Admin and compliance are among the two most feared words for most practice owners. Even just the thought of getting your policies down on paper and distributed to your staff and your clients is enough to make you want to turn around and get back into bed.
Sound familiar? You’re not alone.
In an ideal world, this post would only be relevant to new practice owners but the reality is that there are so many practices, many of them well-established, that don’t quite have their paperwork in order.
Chatting to a private practice owner just the other day, he remarked that getting their policies nailed down has been on their to-do list for over ten years. This is a successful practice with some of the highest levels of client satisfaction around yet they can’t seem to get to this one area.
It’s completely understandable when you think about it. Running a practice is hard work, and writing policies doesn’t feel like it adds much value when there are so many other urgent tasks to get through.
There are hundreds of different forms to manage and various compliance requirements to compound the confusion which is why we’ve gone ahead and done the research to come up with 14 policies every private practice should have.
It might seem like a long list, but if you could tick off just one or two a week, it won’t be long before your policies are in place. These policies form the groundwork for the relationships that you build with your clients and employees. And they also make the hard work of putting them into practice that little bit easier.
So, let’s dive right in. First up, we have the most important policies for clients. Afterwards, we’ll dig into the policies that you need for your staff and your business.
Important Policies for Clients
1. Privacy Policy
This policy should be kept on file and made available for anyone who requests it. It should also be updated on your website.
HIPAA Notice of Privacy Policy
In the US, you will need a HIPAA Notice of Privacy. This verifies that your clients’ private health information is protected in compliance with the Health Insurance Portability and Accountability Act. The policy covers how their private health information may be used or shared and communicates to the client that you will not share their information without approval. This can be sent through to the client with other digital intake forms via Power Diary.
EU GDPR Compliance
For practices in the EU, the personal data and privacy of clients are protected under the GDPR (General Data Protection Regulation). You will need an EU-GDPR policy for your practice that can be shared with clients stating your compliance with the regulations and explaining how you store and use their data. You will also need to get consent from the client before you collect their data.
UK GDPR Compliance
The UK-GDPR is essentially the same as the European GDPR but has been adapted to accommodate differences in domestic UK law. The onus on private practices in the UK remains the same, and you will need to create a GDPR policy that should be communicated to, and acknowledged by, your clients.
Australian Privacy Act
Australian businesses have actually been in compliance with GDPR since 1998 when a similar law (the Australia Privacy Act) was enacted to protect the privacy and identity of citizens.
2. Information Release Authorisation Form
If you work alongside other healthcare providers for your clients, the Information Release Authorisation Form is vital. It allows you to connect directly with other providers involved in the client’s care. It should list all the providers that you can share private health information with and may include doctors, therapists, parents or guardians, and other healthcare specialists.
3. Patient Payment Policy
Also sometimes called the Statement of Financial Responsibility, this is a short statement that your clients sign before their first appointment holding them responsible for payment of your services. With changing healthcare requirements, many clients have to pay a portion or all of the treatment fees. This makes it essential for you to have a commitment from them in writing. Most practices choose to require payment after the session, and this can be communicated in the policy.
A separate payment policy can be drawn up for your admin staff that covers how they should:
- Collect payments;
- Process claims and insurance information;
- Handle outstanding accounts.
The more detail, the better here as communicating your expectations to clients and staff will ultimately contribute to your bottom line (and significantly reduce your stress levels at the same time).
4. Cancellation Policy
Cancellations and no-shows are often the bane of a private practice. It’s a bit off-putting and may make you feel a bit uncomfortable initially, but it will only benefit your practice in the long run. If you keep in mind that every cancellation affects your bottom line, it is easier to take a harder line on repeat offenders.
It should be simple and to the point with information on:
- The cancellation window (i.e. the time after which a client can no longer cancel – often 24 hours);
- The fees associated with cancelling too late, not arriving for an appointment, or arriving late.
The fees and penalties need to be communicated up-front, preferably in writing. They can be emailed when the appointment is made or printed and signed by the client before the first appointment.
If a cancellation policy doesn’t sit well with you, you can make some modifications, such as extending first offender forgiveness, or waiving the fee if they reschedule their appointment. You can also include wording in the policy that explains to clients how their non-attendance negatively impacts your clinic and why the policy is in place. Appealing to your clients’ better nature can help increase appointment compliance and, if it doesn’t, those are maybe not the type of clients you want to attract anyway.
