Be Prepared for Unexpected Visitors

State Boards of Medicine and Dentistry can conduct impromptu visits of medical and dental practices and these surprise visits seem to be on the rise.  There appears to be an increased  focus on practices specializing in surgery, dermatology, podiatry and dentistry. Would you know your rights if inspectors came to your office? How do you protect your practice and your staff?

First, call your attorney without delay to get advice. If you do not have someone on retainer, you can contact us at AssuranceMD and we will provide a qualified professional to promptly assist you. Your practice will need someone to referee the inspection to ensure that proper records are examined and none of your staff is improperly interviewed. Statements made will be “on the record” and can be used later to the detriment of the practice. A proper referee can guide you through the process and ensure that all questions asked are within the permissible scope of an inspection. Should the inspectors have a search warrant, you must allow access to your facility – but contact an attorney right away.

It may be a good idea to hold a “mock” State Board Inspection where an independent professional examines the practice’s physical facility and all records to ensure compliance. At the very least have your office staff conduct a periodic compliance check. The inspection should review vast array of items that Medicare, DEA, OSHA, State Boards and criminal authorities look for when conducting a review:

 

  • Expired medications, samples, creams, lotions, test tubes, OTC medications
  • Unmarked multi-dose vials
  • Non-compliant sharps containers and sharps disposal measures
  • Sharp items in drawers readily accessible to patients / patients’ reach
  • Improper location of sharps containers
  • HIPAA violations
  • OSHA violations
  • Stark Law & Anti Kickback (State & Federal) violations
  • Lack of employment policy & procedure manuals
  • Improper waste disposal
  • Medical or biomedical items intermingled with foods
  • Lack of equipment maintenance logs
  • Poor sterilization measures
  • X-ray machine violations and protocols
  • Unmarked alcohol / hydrogen peroxide / betadine dispensers or expired bottles of same
  • Visible patient sign-in sheets (i.e., they should not be visible)
  • Uncleanliness and Clutter
  • Compliant leases and subleases
  • Business hours not posted