Talking with the Toothcop

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In this episode of Talking with the Toothcop, Duane Tinker walks you through an actual corporate integrity agreement (CIA) involving a pediatric dental practice. Discover the critical elements of a CIA, including compliance programs, training, claims review, and overpayment reporting. This is crucial information to learn how to navigate CIAs and protect your dental practice. Don't miss this essential episode in our CIA series!

Resources mentioned in this episode:

• Closed Corporate Integrity Agreements • CMS Medicare Learning Network

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*** Disclaimer: Duane Tinker is not an attorney and does not offer binding legal advice concerning regulatory compliance. The information in this podcast should not be relied upon or construed as legal advice in any way. Consult your attorney for legal advice concerning compliance matters as they pertain to your dental practice.

This episode was edited and produced by http://parkerkane.co/

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In this episode of Talking with the Toothcop, we dive deeper into corporate integrity agreements (CIAs) and discuss the OIG’s Focus on Compliance roundtable. If you participate with Medicare or Medicaid, this is crucial information.

Learn the importance of a code of conduct, board involvement, and internal audits. Discover how to maintain a low error rate in claims reviews and ensure compliance with federal regulations. Need help with compliance? Contact me!

Resources mentioned in this episode: • Focus on Compliance • HHS Compliance Resources • LIVE Compliance Training • Important Episode: The 7 Elements of Dental Compliance Programs Thanks for listenting to Talking with the Toothcop! Don't forget to follow and turn on notifications for future episodes.

This episode was edited and produced by http://parkerkane.co/

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In this episode of Talking with the Toothcop, we kick off a series on corporate integrity agreements (CIAs) and the importance of compliance programs. Learn what exactly a CIA entails, why you need a compliance program, and how it can protect your practice.

Resources mentioned in this episode: • LIVE Compliance Training • Compliance Guidance for Individual and Small Group Physician Practices • Compliance Program Guidance for Third-Party Medical Billing Companies • Important Episode: The 7 Elements of Dental Compliance Programs Thanks for listenting to Talking with the Toothcop! Don't forget to follow and turn on notifications for future episodes.

This episode was edited and produced by http://parkerkane.co/

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Don't miss this insightful conversation with Duane Tinker and Sophia Dunkley, a practice management coach specializing in case acceptance. In this episode, Sophia shares her journey to becoming a consultant, highlighting the crucial role of case acceptance in dental practices. She talks about the importance of trust, communication, and her strategies to truly enhance practice management.

Tune in to learn valuable strategies for cultivating collaboration, leadership, and patient trust in your dental practice. Connect with Sophia via her links below for a free consultation and to quickly learn how to elevate your practice!

Connect with Duane Tinker on LinkedIn and explore Dental Compliance Specialists, your trusted partners in navigating the complexities of dental regulations and compliance. Schedule your consultation today by calling (817) 755-0035. Resources mentioned in this episode:

The Practice Navigator: https://thepracticenavigator.com/ Sophia Dunkley on LinkedIn: https://www.linkedin.com/in/sophiadunkley/

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This episode was edited and produced by http://parkerkane.co/

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In this episode, Duane Tinker talks with Linda Kane of Zeroed-In Dental Solutions to explore the secrets of transforming dental offices and winning patients who stay, pay, and refer. Linda, a seasoned expert in dental billing and consulting, shares her journey from front office roles to becoming a renowned consultant and trainer in the industry.

See how Linda's innovative approaches and her bestselling book, Dental Office Rescue, can help you optimize your dental practice. Learn about effective insurance billing, creating a cohesive team culture, and the importance of compliance to ensure your practice thrives. Don't miss this conversation — it's packed with practical tips and strategies to elevate your dental office to new heights.

Link to Linda's new book! https://rescuemydentaloffice.com/

This episode was edited and produced by http://parkerkane.co/

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In this episode of Talking with the Toothcop, Duane Tinker provides crucial compliance reminders for your dental practice. Are you aware of OSHA's stepped-up enforcement? Are your social media posts compliant? We cover these topics and more, including the importance of patient selection and creating a safe work culture.

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This episode was edited and produced by http://parkerkane.co/

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In this episode of Talking with the Toothcop, Duane Tinker discusses the seven essential elements of a compliance program that you can't ignore to protect your dental practice. Learn how to comply with federal guidelines and avoid severe penalties under the False Claims Act.

Healthcare Fraud
The False Claims Act
Office of the Inspector General Website
Corporate Integrity Agreements
OIG Compliance for Individual and Small Group Physician Practices
HEAT Provider Compliance Training Videos
Measuring Compliance Program Effectiveness: A Resource Guide

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This episode was edited and produced by http://parkerkane.co/

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In this episode of Talking with the Toothcop, Duane Tinker chats with Elijah Desmond, also known as DJ Smiles. Elijah is a dynamic entrepreneur and motivational speaker in the world of dentistry. His journey from dental hygiene to creating innovative and engaging dental events is truly inspiring.

Elijah shares his path to success, the inspiration behind his many ventures, and his philosophy of blending fun with education in dentistry, making a positive impact on countless lives.

Dental Compliance Specialists: https://dentalcompliance.com/ Duane Tinker on LinkedIn: https://www.linkedin.com/in/duanetinker/ Resources mentioned in this episode:

Elijah's Website: https://elijahdesmond.com/ Elijah Desmond on LinkedIn: https://www.linkedin.com/in/elijahdesmond/

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This episode was edited and produced by http://parkerkane.co/

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In this episode of "Talking with the Toothcop," Duane talks with Dr. Matthew Norton, founder of People Plus Purpose, to discuss the transformative power of understanding and leveraging your team's strengths.

Dr. Norton shares his tips on team coaching and leadership, including his "core 4" assessments that help boost team productivity and success. Don't miss this deep dive into building a purpose-driven, strengths-based workplace!

Dental Compliance Specialists: https://dentalcompliance.com/ Duane Tinker on LinkedIn: https://www.linkedin.com/in/duanetinker/ Resources mentioned in this episode:

People + Purpose: https://peoplepluspurpose.com/ Duane on The Truth Behind Dentistry Podcast: https://youtu.be/SKznnqX39vM?feature=shared

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This episode was edited and produced by http://parkerkane.co/

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In this episode of Talking with the Toothcop, Duane Tinker chats with Dr. Heather Dawn Lawson Myers, a practicing dentist in Jamaica and the founder of Dental Assisting Made Easy (DAME).

Discover the importance of proper dental assisting training and how Dr. Lawson Myers' online platform is filling the gap in dental assistant education. From basic skills to advanced techniques, learn how this program is helping dental practices thrive.

Dental Compliance Specialists: https://dentalcompliance.com/ Duane Tinker on LinkedIn: https://www.linkedin.com/in/duanetinker/ Resources mentioned in this episode:

Dental Assisting Made Easy: https://www.dentalassistingmadeeasy.com/ Train Your Dental Assistant: https://trainyourdentalassistant.com/

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This episode was edited and produced by http://parkerkane.co/

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Join Duane Tinker, "The Toothcop," as he engages in a compelling conversation with Michael Gonzalez, an expert in maximizing dental practice potential by leveraging existing leads. Gain valuable insights into effectively converting your current dental practice leads into loyal, long-term patients!

Michael shares his proven strategies and tactics to optimize your practice's performance, ensuring sustained growth and success. This insightful dialogue between Michael Gonzalez and The Toothcop can revolutionize your approach to lead management in dentistry. Connect with Duane Tinker on LinkedIn and explore Dental Compliance Specialists, your trusted partners in navigating the complexities of dental regulations and compliance. Schedule your consultation today by calling (817) 755-0035. Learn more:

Dental Compliance Specialists: https://dentalcompliance.com/ Duane Tinker on LinkedIn: https://www.linkedin.com/in/duanetinker/ Resources mentioned in this episode:

All On 4 Liaison: https://allon4liaison.com/ Connect with Michael Gonzalez on LinkedIn: https://www.linkedin.com/in/michael-gonzalezjr/ Thanks for tuning in to Talking with the Toothcop! Don't forget to follow and enable notifications for future episodes.

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Introduction: Join Duane Tinker as he welcomes Leah Roling, an acclaimed life coach and celebrated author of "Shift" and "Nobody's Coming to Save You." Specializing in dental professionals' growth and success, Leah shares transformative insights aimed at enhancing both personal and professional realms.

Embracing the Platinum Rule with Leah Roling: Discover the transition from the Golden Rule to the Platinum Rule with Leah Roling. Understand the pivotal shift towards treating individuals based on their personal preferences and needs, a cornerstone for effective communication and relationships in and beyond dental practices.

Enhancing Communication within Dental Practices: Explore with Duane and Leah how effective communication transcends traditional dental services, fostering deeper connections with patients and promoting a thriving practice environment.

The Path to Personal Growth Through Discipline: Leah delves into the essence of personal discipline, the motivational triad, and the journey towards self-improvement and enhanced professional outcomes.

Foundations of Habit Formation for Dental Professionals: Learn Leah's strategies for establishing a sustainable baseline in habit formation, aiming to bolster consistent progress without the risk of burnout.

The Power of Self-Reflection and Gift Sharing in Dentistry: Revisit insights from a prior session where Leah discussed the impact of self-reflection and the importance of sharing one's unique gifts within the dental community and beyond.

Upcoming Opportunities for Professional Development: Stay ahead with Leah Roling's "Manifest Mind" course starting April 1, designed to empower individuals through mindset shifts and actionable steps towards crafting their desired life. Additionally, mark your calendar for an October event focusing on leadership and personal growth.

Connect with Leah Roling: Reach out to Leah through her official website, engage with her on social media, tune into her podcast "Becoming You" with Leah Roling, or get in touch directly via email for insights into transforming your dental practice and personal growth.

Leah Roling's Impact on Dental Leadership and Team Dynamics: Leah Roling stands as a transformative leader in dentistry, emphasizing leadership development, team dynamics, and engagement strategies to combat industry challenges such as burnout, turnover, and absenteeism. Through her innovative approach, Leah fosters environments of empowerment, confidence, and creativity, ensuring dental practices not only meet but exceed modern expectations.

Engage with Leah Roling: Discover Leah's comprehensive suite of resources for dental professionals seeking to enhance their practice's dynamics and patient satisfaction through her website, LinkedIn, Facebook, YouTube, TikTok, Instagram, and her inspirational podcast.

Your Invitation to Transform Your Dental Practice: In the ever-evolving changes in dentistry, the success of your practice hinges not just on the quality of care you provide but also on the health and harmony of your team. Recent shifts in the workforce landscape have brought to light the critical need for evolved leadership strategies that go beyond traditional management.

As a dedicated leadership and team engagement strategist specializing in dentistry, I understand the unique challenges you face—burnout, turnover, and absenteeism are not just issues; they're barriers to your practice's growth and patient satisfaction. It's clear: to thrive in today's environment, simply leading and managing isn't enough. The key lies in enrolling your team in their potential, fostering a culture of confidence, decisiveness, and creativity, and shifting from expectations to empowerment.

Are you ready to assess the health of your practice and explore practical strategies that have proven to reduce absenteeism by a staggering 81% and turnover by 18%? With the average cost of hiring reaching $45,000, reducing turnover isn't just beneficial; it's essential.

I invite you to book a complimentary leadership call with me, where we'll conduct a 5-question assessment to pinpoint the health of your practice. Together, we'll tailor engagement strategies to your unique needs, setting you on the path to a more harmonious, productive, and resilient practice.

The workforce has changed. Has your leadership? Let's explore how you can adapt and excel in this new era.

Leah Roling

Phone Number: 515-865-6716

Email: leahtfl@gmail.com

Social Media Handles

Website: www.leahrolingcoaching.com

LinkedIN- https://www.linkedin.com/in/leahroling/

Facebook-https://www.facebook.com/profile.php?id=100087511623234

Youtube - https://www.youtube.com/channel/UCkSOBSTuY97mQXacTbiufTA

TikToK- https://www.tiktok.com/@leahrolingcoach

Instagram- https://www.instagram.com/leahrolingcoaching/

Podcast: https://podcasts.apple.com/us/podcast/the-becoming-you-show-with-leah-roling-inspire/id1608085445

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Clinical Recordkeeping for Dental Assistants for Nifty Thrifty Dentists Group

🦷 The importance of proper documentation and compliance in dental practices: Learn from Dwayne Tinker, former police officer for the Texas Dental Board, as he shares insights on #DentalCompliance and record-keeping.

Key Takeaways:

1️⃣ Proper notations for medications and doctor's instructions are crucial.

2️⃣ #HIPAA compliance is a must, especially for patient record access.

3️⃣ Respect patient privacy and obtain consent during conversations.

4️⃣ Ensure accuracy and reliability through thorough documentation.

5️⃣ Fix problems in advance to maintain credibility and avoid audits.

6️⃣ Comprehensive clinical notes are essential, including medical history, x-ray findings, and perio charts.

Join us to stay informed about the legal implications of dental records! 📋🔒

#DentalDocumentation #ComplianceMatters #PatientPrivacy #DentalRecords #HealthcareCompliance

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On LinkedIn

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Amanda Hill RDH, BSDH has been a dental hygienist for over 26 years. When she took her annual infection control training in 2017, the speaker covered waterlines. She never knew that she had to do more than flush her waterlines. No one else in her dental office knew that they were supposed to do more.

Her practice failed their first water test, badly. So Amanda dug in and got them to pass their water testing. Then she started offering to help other dental offices. In this episode, Amanda shares her expertise and we have a deep discussion about waterline testing.

Outline of This Episode * [1:56] Learn more about Amanda Hill AKA the “Waterline Warrior” * [6:24] Open line versus closed waterline systems * [11:10] What is a biofilm and how do you kill it? * [16:08] Amanda’s favorite germicide delivery system * [19:39] Reasons you need to do waterline testing * [26:25] Why you want to be consistent with treatments * [28:40] How frequently you should test your waterlines * [33:24] Addressing the flushing your waterlines debate * [38:33] Waterline testing must include documentation

Resources & People Mentioned * Email: amandahillrdh@gmail.com * Friend on Facebook * Follow on Instagram * Connect on LinkedIn * Check out Amanda’s Website * Deanna Otts-Whitfield, RDH, BSDH, MSHQS * BluTube Dental Unit Water Purification Cartridge * Dental procedures during pandemic are no riskier than a drink of water * Preventing Airborne Diseases in Dentistry with Michelle Strange * CDC warns of bacteria in dental waterlines after children are infected

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Without question, the Covid pandemic had a large impact on the healthcare field. It highlighted monstrous changes that needed to occur in the infection control space. MCS put its resources into investigating standards of care in infection control.

MCS came out with some new technologies that will transform the world of infection control. Paul Saueressig outlines the solutions they’ve created and how they can benefit your dental practice in this episode of Talking with the Toothcop. Do NOT miss this one!

Outline of This Episode * [2:12] Learn more about MCS Infection Control Solutions * [8:01] Solution #1: Protective Coating Solutions * [15:03] Solution #2: Rapid Testing Solutions * [26:08] Two options for healthcare facilities * [35:53] The problem with Healthcare-Associated Infections (HAIs) * [39:56] Providing long-term proactive solutions for the healthcare space * [41:09] How to get more information about MCS infection control solutions

Resources & People Mentioned * MCS * Paul Saueressig * Hygiena

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Have you heard of the federally implemented “No Surprises Act?” Were you aware that it applies to dentists? The No Surprises Act protects uninsured and self-pay patients from receiving surprise medical bills. So what does that mean for your practice? Find out in this episode of Talking with the Toothcop!

How the “No Surprises Act” applies to dentists As of 1/1/2022, you need to provide patients an estimate of anticipated charges for dental services, i.e. “Good Faith Estimates” or GFEs. They must be provided upon request or upon scheduling an appointment—well in advance of the treatment plans and financial estimates you may be currently providing.

Because you’re already providing financial estimates in advance of service, does that mean you’re exempt? NOPE. Sorry to tell you, that’s not the case. At this time, it applies to uninsured and self-pay patients. It may apply to insured patients in the future.