5. Testimonial Release
A testimonial release will only come into play from time to time, and for many practices, it may not be relevant at all. But, and it’s a big but, if you do get testimonials from clients, it’s helpful to have a testimonial release waiver ready to go. The waiver authorises the release of their testimonial, and you need to get it in writing whether you can use their name, photos or testimonial.
The laws, regulations and professional guidelines relating to the use of reviews and testimonials can vary across jurisdictions, and health professions. If you’re unsure of the rules that apply to you, your professional association is often a good place to start.
6. COVID Policy
This is a new one for most practices. It’s designed to help practices screen patients more effectively before a face-to-face consultation. To get you started, this is a template from the Chartered Society of Physiotherapy (CSP) in the UK.
Policies for Your Staff and Business
7. Employee Conduct
This is a broad area and can be split into several policies. In general, it should include guidelines on alcohol and drug use, smoking, discipline and performance management. This gives employees a clear framework to do their jobs as they know what behaviour is acceptable at work. It should function as a road map for how to work within the company and give an introduction to your culture.
8. Position Descriptions
Where possible, this should be done on a role basis rather than an employee basis so that there is a greater degree of impartiality. The description should include the level of authority the position has to make decisions, the level of responsibility it has, the tasks required and the overarching goals. It should also clarify how performance will be monitored and managed, and employee skills development training associated with specific roles.
9. Personnel Policies
This policy should clearly state the hours of work, employment terms (including hiring and termination), salary (and bonuses), health benefits, insurance, the number of leave days, sick leave and retirement. The document should take your practice’s culture into consideration as some staff may work flexi-time, and you may have a work-from-home policy.
10. Health and Safety
You will need a top-down approach for this, taking into account industry best practices and any relevant legislation. Especially with COVID, staff may be required to use PPE (personal protective equipment).
Your employees’ health and safety are your top priority. The policy needs to cover how to deal with illness or injury at work, safety guidelines, and how to report a concern. You may also choose to draft a separate COVID policy.
11. Social media Policy
You’ve probably noticed the increasing trend of clients reaching out to you online, and social media has become an important marketing tool for health practitioners. With this trend set to stay, it is crucial that you have a documented policy for managing interactions on your social media channels. An internet and social media policy will protect your practice against reputational damage as well as keeping your client interactions professional. A written policy that covers the guidelines and provides the necessary training will also benefit your employees. A good place to start is the Mayo Clinic’s Policy, it’s clear, concise and includes a link to the reasoning for each of the points.
12. Company Property and Internet Use Policy
Stipulate how employees can use the internet at work. This may include limitations on personal internet use and the requirement that all online activity is legal, ethical and appropriate. The documentation should also include what is considered appropriate for posting on social media as it relates to your practice.
Your team need to use company property to do their jobs, whether it’s therapy equipment, electronics, medical tools or a desk and chair. The guidelines should communicate how to care for the property and if personal use is permitted.
13. Harassment and Discrimination Policy
Harassment and discrimination can have a big impact on the culture of your practice. Keep your employees safe and promote a fair environment with a policy that explicitly prohibits:
- bullying;
- sexual harassment;
- verbal harassment;
- physical harassment;
- hiring discrimination;
- workplace discrimination;
- stalking.
The policy should also cover how to report any incidents of harassment or discrimination and how these will be dealt with.
14. Disciplinary Action Policy
This policy outlines what constitutes a violation of company policy, the disciplinary process that will be followed and the consequences for different violations.
Depending on the size of your practice, many of the policies can be combined. For example, the Employee Code of Conduct could cover most of the policies that relate to your staff in one place. However, the most important ones (privacy policy, cancellation policy, patient payment policy, and employee code of conduct) need to be done separately.
You may have looked through the list and found it a little overwhelming, but, to get started, circle back to the top four and focus on getting them done. If you know other practice owners, ask them for a copy of theirs (you may have to barter with chocolate), or consider hiring a business coach to help you get all your documentation in order.
This is by no means an exhaustive list. So, if your practice uses any other ‘must-have’ policies, please let us know in the comments, and we’ll add it to the list!
