Healthcare Management
Chapter 15: Risk Management in Ambulatory Care Settings
Ambulatory Settings
There has been a steady flow of clinical services out of hospital settings into more cost-effective outpatient settings
Risk management is as important in the outpatient setting as it is in the inpatient, especially as outpatient settings are not subject to accreditation
Of all paid malpractice claims, a greater number are coming from the ambulatory setting than from inpatient alone
Why the increased risk?
Ambulatory settings differ from inpatient in that they do not have the same mix of specially trained professionals managing patient care 24 hours a day including detailed documentation, observation, decision support teams
Ambulatory setting provides infrequent care spread over time and patients are generally seen by personnel with a lower level of training performing tasks in multiple areas
Assessment of the Practice Setting
Risk Managers need to assess the risks inherent to the specific site
Management of risk in the ambulatory setting sites on 3 core principles:
A culture of safety
Good employment practices
Ethical business practices
Culture of Safety
It is important to recognize that human errors are inevitable and leads to ways to strengthen the system of care rather than punishment
4 Key Features
Psychological safety
Active leadership
Transparency
Fairness
Good Employment Practices
Under the principle of vicarious liability, the facility owner is legally responsible for the actions of their employees
Potential risks:
Non-physician employee exceeding their legally authorized duties
Inappropriate actions of employees
Fair employment practice issues
Ethical Business Practices
The risk manager must guard the practice against fraud and abuse by ensuring
Appropriate billing practices
Compliance with Stark Law
No inappropriate upcoding of claims
High Risk Areas
Missed diagnoses
Medication risks
Infectious risks
Communication
Documentation
Office Management
Clear and regularly updated policies and procedures will help maintain high standards of patient care and lower the risk of lawsuits
The Policy and Procedure Manual should be available to all employees and follow the mission, vision and values of the practice setting.
Policy Manual Section – Administration
Describes the organization of the practice setting
Hours of operation
Holidays
Emergency contact after hours
HIPAA
Patient Rights (including children)
Patient responsibilities
Missed appointment policy
Patient complaint procedure
Transfer of care to another provider
Consent forms (including treatment of minors)
Advance directives
Clarifies HR issues
Hiring - Application process, forms and reference checks
Verification of credentials and identity
Verification of Immunization and TB testing
Compliance with employment laws
Job descriptions
Various employee policies
Employee grievance policy
Workplace violence policy
Disciplinary procedures
Employee training
Dress code
Policy Manual Section –
Personnel
Policy Manual Section – Records
Describes policies and procedures for patient health records
Mandated logs
Records maintenance
Records storage
Archiving of hardcopy records
Backup of electronic records
Documentation of missed appointments and communication of all test results
Policy Manual Section – Infection Control
Describes policies and procedures to allow personnel to provide safe care and assess infection prevention practices
Hand hygiene
Personnel protective equipment
Injection safety
Respiratory hygiene
Environmental cleaning
Sterilization of equipment
Disinfection of reusable instruments
Policy Manual Section – Risk Management
Describe routine policies needed to cover
Potential fraud
Lapses in confidentiality
Adverse patient outcomes
Lawsuits
Compliance plan and compliance officer as required by the OIG
Policy Manual Section – Quality Management
Describes the practice’s policies and procedures for quality control
Assessment procedures
Improvement plans
Summary
Ambulatory care settings continue to evolve and face many challenges in patient safety and compliance with laws on business practice.
Risk management is essential to meet these challenges.