What do you have to do? Here are the basics:

You have to provide notice to your patients of their right to receive a GFE
You must post a notice on your website
You must post a notice in your practice where scheduling and service costs may be discussed (so a check-in desk).

You need to implement a good faith form in your practice. You have to issue this to current and new uninsured and self-pay patients before you provide—or continue providing—services. This applies to anyone who even contacts your office. If they ask what you charge for a dental cleaning, you have to provide them with that estimate.

What else do you need to know?

Even if you provide a GFE verbally, it must also be provided in writing (mail, fax, or encrypted email). Before you give out this information verbally, it’s wise to tell a potential patient that you must follow up with this information in written form and ask for their name and address (and assure them this is federal law).
It must be provided within a specific time frame (1–3 business days after an appointment is scheduled or 3 days after an inquiry)
GFEs must be mailed to current patients before you continue with treatment
You have to maintain the estimates that you provide in a patient’s charting and document in their progress notes that you’ve talked about the GFE
They have to be maintained for six years (even GFEs for patients who never scheduled)
A GFE is the cost of services that you anticipate providing for a patient over a year. If those costs change, you must issue a new GFE.

None of this is difficult. But it is just one more thing you have to implement. That’s why we’ve created a toolkit for you to help you implement this in your practice.

Why does any of this matter? If there is a difference of more than $400 between your GFE and billed charges, the patient can initiate a billing dispute that the HHS can investigate. Those decisions are reviewed by a third-party contractor. If the decision doesn’t go in your favor, you can lose out on legitimately earned fees. Secondly, this may become like HIPAA. A complaint may lead to your practice being audited and civil monitoring down the road.

Outline of This Episode * [1:23] The Federal No Surprises Act * [3:35] What you have to do * [7:03] When did this become effective? * [8:04] Why does any of this matter? * [9:52] Where this falls in order of operations * [11:00] Q&A session with Laura * [17:49] How to connect with Laura * [19:46] Important compliance reminders

OUR SPONSORS: ProEdge Dental Water Labs: https://ProEdgeDental.com/Toothcop

Protective Dental: https://DentalCompliance.com/DrugKit

Resources & People Mentioned * The No Surprises Act implementation guide and toolkit * Connect with Laura by email: ldiamond(at)dsedlaw.com

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Everyone needs a compliance program tailored to the needs of their practice. Justin Withrow jumps in when a compliance program is absent and things go horribly wrong. Perhaps a client was employing an individual that's excluded from participation in the Federal Healthcare Program that should have been caught. There is a multitude of things that could happen that could have been prevented by a compliance program. In this episode of Talking with the Toothcop, we dissect the importance of exclusion monitoring, the basics of the false claims act, self-disclosure protocol, and much more.

The importance of exclusion monitoring Justin worked with a multi-location practice where the owner worked with walk-in and Medicaid clients frequently. He was doing criminal background checks and checking licenses with the dental board. But he didn’t know an exclusion list existed with the Federal Healthcare Program that could exclude providers from working with the Medicaid program. Unfortunately, one of his providers knew they were excluded and didn’t tell him. It resulted in a fraud investigation of his practice. He was looking at jail time for something that could easily have been avoided.

It feels like science fiction but it’s the real deal. It’s as simple as running your licensed staff members’ names through a website. You need to know they’re authorized to work with your patients so you can get reimbursed for services rendered. If you don’t, they’ll take that money back—and then some. Justin dissects the basics of the false claims act and the fines you could be looking at if you were caught in this situation. Don’t miss it.

The submission of “unclean” claims If you submit a claim for reimbursement by a provider who is excluded from a state Medicaid program, that claim is labeled as a false claim. Let’s say a practice employs someone who they knew was excluded and billed services as rendered by a credentialed provider. If it was determined the service was rendered by an excluded provider, that triggers a false claim. Any service rendered by an excluded provider and submitted for reimbursement to Medicaid is a false claim.

If a provider has been excluded, that individual can’t have contact with any patient insured with Medicare or Medicaid. If they work on that patient that claim cannot be reimbursed. That’s why it is SO important to do exclusion checks. This applies to dental assistants, hygienists, and even administrative staff. Every member of your organization needs to be regularly run through exclusion databases.

Defining self-disclosure protocol A compliance program helps you identify improper practices (something coded incorrectly, overpayment, etc.), catch them, and self-disclose or clarify that you made a mistake. You can let the governmental agency know a mistake was made and correct the mistake. Usually, you’re given a certain time period—60 days—in which to self-disclose. The government knows mistakes happen. That’s why this protocol exists.

If you’re in the general ballpark of 60 days, it’s usually fine. Even if you’re outside of the 60-day window, doing nothing is the wrong approach. You will get in trouble down the road. It’s always appropriate to rectify your mistakes when they’re identified. Just work with a professional to do it appropriately.

What a compliance program must address A compliance program must address the policies and procedures that an office uses to operate (i.e. OSHA, HIPAA, dental board regulations, state and federal regulations, etc.). You must properly and safely render care to patients while adhering to various laws of various agencies. It’s an all-encompassing document that dictates how you do everything in your practice. It’s who you are and how you operate. It has to be reflected in the day-to-day operation of your practice.

People always say, “We’re too busy.” That’s NOT okay. It’s an excuse. These things can’t fall by the wayside. This has to be a staple of your business. There needs to be a compliance officer that is someone other than the dentist. They are your professional lifeguard. They stop the real cops from coming into play. If you’re “Too busy” it’s only a matter of time before you’re audited or investigated.

Outline of This Episode * [3:56] The importance of exclusion monitoring * [6:30] The basics of the False Claims Act * [11:56] Defining self-disclosure protocol * [16:21] What a compliance program must address * [24:12] Managing the merger and acquisition process * [29:21] Possible reductions in fines and penalties * [31:44] How to connect with Justin Withrow

OUR SPONSORS: ProEdge Dental Water Labs: https://ProEdgeDental.com/Toothcop

Protective Dental: https://DentalCompliance.com/DrugKit

Resources & People Mentioned * DENTAL COMPLIANCE RULES: NEW IN 2021 [PART II] * DENTAL CHART AUDITING [WHY IT’S SO IMPORTANT] * Connect with Justin Withrow * Connect with Justin on LinkedIn

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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When you’re in the midst of a busy day in your dental office, the details are the things that you typically let slide, right? But in the dental business, it’s the details that keep you on track and it’s the details that protect your office from huge fines and your Doctor from losing her licenses. This episode highlights some of the things I’ve seen recently that I think all dental office workers need to have top-of-mind. If you don’t take these things seriously, you’re going to have issues eventually.

Online training or in-person training? Which do you need? Every dental office is going to be required to do Continuing Education from year to year. BLS, ACLS, and PALS are common certifications that need to be upgraded. Many times, compliance teams do their training through “approved” course providers through an online course. That’s OK, but you can’t assume that because it says “approved” or “certified” that it’s truly that across the board. Your STATE may have additional requirements that the course provider is not aware of. For example, for some of the CE requirements, you can do the didactic part online and the testing part online. But you must have a hands-on, in-person evaluation of skills to finish up the CE credit. Don’t get caught out of compliance because you didn’t finish a course as was required. If you discover that’s the case for you, simply fix the issue as soon as possible.

Office Inspections: Things I’m seeing that you should consider As I do reviews at offices to help them get ready for State Board Inspections, I come across a variety of things that are of concern and should be addressed. One of the most common points where I’m finding errors recently is the Pre-Op Sedation/Anesthesia Checklist. State inspectors are fanatical about the form and want it to be used without exception. The title on your form must be exactly that: Pre-Op Sedation/Anesthesia Checklist. There is a lot of information on that form that is required to be ON the checklist. You will fail your sedation review if that is not the case. These are little things you need to make sure are properly in place to pass the inspection. You don’t want to be embarrassed or look bad in front of the board. If you are not 150% sure on your checklist, send me a copy and I’ll send you input on what you are missing (if anything).

Compliance around drugs is a huge issue I’m seeing of late We all know there are compliance regulations in force surrounding the topic of expired drugs. But lately, I’ve come across offices that have terrible problems in this area. Many offices have their checklists but they are not accurate or up to date. In one situation I encountered, the NEWEST expiration date on drugs in their facility was dated 2016. That’s so problematic! You MUST be up to date by removing expired drugs from the premises, and by keeping accurate records. You’re playing a risky game if you’re not taking compliance issues like this seriously. Don’t just check the boxes on the forms, pay close attention to the reality of you drug inventory. Protect yourself and your patients. It doesn’t matter until it matters, and then it matters big time!

Why office inspections are powerfully helpful for your dental practice The beauty of what I do and how I do it is that I’m able to do office inspections as a neutral 3rd party. That means I’m able to be entirely objective because I am not tied to the outcome in any way. I’m not so close that I can’t see the issues. This helps me identify what needs to be fixed, help the staff fix the issues, and move on. It really is that simple. There’s no need for panic or concern because you find something of concern. Just call and I’ll come out and assess everything, give you my recommendations, and point you in the right direction to fix any compliance issues I find.

Quotes for this episode:

“If you continue to think the way you’ve alway thought, you’ll continue to get what you’ve always got.” - Kevin Trudeau

“Do all the good you can, by all the means you can, in all the ways you can, in all the places you can, at all the times you can, to all the people you can, as long as you can.” - John Wesley

Outline of This Episode * [3:58] Continuing Education requirements - changes, updates, clarifications * [10:35] Office reviews and concerns that I’m seeing as I do these reviews * [18:05] Best-practices for Dental office reviews (the article is linked below) * [25:15] The quotes we’ve found helpful this past week

Resources & People Mentioned OUR SPONSORS:

ProEdge Dental Water Labs: https://ProEdgeDental.com/Toothcop

Protective Dental: https://DentalCompliance.com/DrugKit

Get the physical newsletter: The Dental Legal Update (Jeanine’s website)
Dental IQ: Survivor: Dental office audit edition

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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During the 4th Quarter of 2021 we saw a lot of enforcement activity, from the agencies that are announcing their fraud enforcement efforts to insurance companies that are initiating audits, etc. So whatever you’re involved with (Medicare, Medicaid, Indian Health Services, etc.), be sure you have an audit process in place that includes good records on the steps you’ve taken. You need to be able to prove your compliance should an audit or investigation comes your way.

Narcotics charges against a Michigan Dentist, and lesson for all of us A Michigan Dentist was busted recently on narcotics charges, and it’s easy to sit at a distance and pass judgement. But regardless of the facts in this case, there are other things that happen along this line that are more common. For example: sometimes only one Dentist has a DEA license but the others in the practice may write scripts using the other Doc’s DEA number. That’s a dangerous habit to get into. This news story demonstrates that the powers that be are not looking the other way. Don't share your credentials and don’t allow other providers to use your credentials. Sharing is not caring in this situation.

Are you considering the purchase of a dental practice? If you are considering buying a dental practice and the practice has been guilty of compliance issues, you will become liable for those issues the moment you buy the practice. So you need some kind of due diligence process that will assess the practice before you buy to ensure you’re not buying a piece of junk that you can’t get into compliance. But the good news is that not all things that look terrible are terrible. Duane has seen many situations where a practice was able to be easily fixed, then sold (like house flipping) for a profit. If you’re looking for support in the purchase of a dental practice, reach out!

Outline of This Episode * [3:06] Duane’s interest and belief in goals (and another puppy) * [7:13] Regulatory action is taking place, so be sure your audit process is up to date * [8:44] A Michigan dentist is guilty on narcotics charges brought by the DEA * [14:38] The Self-Disclosure Protocols have been renamed * [17:27] The DOJ reintroduces corporate compliance monitors * [26:31] NEW SEGMENT: Inspirational Quotes

Resources & People Mentioned * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * The Pro Edge Water team - www.ProEdgeDental.com/Toothcop (affiliate) * Michigan Dentist busted by the DEA * Self Disclosure Protocols renamed * CIA's are back! * The Justice Department's criminal fraud page

“We don’t rise to the level of our expectations, we fall to the level of our training.”

“Don’t practice until you get it right, practice until you can’t get it wrong.”

“Most people never run far enough on their first wind to find out they have a second wind.”

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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I started the Talking with the Toothcop podcast in December 2017. Andrea has been with me since early 2019. We love doing this podcast together. Sadly, it’s time for us to hit the pause button. We will be back—I promise! But we have a lot on our plates right now and it makes sense to pull back temporarily. If this podcast has been rewarding and educational for you professionally, take some time and go back to listen to our episode archive!

Outline of This Episode * [0:22] What’s happening in our lives! * [4:18] Check out ProEdge Dental * [7:01] Sharing some bittersweet news * [9:07] Learn more about protectIt dental

Past podcast episodes to check out! Check out some of our most popular and episodes packed with need-to-know information:

Dental Unit Waterlines: the Good, the Bad, and the UGLY (with Mike Rust + Kellie Thimmes
The 7 Elements of Dental Compliance Programs
How a Compliance Program can Save Your Bacon
Sedation Inspections + EPCS + Continuing Education
The Importance of Sterilization Processes - Stephen Kovach

We’re always here to answer questions, so don’t be afraid to reach out. Until we return, subscribe to our email list!

Resources & People Mentioned * Check out ProEdge Dental at https://proedgedental.com/toothcop! * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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I work with dental offices and do a lot of dental inspections/consults. I help people identify what they need to do differently. We talk through OSHA, HIPAA, infection control, radiology, medications, state board compliance, etc. But I get really excited about infection control and sterilization. That’s my stage—my moment to shine. In this episode of Talking with the Toothcop, we’re going to talk about instrument processing and cleaning procedures. Find out what you could be doing wrong and what to do instead!

Outline of This Episode * [0:49] Time to redo the 75 Hard Challenge! * [6:00] Check out ProEdge Dental at https://proedgedental.com/toothcop! * [7:16] What a sterilization room should look like * [10:46] Don’t neglect monitoring your ultrasonic * [14:37] Follow manufacturers instructions for use * [16:45] Other things to note when using your ultrasonic * [20:20] Learn more about protectIt dental at https://dentalcompliance.com/drugkit * [21:46] Check out the 2021 Dental Compliance Bootcamp!

What a sterilization room should look like I’ve seen thousands of sterilizations rooms. Some are great, some are poorly designed, and some just don’t shock me anymore. What should it look like? It needs to be physically segregated into different areas for instrument receiving and cleaning, decontamination, preparation and packaging, sterilization, and storage.

There needs to be a “cleaned” area and a dirty area. I can’t tell you how often I see cross-contamination issues. When you bring the instruments into sterilization, the rest of the processes need to move in one direction. If you move in the opposite direction, you’re contaminating what’s supposed to be sterile.

Don’t neglect monitoring your ultrasonic A sterilization area contains two major processes: instrument cleaning and sterilization. If you don’t do one part right, it impacts the entire process. There are monitors in place for the sterilizer, color-changing indicators on instrument peel-pouches, and indicator tape on instrument cassettes. They give us visual confirmation of whether or not the sterilization process worked.

People often monitor the sterilization indicators but neglect the cleaning side of the process. You can’t just assume the instrument washer or ultrasonic is working effectively. Just because it sounds like it’s working properly doesn’t mean it is. You need a qualitative test—like a foil test—to make sure that it’s working properly. It needs to be done frequently. When those machines fail, they don’t sound any different. It is not obvious.

I don’t love the foil test. What do I prefer instead? An ultrasonic cleaning monitor. It can be ordered through your dental suppliers. Get and use that weekly. Record in your records that it passes inspection. It gives you information on several data points: cavitation, enzyme concentration, and more.

Follow manufacturers instructions for use (IFU) Are you using the correct concentration of enzymes in the ultrasonic? More than half of dental offices aren’t. Whatever product that you use for ultrasonic enzymes, make sure you follow the manufacturer’s instructions for use. People frequently use the wrong concentration, which is why I’m partial to tablets. It’s easier to calculate.

