Operational risks such as patient and worker safety, quality of care, patient privacy, security, and dozens of regulatory domains impact all medical practices. However, each medical specialty deals with unique operational risks that are especially important based on their typical service offering and medical office environment.
Our team has conducted operational risk assessment in more than 200 on-site consultations with dermatology practices. We have uncovered specific risk areas that can easily be missed in dermatology practice if you don’t know what to look for.
Some top operational risks for dermatology practices include:
- Surgical Instruments and Sharps
- Laser Safety
- Dermatopathology and Mohs Laboratory Operations
- Regulatory Compliance for Physician Assistants and Nurse Practitioners
1. Surgical Instruments and Sharps
Dermatology practices use autoclaves and ultrasonic cleaners to sterilize surgical instruments. These surgical instruments are considered critical items that confer a high risk for infection if they are contaminated with any microorganism.
A clear policy outlining how instruments will be sterilized, packaged, labeled, and stored — along with a verifiable record of testing and maintaining sterilizing equipment — is the foundation of managing infection control related to surgical instruments.
In addition, the instrument sterilization process involves the handling of sharps, which are subject to the OSHA Bloodborne Pathogen Standard. OSHA requires a detailed and specific exposure control plan. To meet the OSHA standard, it’s important that a dermatology practice’s plan includes information about every step of the process, even describing how instruments are transported to the decontamination area.
Omitting these details is one of the biggest risk areas we uncover in our consultations, and an incomplete exposure control plan is one of the most commonly cited OSHA violations.
2. Laser Safety
Risk management for dermatology practice operations extends beyond clinical expertise, especially when it comes to lasers. OSHA refers to the ANSI Z136.1 Laser Safety Standards when evaluating laser safety incidents, requiring a written plan and standard operating procedure for each laser.
State regulations vary, with special requirements for laser registration, operator licensing, and incident reporting. This creates a web of regulatory obligations that can be overwhelming.
Even if your laser safety protocols are perfect, documentation gaps could expose your dermatology practice to OSHA fines and penalties in the event of a patient or worker safety incident.
Our team has structured laser safety programs in use at hundreds of dermatology practices across more than 20 states, and we’ve conducted follow-up on-site operational reviews at dozens of dermatology sites to independently monitor implementation.
3. Dermatopathology and Mohs Laboratory Operations
Risk management is particularly challenging when it comes to lab operations. While CLIA inspects laboratories regularly, the worker safety requirements are not completely addressed in these inspections.
Keeping lab safety manuals current and accessible is crucial to ensure compliance with the OSHA Laboratory Standard and inspection readiness. Our team has developed laboratory safety programs for dozens of dermatopathology and Mohs laboratories, and we understand the nuances of compliance with specific regulations.
One of the biggest operational risks to any practice is the challenge of keeping up with complex and overlapping regulatory requirements. We have assisted clients in assessing worker safety risks and compliance with the OSHA Laboratory standard as well as addressing adverse CLIA inspection results, working directly with laboratory staff to address deficiencies.
4. Regulatory Compliance for Physician Assistants and Nurse Practitioners
Many dermatology practices employ physician assistants and nurse practitioners. In recent years, dermatology groups have expanded the employment of these advanced practice providers, often in underserved communities. While “incident to” billing springs to mind when thinking about the risks related to employed advanced practice providers, there is additional risk related to overall supervision and compliance with state regulations.
Each state governs the scope of practice, licensure, and physician supervision requirements for nurse practitioners and physician assistants. These regulations are updated frequently. Failure to demonstrably comply with state regulations can result in filing claims to federal programs that are invalidated if state requirements are not met, as well as questions about quality of care.
Something as simple as the failure to sign off on medical records as required by the state or neglecting to update a supervision agreement on the correct schedule can create significant exposure for dermatology practices. Our team has worked with hundreds of dermatology practices to analyze gaps in regulatory compliance, draft supervision agreements and keep track of state regulatory updates.
Choose Compass for Your Dermatology Practice
At Compass Healthcare Consulting, we leverage our extensive operational experience in the healthcare industry to offer expert dermatology risk assessment services and operational support for addressing any residual risk identified in the assessment process. Our comprehensive risk assessments cover crucial areas including the areas discussed in this article as well as all of the OSHA standards applicable to medical practices, operational HIPAA privacy and security compliance, and much more.
Compass provides tailored solutions to identify and mitigate risks specific to dermatology operational risk. Our methodical approach to analyzing each operational risk domain, combined with real-world experience, drives practical and actionable recommendations to reduce the likelihood of adverse events and the related fines and penalties that can occur in the event of a patient or worker safety incident.
Dermatology risk management encompasses crucial areas such as infection control, inventory management, laser safety, lab operations, and staff training. They ensure patient safety, regulatory compliance, and efficient operations. Compass Healthcare Consulting offers expert services to address these challenges, providing tailored solutions for dermatology practices.
