Dealing with Paper in a Paperless Workflow for HIPAA Compliance
Picture the scene--you come home from a long day at work. You put your scale in its corner, and set your bag down on a side table. Hang up your coat, and take your iPad out to do some final charting or billing before calling it a wrap. You sigh with relief, because it won't take long. You're paperless after all.
And then you look down on the table, and you see it--
There's paper in that envelope! Paper you are going to have to deal with! Paper that threatens the very foundation of your paperless freedom! You decide to take it out back and burn it in your firepit because it has no place in your life.
OK don't burn it. You do have to deal with it, but you can deal with it quickly in three short steps. You can perform these steps each time paper comes in (recommended), or have a regularly scheduled paper party. If you choose that option, in the interim you will need to keep that paper correspondence secured (as in, don't open the envelope) or locked to preserve client confidentiality.
Open the envelope and see what kind of paper you are dealing with. Maybe it is just a flyer from GOLD advertising their latest conference, in which case you should sign up immediately because GOLD is the best.*
It might be a letter from a pediatrician, or an invoice from your biller, or correspondence from a client's insurance company asking you to jump through yet another hoop before they will reimbursement. All of these pieces of paper contain Protected Health Information (PHI) and must be dealt with.
Some of the senders may allow you to opt in to paperless communications. For example, I am in-network with Aetna and have it set up so that I only get electronic EOBs. I have configured my bank accounts so that I get paperless statements (those may contain PHI if you accept checks).
If another provider routinely sends you paper reports after seeing one of your clients, consider asking them if they would consider going paperless. They are likely creating those reports on a computer, and could easily create PDFs. Many of the HIPAA-compliant file storage systems will let you have shared folders, or you may feel comfortable with emailing. The Spruce secure messaging app allows you to create a team with other health care providers and share messages and PDFs over a secure, HIPAA-compliant network.
To get this paper into your EHR platform or cloud-based storage system, you'll need to scan it. Check out my book for more information on all the options available to you, and instructions on how to use each one.
If you have a laptop or desktop computer, the fastest and easiest way to scan documents is with an actual scanner. I have this little guy and it has lasted me for about 4 years now. There are other less expensive options that seem to have good ratings, too. I like the portable scanner because I can stick it in a drawer when I'm done. Of course, you could also get an all-in-one printer/scanner/copier which will add speed to your workflow because they can handle multiple sheets at once.
If you have a smartphone, you can scan documents using your phone's camera. Scanning goes beyond simply taking a picture because scanning apps will recognize text, create a PDF, and can send your document to file storage. Your phone will take a picture, which may be significantly larger than a PDF, and you'll have to manually move it to file storage.
You will want to make sure that any app you use is connected directly with your own HIPAA-compliant storage solution, and not transmitting anything you scan over their own network (unless they give you a BAA). PC Magazine has a helpful roundup: 10 Best Mobile Scanning Apps.
Once you've scanned your document, shred it immediately. Don't start a "to shred" pile unless you plan to keep that pile in a locked cabinet. Do it now, get it out of your life. Having a shredder that can handle multiple sheets at a time is super helpful in terms of saving time.
Et voila! A lovely pile of paper shreds suitable for redecorating any hamster's abode, or for feeding the recycling beast. Edited to add: check before using your shreds for a pet, as the ink may be toxic.
*I have no relationship with GOLD other than as a happy customer of their outstanding continuing ed.
About the Author
Annie Frisbie, MA, IBCLC is the creator of the IBCLC Private Practice Essential Toolkit, a collection of books, resources, legal forms, training manuals, and workbooks aimed at helping private practice lactation consultants build a private practice that’s ethical, profitable, sustainable, and enjoyable.