Re: "Appropriate" physical safeguards

[Aleta Ambler]

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--- When you think about locks, think about fire codes even before you think about HIPAA.

fwdanby wrote:

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In the last three offices I designed, I specified NO LOCKS on all exam room
doors.
Reason? To counter any suggestion that sexual harassment might have been
possible.
My staff moves freely, with a discreet knock, in and out of these areas, and
patients who might attempt a spurious harassment suit know this.
FWDanby MD

----- Original Message -----
From: "Noel Chang" <[EMAIL PROTECTED]>
To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]>
Sent: Thursday, October 17, 2002 11:40 AM
Subject: "Appropriate" physical safeguards


  

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I would be interested in hearing from people who deal with solo
    

practitioners
  

or small group practices, what are some of the issues you are having to
address in the doctor's office to ensure that "appropriate" physical
safeguards are provided (section 164.530(c)).  Let's ignore the
administrative and technical safeguards for now.

For example:

At the check in window, is a sliding, frosted glass, window always
necessary?  As long as computer terminals are not visible, nor any other
    

PHI,
  

I say no.

Are lockable doors necessary at every point that you do not intend
    

non-office
  

personnel to access?  Many offices I have seen have a door that separate
    

the
  

waiting room from the rest of the office.  Once you are in the exam area,
however, you can move freely (without any keys or combinations) from the
    

exam
  

room to the insurance desk, to medical records area, to the referrals
    

area,
  

etc.  I would say it is pretty obvious that these areas are not intended
    

for
  

patients to access but what is appropriate?  Do I have to have locking
    

doors
  

to separate these areas from the exam rooms?  Can I just post signs that
notify patients that an area is restricted and they are not supposed to
enter?  This is a gray area to me and without seeing the work area being
considered I would argue it is impossible to make blanket statements about
what is appropriate.  Do people agree or do they feel there are some hard
    

and
  

fast rules concerning how the physical work space should be layed out?

Noel Chang

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The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.