Secondly, people don’t understand the water capacity of the ultrasonic. The box says “one tablet per gallon” so they drop one tablet in, not realizing they have a three-gallon unit. One tablet won’t cut it—you’re off by a lot. I was in an office last week that had a three-gallon ultrasonic and they were putting in one tablet. According to the IFU, they were supposed to be using two tablets per gallon. They should have been using six tablets total!

What’s an easy way to track this? Buy a label maker and print the name of the product and the number of tablets/ounces required each time you fill an ultrasonic.

Other things to note when using your ultrasonic What else do you need to focus on?

Run the ultrasonic with the cover on. When the cover is not in place, you’re spewing aerosols of biohazards into the air. If you don’t have a cover, get a replacement.
Anything that has moveable parts or hinges must be in the open position before it goes in the ultrasonic. If you’re not doing this, bioburden accumulates in the jaw or hinge. Those parts must be exposed to be adequately cleaned and sterilized.
Cleaning time is important and it varies per dental instrument. Review the IFUs for each individual piece you have as well as peel-pouches and instrument cassettes.

If you run the instruments and find when you’re rinsing them that they’re still dirty, what do you do? Run the cycle again. Fight the urge to manually scrub instruments. You will never do as good of a job as the instrument washer/ultrasonic.

Tune in next week for part II—the sterilization process!

Resources & People Mentioned * Check out the 75 Hard Program * Ultrasonic Cleaning Monitor * Check out the 2021 Dental Compliance Bootcamp! * Check out ProEdge Dental at https://proedgedental.com/toothcop! * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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It’s September! And it’s officially Dental Infection Control Awareness Month! We get you’re probably sick and tired of hearing about COVID and infection control. So guess what? Andrea and I will cover infection control without mentioning COVID, other than right now...We’ll cover getting a point-person in place and written policies and procedures. Check it out!

Outline of This Episode * [0:20] Dental Infection Control Awareness Month! * [1:20] Check out ProEdge Dental at https://proedgedental.com/toothcop! * [3:02] Every office needs a point-person * [6:17] Make sure you have written infection-control protocols * [10:31] Learn more about protectIt dental at https://dentalcompliance.com/drugkit

Every office needs a point-person This is an opportunity to use the time we have in Slowtember to review infection control protocols. Every office needs to have an infection prevention coordinator—or OSHA safety coordinator—to oversee all things related to employee safety and infection control. If more than one person is in charge, no one is in charge. Andrea points out that you don’t want to run into a situation where you’re saying, “Oh, I thought you were taking care of that.”

Secondly, you want to make sure if that person leaves their role is reassigned to someone else. If you don’t know who it is, you probably don’t have someone in place. I promise you, there will be someone in your practice who wants to do the role. But if no one steps up, so be it. Someone has to lead the pack and you get to choose who that someone is. But make sure you give them the paid time to get it done.

Make sure you have written infection-control protocols You need to have written policies and procedures that establish how you do things. According to the CDC, you need written procedures specific to the dental setting. This includes things like:

Procedures for containing respiratory secretions
Rules for sick employees
Infection control education
Policies for immunizations and vaccinations (Hepatitis B, Chicken Pox, MMR, Tetanus, Diphtheria/Pertussis)
Safe injection practices for sharps/needles
Rules for cleaning and sterilizing contaminated dental instruments
Having instructions for use for medical devices and instruments (handpiece, sterilizers, x-ray machines, etc.)
Cleaning and disinfection protocols for surfaces
Cleanups of chemical spills or bodily fluids
Testing dental unit waterlines + water treatment
Protocols for the correct use of sterile water
Rules for how to manage boil water advisories
A tuberculosis exposure control plan (review the statistics for your country and state)

Many dental offices that have a written set of protocols have never read them. That means practices are simply assuming their staff has been trained on these things. Not good. The dentist is expected to have the most knowledge and experience with infection control. Sadly, they’re often the least knowledgeable and experienced. Don’t let that be you! You also want to have a detailed conversation with your staff about these protocols. Does your staff know them? You’re only as strong as your weakest link.

Mark your calendar for Dental Compliance Bootcamp 2021! Bootcamp is all things compliance and risk-management related. It’s available to non-clients (even better, It’s FREE for current clients).

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Did you know that September is National Preparedness Month? So in this episode of Talking with the Toothcop, we share some quick tips your practice can follow to be prepared—for whatever may come. We also share a few ways you can take advantage of “Slowtember” and prep for the year to come.

Outline of This Episode * [0:22] Quick tips for emergency preparedness * [6:00] Take advantage of Slowtember * [11:57] Check out Compliance Bootcamp * [12:45] Shoutout to some podcast listeners!

Quick tips for emergency preparedness What are some easy things you can do to prepare your practice for emergencies?

Check that emergency lighting (exit signs) are working properly if there’s a power outage.
Check your fire extinguishers and make sure they aren’t overdue for inspection. The fire department can do—and will sometimes just walk in—fire extinguisher checks for you.
Check your smoke detectors and change the batteries regularly.
Make sure that you perform an annual emergency drill. Have your staff put their John Hancock on a sign-in sheet and keep documentation proving you completed training. If it ain’t written, it didn’t happen.
Get out your medical emergency plan and review it with your staff. Make sure that you walk through every part of the process (except calling 911).

Take advantage of Slowtember September is a slow month for many dental practices, so make sure—if you haven’t already—to get your compliance training knocked out. Cover bloodborne pathogens, HIPAA, cybersecurity, etc. If you participate with Medicaid/Medicare, you’ll also need to do your Fraud, Waste, and Abuse training.

Take a few minutes to review everyone’s credentials and make sure they’re up-to-date. You should check CPR certifications, DEA registrations, sedation permits, even your driver's license and vehicle registration. Check anything that has an expiration date on it—both personally and professionally.

What else can you do? Mark your calendar for Dental Compliance Bootcamp 2021! Bootcamp is all things compliance and risk-management related. It’s available to non-clients (even better, It’s FREE for current clients).

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In this episode of Talking with the Toothcop, you get a glimpse into the “behind the scenes” of what recording an episode really looks like. From food pranks to our favorite Starbucks orders—every tangent that we usually edit out is on full display. Don’t miss a fun and quirky episode that also includes some important news about our Dental Compliance Bootcamp! Listening may even get you some FREE coffee!

Outline of This Episode * [0:21] Food pranks: Starbucks + Subway * [6:10] Check out ProEdge Dental at https://proedgedental.com/toothcop! * [12:12] Dental Compliance Bootcamp 2021 * [20:00] Record-keeping + Compliance Programs + Cybersecurity * [27:48] Learn more about protectIt dental at https://dentalcompliance.com/drugkit

Learn about Dental Compliance Bootcamp 2021 Bootcamp is coming up, November 19th-20th in Hurst, TX (in the DFW area) at the Hurst conference center. The Hilton Garden Inn is attached to the conference center.

We are going to have some hands-on medical emergency training. After attending, dentists will be able to facilitate training for their staff. Secondly, bring your team and run through some scenarios together.
Justin Bonner, DDS Board Certified in Oral and Maxillofacial Surgery & Garrett Starling, MD Board Certified Anesthesiologist will be there! (the course instructors for our pain management course)
You’ll get some courses on insurance with Tonya Burns (Pediatric Consultant).
Laura Diamond—a healthcare attorney—will be returning this year. She’ll be presenting in our risk-management and record-keeping course.

The goal is to provide you hands-on clinical training that you can immediately put into practice.

This years theme: Record-keeping + Compliance Programs Most of our presentations will center around:

We will go in-depth on the nuts and bolts of a corporate compliance program for people who participate in Medicare/Medicaid. We will also complete a mock compliance committee meeting. You’ll learn what you need to talk about and cover in these meetings.
Record auditing is a major element of compliance. We’ll cover what you need to audit/monitor, what it looks like, what records to create, and how to solve problems when you run into them.

If you have any compliance responsibilities, come and immerse yourself in the experience. It’s not your typical conference. It is hands-on and immersive and you will get to experience everything with us. This is an opportunity to learn great things to apply to your organization. It’s also a chance for you to interact with our clients to decide if we’re a great fit for you.

What’s your favorite drink from Starbucks? Let me know at toothcop(at)dentalcompliance.com and I’ll put you in a raffle for a gift card!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Did you know there are specific rules from the Office of the Inspector General (OIG) regarding giving things of value (i.e. gifts) to solicit potential customers? In this episode of Talking with the Toothcop, Andrea and I talk about some of the specific rules on gifts and kickbacks. This is stuff that you need to be aware of so you don’t get hit with penalties and fines for breaking the law.

Outline of This Episode * [3:34] The OIG Backpack Rule * [11:26] Texas Administrative Code Rule 108.58 * [15:25] The anti-kickback statute (42 U.S.C. 1320a-7b) * [20:34] Section 259.008 Dental Practice Act * [23:03] “But everyone is doing it” * [28:08] Dental Compliance Bootcamp 2021

The OIG “Backpack” Rule The OIG released a special bulletin entitled “Offering Gifts and Other Inducements to Beneficiaries.” This advisory from the OIG clarifies how the state interprets and applies the rules and statutes to giving things of value to Medicaid benefit recipients.

While they understand the competitive market and desire of dental practices to differentiate themselves in the mind of potential patients, they must uphold the integrity and fairness of the Texas Medicaid program. Giving gifts may raise concerns among the community and other providers.

The OIG reinforces Texas Administrative Code §371.1669, which prohibits a person “From transferring or offering any remuneration which the person knows or should know is likely to influence the beneficiary’s selection of a provider, practitioner or supplier of Medicaid payable items or services.”

The state of Texas has announced that they will enforce more stringent rules than the HHS OIG, including:

Providers are prohibited from offering items or services to influence health care decisions. The OIG presumes that any items that do not exceed $10 per patient were not provided to influence their decisions.
Likewise, anything offered to a patient must be directly related to dentistry (i.e. a toothbrush, toothpaste, floss, etc.). You are NOT allowed to give patients backpacks and school supplies, even if your intentions are good. We get that it’s back-to-school time and people like to give out back-to-school supplies. Dental providers cannot do that.
You may never offer patients cash or gift cards.

Is it different for non-Medicaid providers? Non-Medicaid providers still have to adhere to the Texas Occupations Code Section 102: Solicitation of Patients, which includes rules about not giving gifts to patients (though it doesn’t explicitly call out backpacks). Can non-Medicaid providers give gifts or do giveaways for current patients? Listen to learn more about Texas Administrative Code Rule 108.58

The anti-kickback rule (42 U.S.C. 1320a-7b) The Anti-Kickback Statute is a criminal law that prohibits the knowing and willful payment to reward patient referrals or the generation of business involving any item or service payable by the Federal healthcare programs (e.g., drugs, supplies, or health care services for Medicare or Medicaid patients).

This includes things like rent, hotel stays, meals, excessive compensation, paying referrals, etc. Physicians or dentists who accept or pay kickbacks will be penalized up to $50,000 per kickback plus three times the amount of the remuneration. Dentists make attractive targets for kickback schemes because you are a source of referrals.

Kickbacks in healthcare can lead to overutilization, increased program costs, corruption of medical decision-making, patient steering, and unfair competition. I hear of offices that offer free or discounted dental care for parents if they bring their children on Medicaid to the practice—which is clearly a violation of Federal law. Taking a kickback can never be justified, even if the service rendered was medically necessary.

More of this is coerced in Texas Occupations Code Sec. 259.008 Unprofessional Conduct.

When people say “But everyone is doing it” Some dentists have pointed out to me that there is an unfair advantage because dentists in their community do these things. The temptation to get involved in a scheme like this is high because “everyone is already doing it.” Firstly, don’t do something that everyone else is doing. That’s not how you grow your business (especially with something illegal).

Instead, find out what’s legal in your state (and federally) and then run tests to see what works. It can be as simple as focusing on giving your patients the greatest experience possible. You can make it a memorable and pleasurable experience. How can you take customer experience up a notch?

Lastly, if people in your community are doing illegal things, perhaps they aren’t aware. If you have the gumption, you can talk to them about it.

We cover a lot in this episode. Listen to the whole thing for all the nitty-gritty details!

Resources & People Mentioned * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * Check out ProEdge Dental at https://proedgedental.com/toothcop! * Offering Gifts and other Inducements to Beneficiaries * Texas Occupations Code Section 102: Solicitation of Patients * Texas Administrative Code Rule 108.58 * 42 U.S.C. 1320a-7b - Criminal penalties for acts involving Federal health care programs * Texas Occupations Code Sec. 259.008 Unprofessional Conduct * Mark your calendar for Dental Compliance Bootcamp 2021

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Are PMP inquiries required for sedation meds that are dispensed in the office? A listener read through the rules in January 2020 and spoke with a sedation officer and was advised that they did not need to do the PMP check if they were dispensing in the office. But the way the rule is worded makes it seem as though you do need to. So in this episode of Talking with the Toothcop, Andrea and I will cover Chapter 111 and spell out the PMP rule in detail. Hopefully, this will clear up any confusion you may have!

Outline of This Episode * [3:43] Rule 111.1: Additional Continuing Education Required * [6:24] Rule 111.2: Self-query of Prescription Monitoring Program * [7:43] Rule 111:3: Prescription Monitoring by the Dentist * [10:51] Breaking down the PMP inquiry rule * [12:54] Rule 111.4: Prescription Monitoring by the Board * [14:12] Rule 111:5: Electronic Prescribing Waivers * [16:51] Subscribe to our email list to stay up-to-date!

Rule 111.1 Subsection B: Additional Continuing Education Required According to Rule 111.1 Subsection B, effective September 1st, 2020 every dentist that prescribes controlled substances must complete two hours of continuing education “...related to approved procedures of prescribing and monitoring controlled substances.” This can be taken annually to count toward continuing education.

Dentists have found this confusing because many have already taken the course. However, the requirement reset September 1st, 2020. So anyone who completed the two hours of continuing education on controlled substances before that date must retake it before September 1st, 2021. I know several thousand dentists have not yet taken this course. We offer this course on our site—that you can complete at your own pace—so check it out.

Rule 111.2: Self-query of Prescription Monitoring Program Rule 111.2 became effective Dec. 25th of 2016:

“Each dentist who is permitted by the Drug Enforcement Agency to prescribe controlled substances shall annually conduct a minimum of one self-query regarding the issuance of controlled substances through the Prescription Monitoring Program of the Texas State Board of Pharmacy.”

Many dentists don’t even have a login for the PMP. You need to do this. The state board of pharmacies can report you and you’ll have to answer for your failure to comply. You will face disciplinary action, which starts with paying a fine and lead to jurisprudence assessment.

Rule 111:3: Prescription Monitoring by the Dentist Rule 111:3 became effective March 1st, 2020, and says:

“(a) Prior to prescribing or dispensing opioids, benzodiazepines, barbiturates, or carisoprodol, a dentist shall access the patient's prescription drug history report through the Texas State Board of Pharmacy's Prescription Monitoring Program (PMP) Clearinghouse. Failure to do so is grounds for disciplinary action.”

The rule goes on to say that an employee of the dentist can do the PMP check when directed by said dentist. The only exceptions? The PMP inquiry does not have to be completed if the patient is diagnosed with cancer or receiving hospice care and it’s noted in their record.

If the dentist cannot do the inquiry due to circumstances outside their control—but has attempted—is not considered to have violated the rule. What circumstances might be outside of the dentist’s control? This would include something like the PMP website being down, your internet is down, etc.

You need to get a process in place, look at the drugs you prescribe, and make sure that you check the patient’s drug history through the PMP before you prescribe opioids, benzodiazepines, barbiturates, or carisoprodol.

Administering versus prescribing or dispensing: What Gives? The PMPinquiry rule doesn’t apply to administering these drugs but prescribing or dispensing. Dispensing is giving it to the patient to take it later. Prescribing usually entails the patient picking up the medication from the pharmacy. In both cases, the patient has possession of the controlled substances with the opportunity to take them.

