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Electronic technologies don’t define business policies

Have you ever reflected on the relationship between your business policies/procedures and your technology choices/usage, such as a practice management system (PMS)?


September 28, 2015
By Jessica Foster


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Have you ever reflected on the relationship between your business policies/procedures and your technology choices/usage

The actual technology deployed can have a huge impact on you and so can the policy and procedures you adopt. We will look at some real and hypothetical frequently asked questions (FAQs) that will help exemplify the scope of interaction between well-chosen, properly used technology, and your internal policies and procedures.

Your written clinic policies are probably broad statements that are the precursor to the actual day-to-day procedures that govern how you deal with internal, legislated and regulatory mandates. Your policies and procedures dictate how your clinic operates covering ethics, patient care, the treatment of co-workers, collection, use and retention of patient records, patient privacy, financial record keeping and other related matters. This applies to self-employed, partnerships and employer/employee relationships alike.

Your online PMS system helps you manage your online appointment booking, patient scheduling, patient billing, treatment and charting, financial record keeping, e-commerce and related work flows. It should not define, enforce or police your internal business policies and procedures.

Let’s look at some examples of how the relationships actually work.

Q. I work with four RMT’s who often cover for each other when sick, on vacation or leave. What happens if a RMT leaves the clinic and takes contact information for all patients and subsequently markets to them?

A. Patient ownership is a matter of policy and there needs to be procedures as well as legal contracts in place that specifically deals with this possible occurrence. Details should be covered within your partnership/employment agreements. As professional health-care providers working together, you need shared access to patient information for the clinic to function properly. Whether patient contact information is in electronic form or on paper in filing cabinets, your written policies and agreements govern their use.

Q. My PMS allows me to bulk e-mail patients and potential clients. Can I just find email lists of people in my area and send them information about my practice, rates and availability?

A. While the technology allows for this, you are still obligated to comply with your profession’s advertising regulations as well as Canada’s anti-spam laws. Your system does not control this. It makes the process very efficient but only you are responsible for ensuring you are in compliance with your policies, regulations and the law.

Q. My system allows me to synchronize patient bookings and associated records with my personal smartphone calendar. Does this make me record-privacy compliant?

A. Not necessarily. If your appointment records are synched to a smartphone calendar application that is hosted by a non-Canadian owned and operated service provider, you will need to ensure you do not identify your patient name and yours on those records. While the technology allows this to be done, your internal policies need to define how you use the feature, if at all.

Q. My PMS online appointment booking system allows me to send electronic appointment reminders. Periodically, a patient tells me they did not receive it (legitimately or not) and therefore do not believe they need to pay for the appointment they missed as per my cancelation policy. What do I do?

A. While the technology may enable automatic email or text reminders (neither of which are guaranteed delivery technologies), it is your written policy that needs to clearly indicate that appointment reminder messages are a courtesy only. Your patients are responsible for their appointment times.

Q.  My system vendor says their online service is hosted in Canada. Does that mean my usage makes me compliant with federal and provincial privacy regulations?

A. No. Many foreign-owned and partially foreign-owned PMS vendors host services in Canada and have neither the obligation nor ability to comply with Canadian legislation. Ask the vendor if they have foreign ownership. Research the company, paying particular attention to their Terms of Use and their Privacy Policy. Can your records be sold or transferred without your or your patients’ express approval? Again, this type of due diligence is dependent on your internal policy and procedures. You are ultimately responsible for the care and safekeeping of your patient records.

Adoption of electronic PMS is now prevalent in RMT clinics. Higher level concerns need to be addressed in your internal policies, such as how specific technologies are used.

The reality is that it is worthwhile maintaining thoughtful analysis and regular reflections on these matters to ensure you, the practitioner, are the one responsibly driving the bus.

Until next time, be well.


Jessica Foster writes on behalf of mindZplay Solutions, provider of massage therapy websites and practice management solutions. To learn more, visit www.massagemanedger.com.


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