regulations.

Resources & People Mentioned

• Connect with Dr. Kane on LinkedIn
• Dental Office Compliance of New England
• Sign up for Dr. Kane's Newsletter

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube

We like to provide clients all the materials they need to prepare for the next calendar year. We usually try to get it to them before Christmas, so it's a sort of Christmas present. One of the things we include in this packet is a blank master chemical list. We've been getting a lot of questions about this list, as well as establishing a code of conduct. Listen to this episode to learn about both of them!

Outline of This Episode

• [0:40] A compliance Christmas present
• [5:11] Nail down your code of conduct
• [7:29] Maintain a master chemical list
• [9:37] The lowdown on safety data sheets
• [11:10] Check out our live training!

Nail down your code of conduct

If you participate with Medicare, Medicaid, Tricare, or other government programs, you need to have a written compliance plan that includes the seven elements of compliance. It's a supplemental document to your office policies and procedures (employee handbook, SOPs, OSHA policies, HIPAA policies, compliance policies, billing protocols, etc.).

It's impossible to have written procedures for every scenario that may occur in the dental practice. So this supplement establishes a decision-making framework for your staff in the absence of a policy or procedure. They are principles to follow to reason through any situation. In short, it's a behavioral guidance tool.

To remain compliant, this code of conduct needs to be reviewed by your staff at least annually. It should be part of the new-hire process and repeated with everyone in the practice—doctors, clinical staff, and administrative staff. You have to read it, discuss it, and sign off on it.

Whether a signed form goes in each employee record or a compliance manual, you just need to be consistent. You have to be able to prove that you have a reasonably effective compliance program in place.

How to maintain a master chemical list

Another thing we include in the update packet we send is a blank master chemical list. Why? Because you need to know what chemicals are being used in your practice. They need to be accessible in the event of a power failure. If you prefer to keep things online, make sure you can access it on your cellphone or have it transferred to a thumb drive for easy access. If you can meet that threshold, you should be good. You can delegate this to a staff member or OSHA coordinator, as long as someone knows where it is.

Safety data sheets

We've been getting questions about where to store safety data sheets. Does it have to be printed? Can it be online? The short answer is that it can be online, but needs to be maintained in the office as well. It should be a table of contents for your practice.

In 2012, we migrated to a DHS system in which they had standardized the format for safety data sheets. Before this, they had been known as material safety data sheets (MSDS). The formatting is now consistent. If you have printed MSDS sheets, it's time to upgrade them to the proper format.

Resources & People Mentioned

• LIVE Compliance Training

Connect With Duane

• https://www.dentalcompliance.com/
• toothcop(at)dentalcompliance.com
• On Facebook
• On Twitter
• On LinkedIn
• On Youtube