A PMP check is not required prior to administering to a patient in your chair immediately. Why? Because you are controlling how it’s administered and how much is administered. So if you're doing in-office sedation and giving it to the patient immediately from your office supply, you don’t need to do the PMP Check. If you prescribe the drug for the patient to pick up and you to administer, then you do need to complete the inquiry before doing so.

We cover a few other pertinent rules in this episode so be sure to listen all the way through! Let us know if you have any questions at toothcop(at)dentalcompliance.com.

Resources & People Mentioned * Rule 111.1 Subsection B * PRESCRIBING & MONITORING PRACTICES * Texas Prescription Monitoring Program * E-Prescribing Waiver * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * Check out ProEdge Dental at https://proedgedental.com/toothcop!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In this episode of Talking with the Toothcop, I share some sobering news that recently happened in Kansas. I’ll also share some important updates that dentists need to be aware of that were highlighted in the Texas State Board of Dental Examiners Newsletter. Stay up-to-date on the latest dentistry compliance issues—don’t miss it.

Outline of This Episode * [0:21] 3-year-old boy dies during dental procedure * [3:13] Get your dental unit waterlines tested through ProEdge! * [4:30] Electronic Prescribing Waiver * [6:03] Texas administrative code Rule 108.7 sub-section 16 * [7:44] Tele-dentistry rule (HB2056) passed * [12:50] Questions about Rule 108.7 sub-section 16 * [14:33] Do dentists prescribe anxiety medication frequently? * [15:26] Learn more about protectIt dental’s emergency medical kit * [16:43] The Professional Recovery Network

3-year-old Boy Dies During Dental Procedure A 3-year-old boy in Wichita, Kansas went in for a simple procedure. He was sedated to have some teeth removed after a gum infection. Unfortunately, something went awry during the procedure and the boy passed away after being transported to a nearby hospital. The incident is currently under investigation though it appears there was no wrongdoing.

However, incidents like these are a sobering reminder to have your dental office prepared in case of emergencies. You need a written protocol in place, your team needs to be aware of their role, and it needs to be referenced as often as possible.

Electronic Prescribing Waiver As of January 1, 2021, the Texas Health and Safety Code 481.0755 dictates that

“Prescriptions for controlled substances be issued electronically, except in limited

circumstances, or unless a waiver has been granted by the appropriate agency.”

The waiver applies to dentists that issue prescriptions for controlled substances—but don’t prescribe many at all. They can apply for a waiver to avoid setting up electronic prescribing. If granted, the waiver allows dentists to write up to 25 prescriptions for controlled substances per year. You can re-apply for your waiver up to 30 days before it expires (it lasts a year from when it’s issued).

Please Note: Many drugs that you may not consider are classified as controlled substances. Do your research and don’t let yourself get caught off guard by this.

Texas administrative code Rule 108.7 sub-section 16 Rule 108.7 sub-section 16 was the COVID rule. It’s now been replaced with what was sub-section 17: You must “Hold a Level 1 permit (Minimal Sedation permit) issued by the Board before prescribing and/or administering Halcion (triazolam), and should administer Halcion (triazolam) in an in-office setting.” Basically, if you want to treat patients with these meds, you must hold a Level 1 permit.

In the newsletter, the featured a question a reader asked, “Can I prescribe or dispense a drug for sedation without a sedation permit?” The answer is no. You have to have a minimal sedation permit to prescribe sedation medications to patients (dosage recommendations in board rules 110.1 and 110.4).

Texas Legislative House Bill 2056 Passes The bill passed on June 16th, 2021. But on August 11th at 1 pm, the Texas State Board of Dental Examiners will host a stakeholder meeting to address the specific rules for teledentistry. This is your opportunity to make your voice heard and shape these rules on the front end. What can you do? Look at other state’s regulations and see what they’re doing and what their recommendations are. Too often dentists don’t get involved when they have the opportunity. If you’re not involved, you can’t complain about it! I think we will see rules formed by March.

Resources & People Mentioned * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * Get your dental unit waterlines tested through ProEdge! * 3-year-old Boy Dies During Dental Procedure * The Texas State Board of Dental Examiners Newsletter * TWT Episode: Electronic Prescribing of Controlled Substances * Texas administrative code Rule 108.7 sub-section 16 * https://tsbde.texas.gov/ * The Professional Recovery Network

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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A lot of people get the Treatment, Payment, and Healthcare Operations (TPO) Exception wrong. So in this episode of Talking with the Toothcop, Andrea and I dissect what it is. We also talk about what to do if you need patient authorization and the importance of informed consent for treatment. Don’t miss it!

Outline of This Episode * [0:21] Coffee + Rom-Coms * [4:07] Learn more about ProEdge Dental! * [5:24] The treatment exception * [10:00] The payment exception * [11:01] The operations exception * [12:14] If you NEED authorization * [13:25] Informed consent for treatment * [17:49] Learn more about protectit dental!

The treatment exception You can communicate with other healthcare providers (i.e. dentists/specialists) to care for a patient (consults, discussions, coordination of care, etc.). Under HIPPA you don’t need authorization from your patient to communicate with healthcare providers regarding treatment. Some state laws are more restrictive. For example, in Minnesota, this does not apply and you are required to get authorization. Federal HIPPA laws allow communication if your state does not have more restrictive requirements.

The payment exception If Grandma stops by to pay a patient's bill, you may have to follow the minimum necessary principle (that a legal guardian is the only one allowed access to patient information). So you may not be able to close the date of service or the procedure but you sure can take payment. If it’s necessary to state a balance to get paid, it’s perfectly fine.

The operations exception The operations exception allows dental offices to access and use/disclose their patient‘s information. You don’t need authorization from the patient or legal guardian. How does that look in practice? Duane is allowed to access a patient’s records without them being notified because it’s for compliance purposes.

If you NEED authorization If you need authorization from a patient to disclose PHI to a third party, there is a form you need them to complete with specific elements that need to be on it. Most information release forms don’t have the necessary information. So what’s needed?

It must clearly identify your entity and who you’re allowed to release information to
What part of the patient’s record you’re authorized to use or disclose
The explicit purpose for the disclosure
A notice that informs the patient they have the right to revoke the authorization at any time (this is what most dental offices are missing)
A signature on the form by the patient or legal guardian

NOTE: Get familiar with your state's recommendations to make sure they don’t have specific requirements for authorizations. If you’re from MN hit me up at toothcop(at)dentalcompliance.com for a template for the form you need!

Informed consent for treatment This seems like an ongoing issue I encounter regularly. Different states have different requirements for informed consent. Common sense dictates—to protect yourself and your practice—you should obtain informed consent from your patients. They should know the potential risks of a procedure and alternative treatments that could be appropriate (including no treatment). They should also be informed of the potential consequences if they choose not to have a procedure done.

If you practice in multiple states, follow the most stringent standard in all of your locations. Then you’ll never run the risk of being out of compliance. In Texas, you need consent for everything that comes with a risk. In Texas, Medicare requires consent for every procedure on the date of service it’s being completed. If you don’t get consent, the insurance companies can recoup what they paid for the services.

Have any good coffee bean recommendations? Send me an email with your suggestions!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Recently, I’ve dealt with some level of confusion surrounding the Hepatitis B vaccinations (HBV) and post-vaccination testing requirements. So in this episode of Talking with the Toothcop, I’m going to cover what both OSHA and the CDC require for the HBV and post-vaccination testing.

Outline of This Episode * [2:03] Hepatitis B vaccination requirements in dentistry * [5:08] OSHA requirements for post-vaccination testing * [10:22] Hepatitis B vaccination recap

Hepatitis B Vaccination Requirements When a dental office hires a new person, they need to determine if that person will have exposure to bloodborne pathogens. Front office staff may have exposure in one dental office and others won’t, whereas a clinical staff will have ongoing exposure. It all depends on the activities of your staff and whether or not they’re cross-trained. But it’s not like a bloodborne pathogen follows the rules and won’t cross into an area they’re not supposed to.

If a new staff member will likely face exposure throughout their employment, they need to be offered the Hepatitis B vaccination. The employer must:

Get a copy of the employee’s vaccination record
If the employee declines the vaccination, they must sign a declination form. (i.e. they may have already had the vaccination).

Dentists, you must show you offered the vaccination within 10 days of hiring the new staff member. Document your attempt to get the vaccination records. Include all of this in your new hire paperwork.

The vaccination is a three-shot series given over six months. At the conclusion, your staff member’s blood needs to be tested to ensure they’ve developed antibodies for Hepatitis B.

OSHA requirements for post-vaccination testing In a 2000 OSHA response to Christopher S. Taylor, M.D. (a flight surgeon), OSHA stated that:

“The employer shall make available the hepatitis B vaccine and vaccination series to all employees who have occupational exposure, and post-exposure follow-up to all employees who have had an exposure incident." (Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, [CPL 2-2.69])

In short, according to OSHA, the employer must pay for post-vaccination evaluation and follow-up at no cost to the employee (2 months after the vaccination series is complete).

In 2015, Richard L. Raimondo, Jr. D.D.S, posed two questions to OSHA.

Once my employees have completed the 3-dose hepatitis B vaccination series, is there a requirement to obtain a test for hepatitis B antibodies? OSHA responded that, yes, a test is necessary for antibodies (according to the CDC).

Dr. Raimondo also asked if anyone hired before this standard was in effect must be tested for antibodies and offered the vaccination series. OSHA responded that at the time, they didn’t recommend further vaccinations or titer testing for anyone vaccinated before December 26, 1997. However, for anyone vaccinated after December 26th, 1997, they did recommend anti-HBs [titer] testing.

Hepatitis B vaccination requirement recap What does this mean for dentists?

Determine who needs to be vaccinated.
Offer them the vaccination and prove you’ve made the offer (i.e. declination form and vaccination record).
Document, document, document. If it isn’t written, it didn’t happen.

Resources & People Mentioned * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * Check out ProEdge Dental for waterline testing! * OSHA response to Richard L. Raimondo, Jr., D.D.S * OSHA response to Christopher S. Taylor, M.D. * Guidance for Evaluating Health-Care Personnel for Hepatitis B Virus Protection and for Administering Postexposure Management

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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This episode of Talking with the Toothcop is a two-parter! In the first half, you’ll get a look behind the curtain and get to know me—Duane Tinker—and my co-host, Andrea Baysinger. In the second half of this episode, we share an important reminder about nitrous oxide compliance rules. Don’t miss it!

Outline of This Episode * [3:01] How Andrea became my co-host * [6:05] I’m an introvert—until I take the stage * [8:09] Andrea is an introvert disguised as an extrovert * [9:29] Country versus city living (who is who?) * [12:22] Raising Australian Shepherds on a ranch * [13:05] Dentists that administer nitrous oxide * [14:31] How dentists get busted for lack of compliance

I’m an introvert—until I take the stage I am an introvert. I’m like Sylvester Stallone (Hawk) in the Movie “Over the Top.” Hawk is a professional arm wrestler preparing for a national event in Las Vegas. At the end of the movie, Hawk is interviewed. He said that before he steps in the ring, he turns his hat backward and it’s like he turns his face and becomes a different person. That’s how I feel when I’m about to walk on a stage and speak. I’m a shy wallflower until I take the stage.

Andrea is very talkative and is a self-proclaimed social butterfly. But she believes it’s just a different version of her. She has a degree in English and loves writing and being introspective. So she’s at her best when she’s chosen to be alone. She feels at peace. She recharges, then gets back out with people.

Country living versus city living My wife and I have a ranch and sometimes I’ll go weeks without leaving it. We’ve got everything we need here (including fast internet). Andrea grew up in the country, too, in a small town of 1,500 people. She thought she was going to stay there for life but she followed her brother to Texas. She packed everything in her Maxima, got a part-time job within two weeks, and has been here for almost 8 years. She’d never in a million years thought she’d end up in a field close to healthcare and now she can’t imagine anything else (including living in the country again).

My wife and I have 6 Australian Shepherds, five of which are related. We have a lot of livestock (sheep, goats, ducks, and geese) because my wife does competition herding with her dogs. Supporting my wife in training the dogs is my extracurricular activity. Plus, there are always things to do around a ranch.

Dentists that administer nitrous Switching gears, I’ve been getting a lot of calls and emails from dentists who are shocked about rules that have been in place for three years now. Many dentists are way out of compliance and don’t know where to start.

How are dentists getting busted for lack of compliance? The state only does inspections for those with level 2, 3, and 4 sedation permits. Those who are administering nitrous will never be inspected for that. But let’s say a new patient comes to see you for a second opinion. You prepare a treatment plan, make your recommendations, and the patient decides to go with you for treatment.

Six months down the road, you get a letter from the state board. They want to copy the patient’s record and the dentist’s emergency plan, and the dentist has no idea what they’re talking about. Nine times out of ten, it’s a complaint against another dentist. That’s how dentists get busted for not having emergency plans. It’s how the conversation starts with me.

Dentists who administer nitrous: What you should be doing What do you need to do? You need to have a written emergency plan in place and train your staff on that plan. You need an AED, stethoscope, blood pressure cuff, backup suction unit, and emergency oxygen unit. Most of the dentists that are calling me had no clue. Luckily, it’s an easy fix.

The takeaway? Be in the know. Get the newsletter from your state licensing board. Visit their website frequently for important information and updates. Get on our email list. We’ll inform you of new rules and regulations. Something is always changing and impacting dental offices.

Need help with compliance? Give me a shout!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In our last episode, we talked about how the Texas State Board allowed their COVID-19 rules to expire. We think it’s a good thing! But a lot of dentists are not happy about it. So in this episode of Talking with the Toothcop, Andrea and I dive a little deeper into the topic. We’ll share why we think it’s a good thing and what dentists can do moving forward.

Outline of This Episode * [2:51] The feedback on the COVID-19 rule expiration * [5:22] You can continue what you were doing * [8:10] Dentists are encouraged to follow CDC guidelines * [11:00] Let us know if you have any episode requests!

The feedback on the COVID-19 rule expiration I’m not entirely surprised dentists aren’t happy with the expiration of the rule. Many dentists want to know what they have to do—they like structure. I thought it was a beautiful thing that the state board was allowing dentists to take the reins again.

But a large cross-section of dentists like the comfort of being told what to do. I don’t entirely understand. I get that you want to focus your energy elsewhere. But I like to be recognized for my ability to think, reason, and make my own decisions. Not everyone feels the same way as I do.

Oddly enough, there were a lot of gray areas when regulations were first announced last year. Dentists wanted clarity. Now they’ve taken clarity away again and it can be overwhelming. So what can you do?

Continue what you were doing We want to be clear. Just because the Texas state board allowed their COVID-19 rules to expire does not mean you have to stop following them. If you—and your patients—were comfortable with the level of safety it afforded you, then by all means stick with it. Work within your comfort level.

However, I believe you need to get comfortable stepping outside of your comfort zone. It’s how you grow. You learn to trust your instincts and your ability to trust your own decisions. As a dentist, you’ve earned respect and you’re recognized as someone qualified to make tough decisions beyond the average person (when it comes to oral health). But everything that pertains to your patient’s health is your responsibility. Don’t be afraid to do your own research and make your own decisions.

Dentists are encouraged to follow CDC guidelines The state board encouraged dentists to follow CDC guidelines but did not instruct them to. It sounds like this governing body understands it’s stressful, so if you want guidance, you can continue to follow the CDC recommendations. But they are giving you room to make your own interpretations. By the tone of the ruling, there is flexibility and forgiveness if you get something wrong.

Any recommendations for requests for our next topic? Let me know at toothcop(at)dentalcompliance.com!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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The Texas dental board let the COVID-19 rule expire (rule 108.7 subsection 16). How does that impact dentists moving forward? What rules do some providers still need to follow? What procedures are still recommended by the CDC? We cover it all in this episode of Talking with the Toothcop!

