Joy Mast: How do HIPAA regulations affect Dropbox usage?
Julie Irwin: That's a great question. It seems that there is a lot of room for interpretation. The basics for compliance are encryption, localized storage and a plan for retrieval should there be a system crash. It's best to check with your IT administrator and have a look at the department of health and human services for the most up-to-date information.
Jenny Kortuem: When you say Evernote is not encrypted, what does that mean?
Irwin: [Encrypted] means that the site converts that data into a code that is not able to be easily read. It "scrambles" sensitive information and only the person receiving or accessing the information has the "key" to unlock or decrypt it.
Janice Giampa: Do we need patient or client consent to use the cloud, etc.?
Irwin: Could you clarify that question please? Do you mean sharing things like AAC vocabulary files?
Giampa: Some people may not be comfortable with their records being communicated in that method. Should we be asking our clients if they are comfortable with that format? Do we have liability if there is a breach and they have not consented to our using these new technologies?
Irwin: Absolutely. That goes back to HIPAA compliance. It definitely needs to be discussed with clients.
Phyllis Watson: I talk with each family individually and ask if they would like a copy of the notes sent via e-mail to them. Almost 100 percent say yes. Prior to sending the document, names are removed and replaced with a code. The family is then able to decide if they want to put any private, identifying information back into the note.
Susan Mary Newton: Are there any good apps for writing treatment notes and maintaining documents?
Irwin: It goes back to encryption and keeping your data protected.
Watson: I use Pages while I'm at an appointment to write notes. Then when I'm back in my office, I print them out for the hardcopy chart. However, there are many apps to do that same feature.
Irwin: Docs Unlimited is another one. It has Word and Excel in it. It's also handy for tracking mileage using the Excel document.
Sharon Clines-Meier: What is an AAC vocabulary file?
Irwin: It's specifically related to a client using an augmentative communication device, and being able to transfer that file privately or publicly.
Beth Dua: Do you find that insurance companies are allowing signatures to be considered valid coming from SignNow or DocuSign Ink?
Irwin: Yes, many offices are using electronic signatures. Think about the Free Application for Federal Student Aid and filing your taxes. Electronic signatures are accepted there.
Dawn Wilson: Getting back to the [subject of] sending notes to parents ... Do you have parents e-mailing you questions about your notes after the session? I notice that I am spending more and more time—outside of my billable therapy sessions—answering e-mail questions from parents. Do you charge for this?
Irwin: That's an excellent question.
Watson: I do my notes at the end of the session and have the parent review them. I ask if they have any questions, so that questions are answered within the billable session. Then I'm able to send when I'm in a wi-fi zone when it goes out to the parent. Answering questions at the end of the session curtails questions via e-mail.
Wilson: So, if you do a 45-minute session, you stop to [write] notes during the session—after 30 minutes or so? Parents are OK with this? I'd think that if they say, "No questions, or if you can answer a question in 1–2 minutes," the parents think they are being cheated out of therapy time. I am private-pay only and parents really watch the minutes to make sure their children get a full 45 of "therapy time." This might be outside the realm of this chat, but I've run into this before.
Irwin: I would guess that you are taking notes throughout the session. Then in the last 5 minutes of the session, you discuss your plan. What can the parents do for "homework" with their child, step-by-step instructions on what to do. It doesn't need to take a lot of time. It really is a matter of making sure that you, as a clinician, and the parents are on the same page with the treatment plan and follow-up at home.
Susan Schlais: Can a person "charge" for any questions outside of the therapy time? I notice there is a difference in the whole interaction when I include the question-asking in the session versus giving the opportunity to e-mail me. (E-mail tends to be all on my own time.) If the parents know they can ask questions and come with their questions—and I may state that I can send them a link or want to answer them via e-mail—that is completely different. But questions need to be written out and brought to the therapy session. Is that ethical? Still satisfactory to the parents and clients?
Irwin: Typically, no, you are not able to charge for time spent outside of direct treatment. [As to] your second part of the question, we think it makes a lot of sense that the parent comes [to therapy sessions] with written questions. I've found that the format treatment, summary, plan, questions, works well once the "rhythm" is established. The focus is the client and what will best meet his or her needs. Sometimes you may find that an occasional e-mail response is necessary, but I think you want to be careful to guard your personal time as well.
Schlais: To clarify, yes—I meant no charges for e-mail but coming with the questions should be encouraged instead. If I answer it in the session with the child, it can be billed [as] session time, but if I answer it via e-mail—and I choose to answer, with links, via e-mail—then it is on my own time ... right?
Irwin: Yes, you are correct, Susan. Time spent answering caregiver questions with the client present is billable time.
Megan Murphy: What do you feel are the main differences between SignNow and SignEasy?
Irwin: I find that it's really about personal preference. SignEasy lets you use PDF, Office and open office documents. You can have multiple signatures and signers with date and initials. SignEasy integrates nicely with cloud storage. It also nicely lists your signatures and documents in the menu.
Mast: Is it sufficient to use numbers for patient names and not do a formal "encryption" with software? If I were using Dropbox, for example.
Irwin: Yes. You're just avoiding any identifying information. It's important to follow the HIPAA guidelines. Think about your own personal medical record number at your physician office.
Barbara Samfield: Do any of the apps for doing notes and reports meet the definition of electronic medical records that will become mandatory through the new health care law as I understand it?
Irwin: A fabulous question. As we move toward the new health care law, I imagine that will be a feature listed in the description of the app. For example, if you look at the description of CX [a cloud service app for Android phones], the literature describes it as HIPAA-compliant. I know we keep going back to this, but check with your IT administrator about this. The issue is with the transmission of the data, so data on your machine needs encrypting before being transmitted.