Outline of This Episode * [3:20] The impact of the expiration of the COVID-19 rule * [4:41] The OSHA Emergency Temporary Standard * [9:25] 1910.504: The Mini Respiratory Protection Program * [16:35] Subscribe to the podcast and sign up for our newsletter!

The impact of the expiration of the COVID-19 rule How does this impact you? Maybe very little. There is no longer a Texas State Board rule that says you have to follow these specific rules. You don’t have to wear N95 masks. You don’t have to do twice daily temperature checks. You don’t have to screen patients and check their temperature. But many of you have gotten used to the process and feel like it’s best to continue. You absolutely can! You get to decide how to care for and keep your patients and staff safe—whatever that looks like for your practice.

The OSHA Emergency Temporary Standard There is an OSHA standard—the “Emergency Temporary Standard”—that was released a few weeks ago and was effective immediately upon release. That means it is an enforceable federal law. Who is impacted by this law? Those who work with people who are suspected of having or confirmed to have/had had COVID-19. This can include employees at:

Hospitals
Nursing homes
Assisted living facilities
Emergency responders
Home healthcare workers
Employees in ambulatory care facilities

It does not apply to non-hospital care centers where non-employees are screened before entry and those with COVID-19 are not allowed to enter. So if you screen everyone that walks in the door, this rule doesn't apply to you.

If it does apply, you must have a written safety plan, patient screening management, transmission-based precautions, PPE, physical distancing, and more. What qualifies as screening? Listen to find out!

OSHA Standard 1910.504: The Mini Respiratory Protection Program When respirator use is required, the respiratory protection standard applies. This requires medical evaluations, fit testing, a written safety program, user seal checks, and training. What does the “mini” version require? User seal checks and proper training. 90% of dental offices are already here.

CDC COVID-19 guidelines are still recommended The state board still recommends finding the CDC guidelines:

Postpone procedures if they aren't medically necessary
Implement Teledentistry and Triage Protocols (doesn’t apply yet)
Screen and triage everyone entering for signs and symptoms of COVID-19
Monitor and Manage Dental Healthcare Professionals (if you’re sick, stay home)
Create a process to respond to COVID-19 exposures among DHCP and others
Implement universal source control measures
Encourage physical distancing
Consider COVID-19 testing for patients and staff who don’t exhibit symptoms (we recommend you don’t do that)
Do things to minimize exposure
Implement universal use of PPE

Familiarize yourself with this stuff!

Resources & People Mentioned * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * The expiration of the COVID-19 Rule * Texas Dental Board Rule 108.7 Subsection 16 * COVID-19 Healthcare ETS * The Mini Respiratory Protection Program * CDC Guidance for Dental Settings * Save the date for bootcamp: Nov. 19th and 20th

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Are you doing proper sedation and anesthesia reviews? Are you making sure you don’t have drugs sitting in your office that expired pre-COVID? Are you checking with a patient’s primary care provider before administering anesthesia? Being busy and overwhelmed isn’t an excuse for not doing your due diligence. In this episode of Talking with the Toothcop, Andrea and I touch on the importance of doing a proper review.

Outline of This Episode * [4:09] Sedation and anesthesia reviews * [8:49] Upcoming anesthesia course

Check for expired drugs and equipment I’ve done a lot of sedation and anesthesia reviews in the last few months, and I can tell that some offices have been quite distracted. Those that have been quite busy aren’t staying on top of the things they should, like an annual inspection of the sedation process and equipment reviews. As a result, I’m finding a lot of expired stuff. They’re lucky I found it—not the state board. You need to be routinely checking to make sure you’re not storing expired drugs.

Sedation and anesthesia reviews You also need to be diligent in your patient screening and selection for anesthesia. Don't overlook even the slightest detail. Get the proper medical consultations done versus just getting medical clearance. “Medical clearance” is not an absolution of viability for you. You can’t just exchange paperwork with their primary care physician. Take the time to document the conversation in your clinical notes (with great detail).

Take your pride out of the equation. Even if you’ve done something 1,000 times, there may be one time something goes wrong. If you can’t prove you’ve done your due diligence and properly screened your patient, you won’t have a leg to stand on. Err on the side of caution. If a conversation happened—but it’s not in your records—it didn’t happen.

Upcoming anesthesia course We have an anesthesia CE course coming up on June 5th from 8 am to 12 pm central, but open to anyone across the US. The course is “Principles and Practices of Dental Office Anesthesia,” taught by Dr. Justin Bonner and Dr. Garrett Starling. If you’ve done the same anesthesia course, change it up. Hearing the same thing from a different perspective might impact you in a more meaningful way. Learn more by clicking the link in the resources!

Call to action: When you get to your office, check the expiration dates on your emergency drugs and all of your equipment. Make sure they aren’t expired.

Resources & People Mentioned * Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you! * Principles and Practices of Dental Office Anesthesia: https://dentalcompliance.com/products/live-anesthesia-principles-and-practices-of-dental-office-anesthesia

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Last week, I read an article about an oral surgeon in North Carolina who got busted after a patient died. So in this episode of Talking with the Toothcop, we’re going to talk about what happened, why it happened, and how it could have been prevented. This isn’t to shame the dentist or staff involved, but to learn from the mistakes that were made. Tragedies in the dental office should never happen.

Outline of This Episode * [0:22] Death in the dental office * [8:50] Get professional help before it’s too late * [13:45] The Professional Recovery Network * [18:21] Your patients may not trust you anymore * [20:20] The current action being taken * [24:15] Upcoming CE courses

Death in the dental office According to the article Leland oral surgeon suspended by Dental Board, under investigation by SBI for drug misuse, Dr. Mark Austin had his license suspended following an investigation by the State Board of Dental Examiners. The patient in question came in for an appointment to receive a dental implant. The doctor administered sedatives before and during the procedure. Unfortunately, the patient’s oxygen saturation dropped significantly, and after attempting to place an endotracheal tube, 911 was called. The patient died a few days later in intensive care.

This prompted an immediate investigation by the dental board. The DEA and state board combed through this dentist’s practice. Even worse, in an earlier audit, the doctor couldn’t account for substances that were supposed to be maintained at his office, including Fentanyl. The investigation also alleges that he used illicit substances personally for two years while practicing.

The patient was at 60-70% oxygen for 20 minutes. Brain death happens when it’s deprived of oxygen for 4–6 minutes. When EMS arrived, the patient didn’t have a pulse. The Dr. had not administered CPR prior to their arrival. His brain was deprived of oxygen for far too long, and he suffered irreversible brain injury and died 4 days later.

Get help—or get busted If you or someone you know is struggling with a drug or alcohol problem, get help. It can be done anonymously before you impact your patient’s lives. Because when a dental board gets involved, they’ll issue an emergency suspension which creates a public spectacle. This situation is attached to Dr. Austin’s license for the rest of his life. Every insurance company he attempts credentialing with will know. Some won’t take the risk. If someone had recognized he had a problem it could all have been prevented.

It’s hard to get help. But when you do, you go to a special rehab just for doctors. You’re there with other dentists or physicians in recovery. You avoid a public stigma while getting acceptance and support. This isn’t about shaming dentists, it’s about getting them help.

It’s sad that a world-renowned cardiologist—someone who devoted his life to helping people—lost his life in a preventable situation.

You have a moral obligation to protect your patients Someone had to have seen the signs in this doctor and did nothing. You can’t hide a drug addiction for over a year. If you work with someone who is struggling, you have an obligation and responsibility to report this behavior. You’re either part of the problem or part of the solution. The staff had a moral and ethical obligation to make a decision. They didn’t make the right one.

The proper training and preparation for something like this could have prevented someone’s death. This is why we’re talking about this. Dental offices need to be taught the right way to do things. A reasonable person should ask, “What could I have done to prevent that?” Sadly, these staff members will carry guilt with them for the rest of their lives.

The current action being taken The dental board received information that Dr. Austin had prescribed controlled substances for staff members—outside the scope of dentistry. The board also received evidence that he was unable to account for controlled substances and had been taking them for two years. In a nutshell, he agreed to a suspension of his license.

Resources & People Mentioned * Leland oral surgeon suspended by Dental Board * Professional Recovery Network (Texas) * Consent Order Suspending License * Dental Compliance CE Courses

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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I recently realized it’s been so long since I’ve played my guitar that the strings have started to rust. It’s sad and embarrassing to realize I’ve let something I love that’s important to me get forgotten. But it made me question: Where do you have rusty strings in your dental practice? Where are you not putting in the energy and effort into things that you should be? Have you let the things that are important to you go to the wayside? In this episode of Talking with the Toothcop, our goal is to bring you back to your current reality.

Outline of This Episode * [0:22] Where do you have rusty strings? * [2:23] You have to sweat the little things * [6:22] Take a moment for self-reflection * [8:26] Get on my schedule for a chat!

Where are your rusty strings? We’ve had a lot of distractions with the pandemic. Because of this, I’ve seen a lot of “rusty strings” in dental practices. People are forgetting to do a step-wedge test for their x-ray machines. They’re forgetting medical emergency training and preparedness. Many people are just going through the motions.

In every sedation inspection that I’ve done recently, everyone has had grossly expired equipment. These people are filling out their checklists but not really paying attention—which defeats the purpose of the checklist! Some of these things expired pre-pandemic.

You have to sweat the little things Think about everything that happened in the last year. All of your energy and focus may have gone into keeping your practice afloat. It begs the question—is there something you can do to prepare for the next pandemic?

When a crisis happens you focus on priority #1. With COVID, it was infection control. But you still have to focus on step-wedge testing and check for expired drugs. You still have to do your OSHA and HIPAA training. These things are basic and don’t require much effort to do. But all of the focus was on the pandemic.

Maybe this won’t happen again in our lifetime, but other things will happen. You need to focus on the things that you still need to be doing and don’t forget the little things, or they will morph into bigger problems. It’s always the little things that fall through the cracks.

Take a moment for self-reflection: mental checklist Take a moment to think through where you’re at right now. Did you do your HIPAA security risk assessment? Have you done your OSHA training? Have you done emergency training? What are the things you need to be doing regularly? Are you on top of everything? What are the things that you’re missing? Figure it out and get back on track.

We aren’t bringing this up to shame anyone. But it’s easy to get caught up in the moment, and it’s important to take a breath and realign. Take a mental inventory, make a list of what you need to catch up on, and execute.

Are you stressed and don’t know where to start? Head on over to DentalCompliance.com and get on my schedule for a complimentary consultation. Just fill out a simple form, and Andrea will get you on my schedule for 30 minutes of my undivided attention. Then you can ask all of the questions you want.

Resources & People Mentioned * FREE 30-minute Consultation

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Who says compliance training can’t be fun—or funny? In this fun episode of Talking with the Toothcop, we take a short break from our scheduled programming to hopefully share some laughs. Plus, we drop some important news about upcoming events. Don’t miss it!

Outline of This Episode * [2:08] Why OSHA training is dangerous * [6:44] An intentional demonstration * [12:19] Bootcamp is coming BACK!

Why OSHA training is dangerous Those who know me know I LOVE public speaking. Recently, I was doing an in-person OSHA/compliance training (which was awesome). I was speaking in a movie theatre and this particular movie theatre had a short stage about one foot off the ground. Toward the end of the presentation, I was talking about medical emergency preparedness.

I like to lean on things and decided to lean on a bar. Turns out, the bar was pretty low—a lot lower than I had anticipated. I ended up awkwardly squatting into a semi-sitting position to learn on the bar. But as I did, I slid back onto the platform and fell on my back. As I’m falling, I’m saying “It’s important to be prepared for unexpected emergencies.” Splat. The audience was confused and perplexed.

I couldn’t figure out how to get back up without looking ridiculous. I managed to sit up and continue my lecture while sitting. I finally figured out a plan to get up and quickly hit the next slide, which said, “We don’t rise to the level of our expectations, we fall—HA—to the level of our training.”

I walked off the stage and made a beeline for the door. People asked the hostess if I did it on purpose and she was like, “Yeah, he does that stuff all the time.”

The takeaway? Come see me speak live! Need a speaker for an upcoming event? Throw my name in the hat!

Bootcamp is coming BACK! Bootcamp is coming back in 2021! The planning is in motion. It will be a two-day event on the 19th and 20th of November. More details to come.

Resources & People Mentioned * Dental Compliance Live Training

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In the first episode of this series, we talked about what a corporate integrity agreement is. In the second episode, we covered focusing on compliance. In this episode of Talking with the Toothcop, we are going to walk through an actual corporate integrity agreement. If you’re caught in the OIG’s crosshairs, this is just one example of what you might expect.

NOTE: These are NOT confidential and are public documents on the OIG website.

Outline of This Episode * [2:15] A pediatric corporate integrity agreement * [9:27] Reach out to us for support * [12:02] Compliance Bootcamp 2021

A pediatric corporate integrity agreement This CIA was executed in August 2016 with a three-year term (a CIA is typically a five-year term). The CIA stipulated that the dentist and all employees and contractors (including billing) had to establish a compliance program that included:

Posting a notice in their office that patients could see—within 60 days of the effective date—that provides the OIG hotline number as a confidential means to report fraud or abuse.
They had to include three hours of training and education for the practitioner and all covered entities within the first reporting period. That may only be satisfied by taking courses provided by the CMS Medicare Learning Network. It must include a billing, coding, and claims submission course and a medical record documentation course. New employees had to receive three hours of training within 45 days of being hired.
An independent review organization was hired to conduct a review of the doctor’s coding, billing, and claims submission to CMS.
Ineligible persons include anyone barred or suspended from participation with federal healthcare programs (this shows the importance of continued exclusions checks). Doctors had to prove that they had checked and tracked that their employees were not on an exclusion list.
For the purpose of this CIA, an overpayment meant the amount of money a doctor had received in excess of the amount due and payable under any federal healthcare program requirement. If an overpayment was identified, they had to repay it to the appropriate payer within 60 days. They then had to take steps to prevent overpayment from happening again. Any paid claim had to be supported with proper documentation.

This CIA didn’t even flesh out all seven elements of a compliance program. Even if the situation is over, it’s still a public record forever.

Get the help you need—now Don’t wait until you’re in trouble to get help. Set up a compliance program to protect your practice so you don’t end up on the chopping block. The prevention is worth it. Just because it hasn’t happened doesn’t mean it won’t. If you’d like to schedule a call with me, call our office at 817-755-0035 to speak with Andrea and set up a Zoom call.

Resources & People Mentioned * Closed Corporate Integrity Agreements * CMS Medicare Learning Network

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In the last episode, we talked about what a corporate integrity agreement is and what compliance programs should look like. In this episode of Talking with the Toothcop, we continue our series on corporate integrity agreements by looking at the OIG’s Focus on Compliance roundtable discussion. If you participate with Medicare or Medicaid, you HAVE to pay attention to this.

Outline of This Episode * [3:23] Corporate Integrity Agreements * [5:21] The focus on compliance document * [8:59] The board of directors * [10:53] The role of the internal audit * [11:26] Claims review requirements

Corporate Integrity Agreements Just to recap, according to the OIG, a corporate integrity agreement is “Part of the settlement of Federal health care program investigations arising under a variety of civil false claims statutes. Providers or entities agree to the obligations, and in exchange, OIG agrees not to seek their exclusion from participation in Medicare, Medicaid, or other federal healthcare programs.”

A CIA usually remains in effect for five years. If you don’t agree to this, you lose the ability to participate in federally funded programs. If Medicare or Medicaid represent a large cross-section of your business, you could lose your business by losing the ability to work with them. It’s a large reason why organizations agree to CIAs. CIAs have evolved into what they are today.

Focus on Compliance: The Next Generation of Corporate Integrity Agreements In 2012, the OIG held a roundtable discussion with stakeholders with entities and organizations that were under an active CIA to get feedback. The goal was to tweak CIAs to make them more effective to organizations.

In this discussion, the CIAs required each participant to have a code of conduct setting forth their commitment to compliance. They also had to implement policies and procedures governing the compliance program and adherence to program requirements.

A code of conduct is a great foundation for a compliance program and establishing policies and procedures. Your written policies and procedures should address each of your risk areas. The OIG now leaves it up to the organization to identify what topics you need further training on based on the CIA. So they’re moving away from an hours-driven training program to topic-driven. The government is responding to and taking feedback on some of their requirements.

The board of directors involvement We do work with some dental partnership organizations and DSOs. CIAs require that the board of directors also receive training, reports from the compliance officer, and pass an annual resolution certifying the board is overseeing the compliance program.

The board’s responsibilities result in more engaged board members, which assists in the allocation of resources to mitigate risk. An engaged board motivates executives and healthcare providers to commit more fully to compliance.

I spend a lot of time working actively with boards and compliance committees and I see this. It takes a few meetings to see people get why it’s necessary. Once things click, I become more of a silent presence and less of the person leading the charge. This is how it should be.

What is the role of an internal audit? Why is it so important? Listen to learn more!

Claims review requirements Most CIAs require the provider to conduct a discovery sample of 50 paid Medicare claims randomly selected from those submitted by the provider during a specified 12-month period. If the error rate is 5% or greater, the provider must conduct a full sample systems review—which is far more involved.

When an organization is under a CIA, they have to maintain an error rate of less than 5% in their audits. Based on my experience, this is difficult to accomplish. I’ve been doing record audits for over 10 years and the average error rate is north of 15%. Why? Because auditing processes aren’t in place and people don’t go back and check for mistakes.

The average dentist thinks they don’t make that many mistakes, but unless you do audits and have definitive proof, you don’t know. If you’re playing the Medicaid/Medicare game, you’ve got to know that your error rate is below 5%.

You’re not expected to have a full-time compliance officer in place—but you are required to have auditing and monitoring processes in place. So if you’re a small dental office, you must pull and audit at least 50 coding and billing records a year.

Need help with this process? Send me an email and I’ll share some samples of overpayment lists.

Resources & People Mentioned * TWT Episode: The 7 Elements of Dental Compliance Programs * Focus on Compliance * HHS Compliance Resources * LIVE Compliance Training

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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This episode is the beginning of a series about corporate integrity agreements. One of the important elements that is part of a corporate integrity agreement is implementing a compliance program. Why is it so important to have a compliance program? What should it consist of? How can a compliance program save your practice? Find out in this episode of Talking with the Toothcop!

Outline of This Episode * [2:40] Corporate integrity agreements * [4:41] Compliance program guidelines * [6:48] Why you want to implement a compliance program

What is a corporate integrity agreement (CIA)? A corporate integrity agreement addresses a specific issue while attempting to accommodate or recognize the elements of compliance programs. A CIA typically lasts for five years with a certain amount of requirements attached. What are those requirements?

The organization must hire a compliance officer and appoint a compliance committee
They have to develop written standards and policies
They must implement a comprehensive employee training program
Retain an independent review organization to conduct annual reviews
Establish a confidential disclosure program
Restrict employment of eligible persons
Report overpayments, events, ongoing investigations, and legal proceedings
Provide implementation reports to the OIG on the status of compliance activities

A large part of demonstrating compliance is creating a compliance program. What should that consist of?

Compliance program guidelines The OIG provides compliance guidance documents for the healthcare sector, including dental practices. Regardless of what sector of healthcare you’re in, these compliance guidelines center around 7 elements of compliance:

Conduct internal monitoring and auditing processes
Implement written policies and procedures
Designate a compliance officer and compliance committee
Conduct effective compliance training and education
Respond promptly to violations and take timely corrective action
Develop effective lines of communication
Enforce standards through well-publicized disciplinary guidelines

A corporate integrity agreement is agreeing to create a compliance program—with the added bonus of a babysitter, the independent review organization.

The best way to learn is from others' mistakes, right? It’s less painful and less costly. Compliance programs are NOT cheap. The government wants you to feel the pinch. They expect you to invest time, money, and effort into compliance.

Why you want to implement a compliance program Long before the OIG came out with guidance, the US Judiciary came up with federal sentencing guidelines that existed for different types of crimes. Chapter 8 deals with healthcare fraud. The OIG compliance guidelines come directly from these US Federal Sentencing Guidelines.

If an organization gets busted for something—but has a reasonably effective compliance program in place—it can reduce fines and penalties up to 90%. When an organization is busted, the government's first ask after an audit is the highest amount. It can be millions of dollars. If you can reduce that by 90%, it can take $1 million down to $100,000. That’s a big deal.

That is where your return on investment comes in. An effective compliance program will pay off. But it’s also my goal that our clients never realize this investment. These are systems that you need to implement. When it comes to compliance, there’s no such thing as “Set it and forget it.”

Resources & People Mentioned * LIVE Compliance Training * Compliance Guidance for Individual and Small Group Physician Practices * Compliance Program Guidance for Third-Party Medical Billing Companies * TWT Episode: The 7 Elements of Dental Compliance Programs

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Emergency medical kits are essential for dental practices—but most have a kit thrown under a cabinet that’s stocked with expired medications. Scott Sankary is the Co-Founder at Protect It First Aid & Safety, a company striving to change this unsafe practice. They supply emergency products and monitor expiration dates to keep customers in compliance. What do they offer to dental practices? How is their solution better than their competitors? Find out in this episode of Talking with the Toothcop!

Outline of This Episode * [0:35] Scott Sankary with Protect It Dental * [5:47] Protect It Dental’s EMK series * [8:11] How to become a customer * [14:34] Their subscription-based program * [21:58] How are they different?

Protect It Dental’s Emergency Medical Kits Protect It Dental is best known in the dental world for their emergency medical kits—their EMKs. The kit itself is made of white metal, weighs approximately 9 pounds, is 15.5” by 6” by 10.5”, and has a handle. It’s well-marked as an emergency medical kit. It can be wall-mounted or stored on a countertop. They also have a grab-and-go magnetic wall mount. It’s well organized and everything has a customized slot. There is also a product key on the inside door. The kit is designed to bring order and calm to a chaotic situation.

They have four kits to choose from, each with seven essential medications, consistent with ADA and GADA guidelines.

EMK #1: This is the basic and most popular kit. It includes two diphenhydramine vials, two epi ampules, 1 albuterol, 1 adult EpiPen, 1 EpiPen trainer, 2 naloxone vials, nitroglycerin tablets, glucose, aspirin, ammonia inhalants, a CPR mask, and 2 syringes. If you don’t work with kids or seniors, this kit will work for your practice.
EMK #5: This is the same kit, except the nitroglycerin tablets are replaced by nitroglycerin spray—which is best practice for elderly patients who have swallow reflex issues. If you work with seniors—but not kids—this kit could be a good choice for your practice.
EMK #10: This is the same as kit #1, plus a pediatric epi pen. If you see kids in your practice but not seniors, this is the kit for you.
EMK #15: This is the same as kit #1 + a pediatric EpiPen + nitro spray. If you see both kids and seniors, this is the kit for you.

How to become a customer Protect It Dental allows you to buy a kit, onboard existing medications (using proprietary technology), or purchase individual medications a la carte. But to get the full benefit of their program, you need to sign up for auto-replenishment. The problem is that so few people are willing to commit to sign-up for auto-replenishment because they’re worried about cost.

Those that don’t buy a kit and use the EMK onboarding wizard can ease into it. If you choose to onboard an existing kit, their site will walk you through the onboarding process, which will only take 10–15 minutes. The drugs get entered into the Protect It system so you’re set to get replenished on the medications as they expire or are used. You’ll receive a notification saying it’s time to order and you simply pay as you receive replenishment medications.

If you’re set up for auto-replenishment, you receive products 30 days before their expiration date. It comes with a postage-paid disposal bag to ship to their third-party destruction source.

The subscription-based program Protect It Dental is now offering one-year or two-year subscription options. If a dentist chooses to continue to a second year after the first, they convert them to the two-year pricing and so on.

When a customer purchases a kit, all meds and supplies are pre-loaded into their system and management is simple. The subscription program solves everything. They receive a new kit for a single monthly payment. As items expire, new ones arrive and old ones can be disposed of.

Even if drugs are used—and not just expired—the replenishment is also included in the subscription program. They made it easy and cost-effective to acquire a new kit and enroll in the auto-replenishment program. You shouldn’t have to worry about expiration dates and constant monitoring—Protect It can do it for you. The solution makes it really easy for dental practices to say “yes.”

The dentist’s investment is being protected. Patients are being protected. Some of these medications are life-saving. This subscription is eliminating apprehension and providing dentists with quality care. This is hard to compare to other options out there.

What sets Protect It Dental apart? Protect It Dental is privately owned and there to serve the dental practice—not a shareholder. They’re small, innovative, and high-tech. They have in-house developers and custom programming to fit their business. What they do is driven by conversations with customers and prospects. They’re a small business supporting small businesses. Their pricing is customer-friendly and they have a genuine desire to help people.

Resources & People Mentioned * Scotts Phone #: 817-800-9541 * Scott(at)ProtectItNow.com * Scott Sankary * Protect It Dental * EMK Kits * Onboard Existing Meds * Individual Medications

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Are you cultivating a culture of compliance in your dental practice? Are you careful about what you post on social media? Are you staying on top of X-ray machine maintenance? In this episode of Talking with the Toothcop, Andrea and I dive into some important compliance reminders you need to be mindful of—especially because OSHA is cracking the whip.

Outline of This Episode * [3:21] It’s time to create a culture of safety * [4:59] A brief social media etiquette guide * [6:22] OSHA is stepping it up * [8:14] How to maintain your X-Ray machine * [12:35] The topic of patient selection * [15:18] What to do before administering Nitrous

OSHA is stepping it up On March 12th, 2021 OSHA sent out a news release that said they launched a program to protect workers with safety concerns. OSHA is stepping up its enforcement efforts and protecting workers’ rights to a safe work environment.

It’s time to take this stuff seriously and step up your game. Don’t look for loopholes—get this stuff done. We are seeing a shift under the new administration to enforce these things. If you get busted, it will be considered a serious violation. If you’re willfully negligent, it could be up to a $150,000 fine for a single violation. They are out for blood.

A brief social media etiquette guide I’ve gotten some questions about whether or not practices should post specific photos on social media. Before you post photos on social media, make sure you get signed releases from patients. Secondly, make sure anyone in the photo is wearing the proper PPE based on what the situation looks like—not what it is. We are still in a pandemic, so you better be wearing your respirator and other PPE whenever required. Rember, anything posted on social media can be evidence for anyone to use against you.

Maintain your X-Ray machine There are things you need to do regularly to maintain compliance with your office’s X-rays and to pass state inspection. I recently got a call from a client with an inspector in their office. I dropped everything to walk them through the situation. I talked directly with the inspector and directed her to the information that said what they were supposed to be doing. But it shouldn’t have come to that. The office luckily didn’t receive a fine but got slapped with a violation.

You have to use a multi-dimensional device or commercial device (i.e. a phantom or step wedge) with every sensor. You must test every sensor on every machine. The distance with the sensor and the cone head must be consistent every time you do the test to control variables. You have to do the same test with the same equipment with the same settings every single time.

What is the best way to do it? Listen to learn more! If you’re still confused, shoot me an email if you have questions! I’m happy to help.

The topic of patient selection Just because someone walks into your office doesn’t mean they're your patient. They become your patient when you examine them and create a treatment plan for them (in Texas). If your first interaction is with the patient and some red flags come up, do not move forward. You can send them another dentist and go your separate ways.

But once you plan their care and present them with a treatment plan, you can only dismiss them with proper mechanisms (so you’re not “abandoning” a patient). Listen to your gut feeling. These patients are the types that sue you or file state board complaints. You may have a huge compassionate heart—but you must protect it. Don’t take on patients that you shouldn’t.

Listen to the whole episode for more tips on creating a healthy work culture and a reminder of what you should be doing before administering nitrous!

Resources & People Mentioned * The National Emphasis Program * Risk Management and Record Keeping Course (w/Laura Diamond) * X-Ray Dental Compliance Episode

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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If you fail to follow the infection control protocols that you KNOW will prevent the transmission of disease, you’ll find yourself dealing with an infection control breach. In this episode of Talking with the Toothcop, India Chance, Michelle Strange, Andrea, and I wrap up our conversation on infection control breaches. We talk about posting on social media, the CDC’s steps to evaluate an infection control breach, and things you can easily implement to prevent infections in your dental office. Don’t miss it!

Outline of This Episode * [0:35] Don’t advertise your mistakes on social media * [8:51] The CDC’s 6 steps to evaluate an infection control breach * [14:45] Your duty to report extends beyond saving your reputation * [17:35] Get a fresh perspective on your infection control practices * [25:16] Why you should implement video cameras in the dental office

Do NOT do this on Social Media Michelle has seen dental professionals advertising their mistakes flippantly on social media. One person said they were reusing single-use items and just throwing them in their autoclave. This same person also wasn’t wearing and using utility gloves when necessary. But when something happens in that person’s office and they have a breach, anyone can look on social media and demonstrate a history of non-compliance. Why are they advertising their infection control breaches? Nothing is stopping someone from taking a screenshot and taking that to the state dental board.

India has never had a dental board inspection based on a post on social media. However, class action lawsuits immediately scour social media for breaches that could be used in their case. Anyone suing a dentist will look at social media and they’ll tie-in infection control breaches to whatever the complaint is.

The CDC’s 6 steps to evaluate an infection control breach India recently saw a practice post a video on their YouTube channel (and Facebook). It was a training video with multiple practitioners learning how to do procedures. There were probably 15 people in the different operatories. The problem? There was an egregious amount of infection control breaches in the training. She was so shocked they posted it online.

The CDC outlines six steps to take when an infection control breach happens:

Identify the infection control breach: In the video India mentioned, they weren’t using sterile water, only half of the people were wearing masks, and they reused single-use items in surgery.
Gather additional data: What was the timeframe of the breach? Which patients did it impact?
Notify key stakeholders: Notify infection control professionals, risk management, health departments, healthcare providers, etc.
Perform a qualitative assessment: Categorize your errors and identify risks.
Make decisions about patient notification and testing: What patients were impacted? What is the risk of transmission? Do you have a duty to warn patients and the public?
Figure out communication and logistical issues: How and when will you notify the affected patients? Inform them if they’ll need testing done. Have a plan in place to answer media inquiries.

What will you implement to prevent these breaches from happening again? You have to show that you’ve done your due diligence. If you don’t hire an infection control specialist, the CDC has checklists and even has an app. Do something to get ahead of infection control breaches and protect your staff and customers—and reputation.

Get a fresh perspective on your infection control practices Sometimes, infection control coordinators are too close to the issues at hand. You may have no idea that you’re a few degrees away from where you should be. But a fresh set of eyes can give you a completely different perspective. You don’t have to hire one of us. But, you could work with another practice to trade a staff member or OSHA safety coordinator to do inspections.

India recommends that you get an admin without clinical experience to take the infection control checklist and do an inspection. They’ll follow whatever is written down word-for-word. They don’t have a bias because they’re going off that checklist—not experience.

We all agree that a professional can complete the most accurate assessment. They can help you shift and pivot in the right direction. But no matter what, you need buy-in from the doctors and all other employees. How can you foster that buy-in? What can you do to give your staff consistent reminders? Listen to hear our thoughts!

Implement video cameras in your dental office What about putting a video camera in the dental office? When I was a cop, having a body cam saved me many times. Quality control is so important—and the camera doesn’t lie. A video that you can watch can help you understand context when something doesn’t seem right. It’s why I recommend dental practices put video cameras in operatories and sterilization areas. This can give you an added layer of quality control accountability. It can show you where you’re weak and where things need to be addressed.

All of the major sports teams film the entire game. They watch it, look for areas to address, and learn and improve. Hospitals and doctor offices use these “extreme” measures. Having oversight won’t hurt you—it will help you. Listen to this episode for our entire conversation around handling infection control breaches and learning what you can do better.

Resources & People Mentioned * Level Up Infection Prevention * Evaluating an infection control breach

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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What qualifies as an infection control breach? What is the easiest way to prevent them? In this episode of Talking with the Toothchop, India Chance and Michelle Strange return for a conversation about infection control breaches. We talk about what they are, why we can’t ignore them, and how we can do our part to prevent them.

Outline of This Episode * [7:05] What is an infection control breach? * [13:11] Have written protocols in place * [15:56] The most common infection control breach * [21:30] Why training + preparation is important

What is an infection control breach? A breach in infection control is when there is a lapse—a failure to break the chain of infection—that impacts patients and employees. You have to recognize that there was a failure and notify those who were affected.

In 2013, the dental board in Oklahoma exposed Dr. W. Scott Harrington for unsafe practices in his dental office. One of his patients contracted HIV from his unhygienic practices and up to 7,000 others were exposed to hepatitis B, hepatitis C, and HIV.

It’s not always egregious or newsworthy breaches. It can be a corner that got cut. It can be something that got dropped on the ground. These protocols aren’t just in place to protect patients, they’re in place to protect staff as well. The bottom line is that the medical field doesn’t mess around with infection control breaches—neither should dentistry.

Have written protocols in place All of us run into difficult conversations with staff about personal hygiene—even something that seems as silly as wearing nail polish and fake nails. It’s uncomfortable. Plus, research has been done on how nail beds with chipped polish and artificial nails are perfect reservoirs for bacterial loads. It’s why India and Michelle encourage dental practices to have written protocols in place for personal hygiene. It’s less of a headache when you have a policy and it isn’t just “anything goes.”

Common infection control breaches I think the most common infection control breach I see is with sterile processing. Michelle got a call from a dental office with a big sterilization breach that had to do with a malfunctioning sterilizer. They weren’t doing the necessary prevention protocols.

India sees a lot of little small breaches like someone cutting corners or simply weren't sure they were doing things correctly (and they weren’t…). But she agrees that the large breaches where patients must be notified seem to be with sterilization.

Michelle sees a lot of needlestick injuries. Michelle once witnessed a hygienist get punctured by a tip and was bleeding. Her reaction was “Oh I’ll just wash my hands” and didn't get a medical follow-up. Luckily, she wasn’t working with a patient. Her exposure could’ve been far worse, especially because a lot of dental practices don’t take adequate medical histories.

Many dental offices don’t use the health history section of their digital charting much—if at all. If you do have one of those injuries, you need to have a grab-and-go kit in place. You just grab it and head to get medical attention.

At LevelUp, they’re training infection control coordinators to do that across the board. Regardless of the injury or hazard, they have a grab-and-go packet for medical attention. No one wants to have to dig to reference infection control protocols—have it ready.

Why training + preparation is important When I do OSHA and infection control training, I talk about what an occupational exposure is as well as what steps to take after exposure. But I don’t want you to have to remember the protocol. The sad truth is that if you know what to do, you’ve dealt with it too many times. You need to do a root cause analysis and find out why it keeps happening. Is it a systemic failure? Was someone just not paying attention? Was someone not wearing PPE?

More training needs to happen upfront before you even touch a patient so dental staff aren’t questioning what to do if something happens. We need to do our part to train our staff with the correct protocols, infection control programs, standard operating procedures, etc. We need to have written policies, and reinforce a culture of compliance.

Dental practice owners need to understand the cost analysis with infection control breaches. Occupational hazards are so expensive to deal with. They don’t know how much more it’s costing them. Safety is good for business. Prevention is less expensive. It will save you time and money. We must shift the perspective in infection control breaches from the standpoint of reacting to one of prevention.

Tune in next week for the rest of our conversation about infection prevention!

Resources & People Mentioned * Level Up Infection Prevention * Evaluating an infection control breach * Story on Tulsa Dentist

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Why is the role of an infection control coordinator so important? How do you simplify safety so any dental office can appoint an infection control coordinator and properly train them? In this episode of Talking with the Toothcop, Michelle Strange and India Chance join Andrea and I to talk about the importance of having an infection control coordinator in your dental practice.

Outline of This Episode * [2:17] The importance of an infection prevention coordinator * [6:27] Who should fill the role of ICC? * [11:41] Teamwork makes the dream work * [21:00] How to communicate effectively with your team * [29:21] Do you need an infection control coordinator?

Simplifying the role of an infection control coordinator Let’s face it—the role of an infection control coordinator can be overwhelming. Infection control and OSHA guidelines, rules, and regulations have a lot of nuances. When people are overwhelmed, they tend to do nothing. So India and Michelle created the Level Up Infection Control podcast + company to create a community of support and simplify the role of an infection control coordinator. They share step-by-step how-tos and useful information and take you as the listener on a journey as if they were training you in-person.

Who should fill the role of ICC? India and Michelle note there are a few things to consider, namely—who is interested? Do they have time to give outside of their clinical hours? Who wants to do it? A clinical background is important, but you can’t assign this role flippantly. They need great communication + problem-solving skills and can hold others accountable. You have to know your team members.

What if you don’t have someone that wants to take on the role? At this point, India points out that it makes sense to pick a clinical team member. A lot of the protocols and systems deal with the clinical side. You need experience with that to successfully implement those protocols and mandates.

The infection control coordinator role itself and what you have to manage can be extensive at times. The key to infection prevention is that it must be implemented daily. You can't let things build up and only review once every three months. Patients are looking at dental practices. OSHA is following infection control and prevention closely. Regardless of who you choose, they need proper training.

Teamwork makes the dream work Getting things done comes down to delegation. If you’re the infection control coordinator, you don’t have to implement the whole program yourself—you can delegate. But the bottom line is that you chose to go into healthcare. You have to find the time.

Michelle and India concede that it is a lot of time on the front end as you create processes, systems, and standard operating procedures. But as you start to become unconsciously competent you start to just “do it.” Creating a team approach where everyone knows their roles, will save you time.

Developing unconscious competence How do you develop unconscious competence? How do you foster a team approach to infection prevention? Michelle shares that she once strolled into a room after a patient and threw the instruments that were used in the ultrasonic. But she got distracted and forgot to turn it on and run it. A new assistant pointed out that she forgot to turn it on. If she hadn’t said something, Michelle would’ve created a breach in infection control.

You have to have a team that notices and comes alongside to help you if something is missed. You have to keep each other accountable to keep your patients safe. The moral of the story is that you have to have an infection control coordinator role, but it is a team effort to implement an infection control program. If you’re committed to a team approach, each person helps to carry the load.

India emphasizes that infection control isn’t just about protecting the patient—it protects you as the clinician as well. This role protects every single stakeholder in a dental practice. It’s not your job to be the sheriff. But you must deliver the information in a way that is supportive, encouraging, and promotes change.

So how do you tactfully but firmly let someone know it’s time to make a change? How do you communicate with people that don’t like change? How do you motivate them to be changemakers? Keep listening to hear India and Michelle share their thoughts.

Resources & People Mentioned * Level Up Infection Prevention * Level Up Infection Prevention (podcast) * A Tale of Two Hygienists (podcast) * OSAP Infection Control Coordinator Role

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Dr. Lisa Kane is to New England what I am to Texas. She is THE compliance guru. She practiced dentistry for 20 years before switching to consulting. After years of dealing with migraines from leaning over patients, she made the move—which she’s done for the last four years. She’s always loved the business side of dentistry and it was the perfect fit.

Outline of This Episode * [0:21] Dr. Lisa Kane joins the Toothcop * [3:50] Compliance, education, PHI, & civil rights * [7:58] What people misunderstand about consultants * [9:44] What Dr. Lisa Kane offers with consulting * [12:43] Are peers receptive to her feedback?

Compliance, education, PHI, & civil rights Dr. Kane spends her time opening people’s eyes to regulations they need to follow. Before the COVID pandemic, no one took infection control and OSHA guidelines seriously. In Massachusetts, whatever the CDC says you must follow. In Texas, the state board requires the use of N95 respirators. It’s been hard educating people on the science behind these regulations and that it is actually for their health.

At the same time, there’s an intersection between protecting one’s health and protecting their civil rights. I worked with a hygienist who is hearing impaired and reads lips. When a patient is wearing a mask, she can’t communicate. Where is the line between protecting oneself and overcoming civil rights issues? Where is the intersection between conflicting regulations? Sometimes, there’s no good answer.

What people misunderstand about consultants People don’t always understand that Dr. Kane is there to help. She doesn’t go into a dental office and bark orders like a drill sergeant. She’s sure to point out that the process is a conversation. She is sharing the regulations and what you need to do and it’s up to the dentist to make decisions for their office. She’s giving them protocols and walking them through the things that are daunting.

If someone comes into your office, you have to keep them safe. You don’t want to say “I didn’t have time” when faced with consequences for not keeping a patient safe.

What Dr. Lisa Kane does Dr. Kane typically starts by running an infection control or OSHA class for a practice. Then she walks through the dental office and recommends board regulations (OSHA and CDC) to implement. She does a lot of explaining with staff (i.e. why they need to wear gloves) and helps them brainstorm how to do things safely.

She can also help implement monthly protocols, run safety meetings, keep OSHA handbooks up-to-date, and more. She does a lot of fit testing for masks as well. She has partners that offer CPR and HIPAA training.

Are peers receptive to her feedback? Dr. Kane can say that she has been in their shoes and knows what it’s like to have to juggle this stuff. Whereas I was a cop, and was the enforcer of rules. Dr. Kane finds that people are appreciative of her experience and that she can form a connection with practice owners. They know that she knows what she’s talking about.

Want to learn more about Dr. Lisa Kane and what she offers? She just launched a newsletter that will highlight protocols and why you need them. Check it out! And be sure to sign up for our email list to stay up to date on the latest regulations.

Resources & People Mentioned * Connect with Dr. Kane on LinkedIn * Dental Office Compliance of New England * Sign up for Dr. Kane’s Newsletter

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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We like to provide clients all the materials they need to prepare for the next calendar year. We usually try to get it to them before Christmas, so it’s a sort of Christmas present. One of the things we include in this packet is a blank master chemical list. We’ve been getting a lot of questions about this list, as well as establishing a code of conduct. Listen to this episode to learn about both of them!

Outline of This Episode * [0:40] A compliance Christmas present * [5:11] Nail down your code of conduct * [7:29] Maintain a master chemical list * [9:37] The lowdown on safety data sheets * [11:10] Check out our live training!

Nail down your code of conduct If you participate with Medicare, Medicaid, Tricare, or other government programs, you need to have a written compliance plan that includes the seven elements of compliance. It’s a supplemental document to your office policies and procedures (employee handbook, SOPs, OSHA policies, HIPAA policies, compliance policies, billing protocols, etc.).

It’s impossible to have written procedures for every scenario that may occur in the dental practice. So this supplement establishes a decision-making framework for your staff in the absence of a policy or procedure. They are principles to follow to reason through any situation. In short, it’s a behavioral guidance tool.

To remain compliant, this code of conduct needs to be reviewed by your staff at least annually. It should be part of the new-hire process and repeated with everyone in the practice—doctors, clinical staff, and administrative staff. You have to read it, discuss it, and sign off on it.

Whether a signed form goes in each employee record or a compliance manual, you just need to be consistent. You have to be able to prove that you have a reasonably effective compliance program in place.

How to maintain a master chemical list Another thing we include in the update packet we send is a blank master chemical list. Why? Because you need to know what chemicals are being used in your practice. They need to be accessible in the event of a power failure. If you prefer to keep things online, make sure you can access it on your cellphone or have it transferred to a thumb drive for easy access. If you can meet that threshold, you should be good. You can delegate this to a staff member or OSHA coordinator, as long as someone knows where it is.

Safety data sheets We've been getting questions about where to store safety data sheets. Does it have to be printed? Can it be online? The short answer is that it can be online, but needs to be maintained in the office as well. It should be a table of contents for your practice.

In 2012, we migrated to a DHS system in which they had standardized the format for safety data sheets. Before this, they had been known as material safety data sheets (MSDS). The formatting is now consistent. If you have printed MSDS sheets, it’s time to upgrade them to the proper format.

Resources & People Mentioned * LIVE Compliance Training

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Needlestick injuries have been cropping up again in the last few months. These injuries are considered “occupational hazards” in dentistry—but should they be? Why is it happening? What’s the contributing cause? In this episode of Talking With The Toothcop, Andrea and I talk about this costly “never event” and how to best prevent it.

Outline of This Episode * [0:52] The protocol with needlestick Injuries * [5:25] Coordinating testing with patients * [8:20] Annual Sharps Evaluation + Usage * [10:59] Live OSHA Safety Coordinator Training

The high cost of needlestick injuries The CDC came out with some statistics that said the average needlestick injury costs $700–$750. That’s a load of crap. If you can’t get a negative test from the source patient, the employee must be treated as though an infection occurred. The post-exposure treatment includes taking costly antiviral medications.

If a hygienist slices their fingers open or someone gets poked by a root tip, you have to ask the source patient to get a blood test. But OSHA doesn’t outline who pays for the patient’s blood draw. I recently helped an office with a patient that didn’t want to get a blood draw. I followed up to understand what her concerns were. Turns out, she didn’t mind doing the blood test—she just couldn’t afford it. So we arranged transportation and the practice paid for the blood test. It saved a lot of headache—and medication usage—for the employee.

Andrea points out that the majority of people understand that you’re human and make mistakes. They’re willing to do the right thing and are reasonable. You just have to be honest. Some of the recent incidents have involved pediatric patients. It’s uncomfortable to have to ask a parent to take a child for a Hepatitis B or HIV test but it’s a conversation you have to have.

Start taking preventative measures While it’s considered an occupational hazard, a needlestick injury is a “never event” that should never happen. Sharps containers should be located as close as feasible to the point of use. One simple thing that could be implemented is having the doctor break down their own needle. At that point, the odds of a staff getting stuck with a needle go down to almost zero. But a lot of dentists would rather have their staff do it for them.

Proper sharps usage is imperative It’s clearly defined under the bloodborne pathogen standard that dental offices must use sharps with engineered sharps injury protection (SESIPs). These needles have a built-in safety mechanism that reduces exposure. There are only two products that meet this threshold. One is the Verena SimpleCAP. The other is the Septodont Ultra Safety Plus XL Safety Syringe.

We recommend doing a yearly sharps training to educate your staff on how to properly use needles. Make sure all non-management clinical staff that works with these needles participates in the annual evaluation. Keep those records with your OSHA training records.

Resources & People Mentioned * Live OSHA Safety Coordinator Training * Measuring the Cost of Sharps Injury Prevention * Septodont Ultra Safety Plus XL Safety Syringe * Verena SimpleCAP

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In this episode of Talking with the Toothcop, we’re sharing a few more important reminders and things to stay on top of in 2021. This includes evaluating X-ray equipment, quarterly water testing, new CE requirements, completing CPR courses, and handling your exclusions monitoring. Why is it so important to stay on top of these things? Find out in this episode!

Outline of This Episode * [2:27] X-ray equipment * [6:26] Quarterly water testing * [7:53] Human trafficking CE * [9:51] CPR courses * [12:04] Exclusions monitoring

Do NOT neglect your X-ray equipment Texas has some of the most stringent enforcement in the country. X-ray rules were updated in 2019 and effective today. If you have digital X-ray machines, you’re required to have a Quality Assurance/Quality Control (QA/QC) process. That means you need to get out your X-ray manual and do an equipment performance evaluation (EPE).

For 2D technology, you must do this evaluation within 2 weeks of installation and every four years. If you have a 3D X-ray machine, the evaluation is required within 30 days of install and every year thereafter (in a time-period no later than every 14 months).

If you miss the inspection, you may get lucky with a slap on the hand. If it happens again? A $4,000 fine. Don’t mess this up.

Get your quarterly water testing completed Now would be a great time to do quarterly water testing. You want to make sure that your output meets safe drinking water standards (500 CFU or less). It doesn’t matter what treatment protocol you have—you need to verify it’s working properly with water testing. You can do it yourself, or mail a sample off. If you don’t have one in place, I recommend ProEdge Dental.

Complete a hands-on CPR course The state audits 5% of all licensees every year in the state of Texas. This year, people are getting busted for not completing the hands-on CPR courses. You can’t try to sneak by with the online-only courses. You have to do a hands-on skills evaluation or it will be rejected. If they reject it—and you waited until the last minute to complete your certification—your license may expire. That could mean you’re practicing without a valid license, which is punishable.

The bottom line? Track your credentials. We know they all expire at different times, so set up a calendar and plan. Make sure you meet your requirements for the year. You can also compile the expirations for all of your staff and get a reminder in the calendar 45 days before. Don’t wait until the last minute.

Exclusions monitoring If you work with Medicaid, a federally qualified healthcare center, private dental practice/DSO, and you provide service to Medicare or Medicaid patients, you must do exclusions monitoring. Check before you hire someone and every month after hire. The more frequently you check, the fewer claims will be affected. If one of your staff members is on the exclusions list—even if they’re administrative—every claim filed will be tainted. You might have to return hundreds of thousands of dollars of claims that have been paid to you. Minimize your risk by doing your due diligence. Check every doctor and staff member monthly, no matter their role.

Resources & People Mentioned * Pro Edge Dental * OIG Compliance * Toothcop Compliance Training * Human Trafficking Training

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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What’s new in 2021? CE requirements are changing, PMP self-query rules are in effect, and e-prescribing has officially kicked off. Andrea and I talk about all of the changes—and where to learn more—in this episode of Talking With The Toothcop. Don't miss it!

Outline of This Episode * [0:21] The first episode of 2021! * [2:26] PMP Self-query * [4:20] Check patient history * [6:04] E-prescribing rules * [9:07] NEW CE requirements

PMP Self Query According to Rule 111.2, if you have a DEA registration (or multiple) you’re required to check your prescriber history at least once a year in the PMP platform. Login and enter the dates you wish to check. You don’t need to document it—the state automatically records that you’ve checked. If you don’t, you may end up in front of the state board for lack of compliance. In Andrea’s words, “Check yourself before you wreck yourself.”

Diligently check patient history As of March 1st, 2020 every time you prescribe a controlled substance you have to check the patient’s history in the PMP. This can be delegated to another staff member to do (under their login—not yours). This helps you make an informed decision about what to prescribe.

E-prescribing rules in Texas Effective 1/1/2021, Texas dental providers are required to e-prescribe. There are standalone systems available or some that tie into your current software (linked in the resources). It’s not cheap, but you need to do it. The state board does allow for some exceptions, including if you prescribe fewer than 25 prescriptions a year (i.e. all of 2020).

NEW CE requirements Dentists used to be required to take a two-hour CE course every three years regarding opioid and controlled substance use in their dental practice. As of 9/1/2020, dentists with a DEA registration need to take a course on prescribing and monitoring controlled substances.

Rule 104.2 takes effect 1/1/2021: every dentist with direct patient care responsibilities must complete two hours of education per year—or four hours per renewal period—on pain management. Duane has hired some clinicians to teach this course, check out the resources for the link to our training!

If you took the old prescribing and monitoring course on or before 8/31/2020, it’s completely different from what’s required after 9/1/2020. You have to take it again. Secondly, if you don’t have direct patient care responsibilities (i.e. you’re a consultant with a dental license or a teacher) you don’t have to do the training. The bottom line? If you touch a patient, you should take the course.

Listen to the whole episode for all of the details!

Resources & People Mentioned * Dental Compliance Training LIVE Courses * Texas Administrative Code Chapter 111 * Dentistry Rules + Regulation Changes in Texas * The DEA and Dentistry [Need to Know Updates] * Texas State Board E-Prescribing Waiver * E-Prescribing Waiver Form * iPrescribe * Allscripts * iCoreConnect * Veradigm * MD Toolbox * Surescripts

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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If COVID has taught us anything, it’s given us clarity. The first thing you should question for 2021 is “What do you want?” Dentists are realizing that “I might” or “I should” needs to turn into a solid plan. Do you want to recover losses? Do you want to grow? Do you want to slow down?

Sometimes the best way to implement goals is to have someone come alongside you to help you through the process. That’s where Tonya Burns comes in. Tonya is a consultant working exclusively with pediatric dental practices. Her mission is to empower dental practices to reach success—whatever that looks like for them. Listen to this episode of Talking with the Toothcop to learn more!

Outline of This Episode * [2:20] Tonya Burns: Pediatric Dental Consultant * [3:41] Tonya is MORE than a consultant * [6:33] How to implement goals in your practice * [12:32] What years of consulting have taught us * [29:41] Implementing automation in dentistry * [37:49] Tracking metrics with clients * [39:20] Systems are great—so is accountability * [41:58] Learn how to embrace change * [43:07] How to connect with Tonya Burns

Tonya is MORE than a consultant Tonya feels the word “Consultant” often comes with bad connotations. She wants to change the stigma. She comes into dental practices to help devise plans based on that office's wants and needs. She crafts her approach to each practice and what they’re capable of. She reinvents the wheel all the time. She enjoys being involved in every part of the process, from goal formation to implementation. She’s there to hold them accountable and give them direction. Sometimes she helps them fine-tune their own systems and redesign them.

Her goal is for a practice to achieve their goals without leaving any patients behind. No one should fall through the cracks. A lot of patients falling through the cracks in pediatrics. Why? Because there’s so much volume. You need to identify holes in your practice and fix them before it’s too late. That’s where a wonderful consultant like Tonya can step in and be a game-changer for your people and your business.

Implement SMART goals in your practice Tonya emphasizes that right now is a great time to be in pediatric dentistry. It isn’t feeling the effects like other specialties and general dentistry has. Parents will always do for their kids what they won’t do for themselves. Dental practices are also doing a great job at making their patients feel safe.

Tonya also points out that now is a great time to set SMART goals (specific, measurable, attainable, results-oriented, and timebound). Do you want to recover losses? Do you want to grow? Do you want to slow down? What do you need to do to get the practice in the right position? You should set realistic goals that you can measure and attain. Let your team set some goals as well. What would they like to see happen? Have you realized you need more education to be more efficient?

Consultants CAN empower change Tonya was hired to work with a practice that had a toxic environment. The dentist said, “I just want them to be happy.” The dentist had bought out another office, merged the practices, and told them “This is how it is.” They had broken processes. No one had any respect for each other. There were power struggles. They would even cuss each other out through their headsets.

They worked through the problems and at the end of the relationship, she had all the “mean girls” texting her and thanking her. They didn’t realize how bad they were. The practice turned around and did well. People want to trust who they’re working with. It’s all about finding a connection and making sure you’re a good match. But you also have to walk away from people if you know you can’t help them.

Implementing automation in dentistry Tonya is now helping implement automation in dental offices as part of her consultation service. They take repeatable processes, put a bot into use, and then teach the team how to use it properly. This is a way to work leaner and help your overhead. Robots can do insurance verification, track claims, do payroll, and even send claims and statements. They’ve now taught the robots to read EOBs and they should be able to post payments soon. You can program the bot to do anything that you want.

But they still need a human running them. Implementing automation removes human error with small things and removes things that offices hate doing. It can clean up the process and streamline it. It all happened because Tonya met a pediatric dentist whose husband owned an automation business. She started helping to program them to work with a team in an office. Now they’re going live with clients.

How long does it take to implement? If you want the robots customized to your practice—which is what Tonya advises—then the process takes about two weeks from testing and implementing to using.

Wonderful things are coming for the pediatric community. Listen to the whole episode for the full conversation about pediatric consulting, implementing new technology, and the future of dentistry.

Resources & People Mentioned * Go to ProEdgeDental.com/Toothcop for a special offer! * Connect with Tonya at TonyaBurns.com * Tiny Bubbles by Don Ho

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Texas has rolled out some regulations and rule changes that dentists need to stay on top of. From controlled substance CE changes and equipment performance evaluations to medical emergency preparedness training and sedation inspections—we cover it all in this episode of Talking with the Toothcop. Don’t miss it!

Outline of This Episode * [0:21] A trip down memory lane * [4:41] Controlled Substance CE changes * [13:57] Controlled Substances: EPCS + patient query * [19:11] The Human Trafficking Course requirement * [21:30] X-ray equipment performance evaluations * [25:02] Step-wedge test + medical emergency preparedness training * [27:30] What dentists are getting busted for in sedation inspections * [34:17] Mail Bag: Does your office need to use respirators? * [37:13] Georgetown Dental’s violations

Changes to Controlled Substances Regulations A lot of controlled Substance CE changes came out in 2016. Some dentists still aren’t in compliance with these rules. Rule 111.1 is a CE requirement for every dentist in Texas with a DEA registration. Up until 9/1/2020, dentists were required to complete a two-hour CE course on opioids and the use of controlled substances in the dental practice. Now you’re required to do an additional two-hour course on monitoring and prescribing practices for controlled substances.

This takes effective As of January 1st, 2021 all dentists with direct patient-care responsibilities are required to complete a pain management CE (Rule 104.1 ). It is a two-hour CE course that you must complete annually. Some CE requirements are annual OR every other year. I.e. the human-trafficking course must be completed per renewal period or every two years.

NOTE: A dentist is NOT required to have a DEA registration if you’re not prescribing. But moving forward, the only way you can prescribe any controlled substance will have to be done through Electronic Prescribing of Controlled Substances (EPCS).

Controlled Substances: EPCS + patient query Under rule 111.2, any dentist with a DEA registration is required to login to the PMP (Prescription Monitoring Program) and complete a self-query to review your prescribing history. Even if you don’t prescribe controlled substances, you still have to log in and perform the search. Luckily, there’s no need to document it. They monitor the keystrokes and searches you perform when you log in—which is why you have to do it.

Before issuing a prescription for a controlled substance to a patient, you’re required to check the patient’s history in the PMP (Rule 111.3). If you’re administering a controlled substance from an office supply (and not ordering it or prescribing it) you don’t need to do the search.

Rule 111.4 allows the state board to monitor dentists prescribing practices. In Texas, it’s managed by the State Board of Pharmacy. Some dentists have disciplinary actions on their license for failure to comply with these rules—so we aren’t just saying them to say them. They are important.

X-ray equipment performance evaluations (EPE) The most common thing dentists get busted for is not having equipment performance evaluations (EPE) completed in time. It’s simply a calibration check that must be performed by an outside party. The state requires it for two-dimensional x-rays every 4 years from the date of the last EPE. It’s such a common violation that half to most dental offices have been busted for this. They don’t give second warnings—you’ll get a $4,000 fine after your first warning. This is one of the easiest rules to comply with. NOTE: If you have a three-dimensional x-ray machine, it must be checked annually.

What dentists are getting busted for in sedation inspections The first thing dentists get busted for is expired AED pads OR not having pediatric AED pads. You have to have pediatric appropriate equipment if you administer nitrous to children under 13.

Another thing is not checking vital signs intraoperative or perioperative. That includes blood pressure, heart rate, O2 Sats, and respiratory rate every 10 minutes. I know dentists who are in hot water right now because they’ve failed multiple times. Don’t let something so silly leave a black spot on your record.

Pull up your Pre-Op Sedation/Anesthesia Checklist and look at rule 110.3. Make sure your pre-op checklist has everything that’s required and it’s titled “Pre-Op Sedation/Anesthesia Checklist.” No joke—if it doesn’t say that, they will make you fix it. This is true for level 1 and Nitrous Oxide only as well.

Mail Bag: Does your office need to use respirators? When most people hear the word “respirator” they automatically think of elastomeric respirators (i.e. a Darth Vader type mask). Dental offices do wear N-95 masks, but it’s actually called a face-filtering respirator. It’s still a type of respirator—just not what you think of. Texas (Rule 108.7 Subsection 16) requires the use of an N-95 Respirator mask when working within 6 feet of aerosol-generating procedures (anything where you use a handpiece). It applies to dentistry in Texas and other states.

Why you HAVE to follow the rules OSHA reported that since the pandemic, there has been $1.4 million in fines issued to healthcare providers. There was only one dental office on that list—Georgetown Dental in Massachusetts. They were busted for over 7 violations, but here are a few:

1910.134(c)(1) – No Written Respiratory Protection Program. You need a written plan.
1910.134(e)(1) – No Medical Evaluations for Employees. You must provide them a medical evaluation to make sure they can use a respirator.
1910.134(f)(2) – No fit testing. They must be fit-tested before initial use of the respirator.
1910.134(k)(1). Employee training. The employer shall ensure that each employee can demonstrate knowledge of how to use, maintain, and store the respirator.

Any dental office needs to make sure they comply with these rules. To get the full details on all of the rules and regulations that have changed, give the whole episode a listen—and take notes.

Resources & People Mentioned * SedationCE * Sedation Inspections + EPCS + Continuing Education * SOAR Health and Wellness Training * 1910.134(c)(1) – No Written Respiratory Protection Program

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Why do you need to monitor and audit your charting? Why is verifying that your billing is done correctly so important? Because your life and your livelihood depend on it. An ongoing evaluation process is so important to a successful compliance program. Are your standards and procedures accurate? Is your compliance program working? Are claims being submitted properly?

All of these questions are important to answer. So in this episode of Talking with the Toothcop, Andrea and I walk through the OIG standards for record monitoring and chart auditing. We share some important definitions, my auditing process, and other things that are important to track and monitor. Don’t miss it!

Outline of This Episode * [1:37] Recap of the last episode * [4:03] The OIG Auditing and monitoring procedures * [11:38] Avoid a Corporate Integrity Agreement (CIA) * [13:08] The definition of an overpayment * [13:56] Understanding the False Claims Act * [15:00] Proper charting review and noting * [19:57] The threshold for fraud is low * [22:18] Guidance for compliance officers for CIAs * [29:59] What do you focus on in a record audit? * [34:03] Other things you need to monitor * [37:00] Find the time to do audits * [39:49] The OIG Self-Disclosure Protocol

What does the OIG consider an effective monitoring program? An audit is one of the best ways a dentist can make sure they’re following proper procedures with their charting and billing. It’s also a great way to find problems and nip them in the bud before they continue. The OIG defines two types of review: (1) A standards and procedures review; and (2) a claims submission audit. I’ve found that a review of standards and procedures is almost nonexistent in most dental offices because most don’t even have written standards and procedures.

The OIG states “In addition to the standards and procedures themselves, it is advisable that bills and medical records be reviewed for compliance with applicable coding, billing and documentation requirements.” Who should be included in the audits? Ideally, the dentist, dental hygienist, and whoever is in charge of billing.

The OIG recommends that you take a snapshot i.e. a benchmark to track that your practice is reducing the number of claims that are overpaid or denied.

What do you focus on in a record audit? A self-audit is primarily to determine:

Bills are accurately coded and reflect the services provided
Charting and documentation is being completed correctly
The services provided are necessary

Are there any patient safety or qualitative issues? Look at any issues that will pose a problem to your license and your freedom. You’re more likely to be audited on your higher-dollar items, but they’ll often include records for limited exams and hygiene. There are just a few of the things you need to monitor:

Vital sign records for sedation (document at certain time intervals, time and amount given, etc.). Calculate your time correctly, you will be scrutinized on it.
Improper coding and billing
Document tooth number and surfaces
Make sure you’ve gotten proper consent
Exclusions monitoring
Pre-hire screening

You need to be adept at identifying non-compliance from patient intake through submission and payment. Through this process, you can identify what needs improvement. The OIG recommends that you conduct periodic audits at least once per year. They also recommend a random selection of patient records to review (but preferably 5+ per payor and 5+ per dentist). I share the process that I prefer, listen to learn how it’s different (but still compliant).

What do you do when you find problems? If you identify problems while doing your review(s) you need to determine whether it merits further training and education with staff or changes to your process. If you find risk areas or vulnerabilities, they need to be addressed. The OIG notes that the specific actions taken depend on the circumstances of the situation. It can be as simple as a repayment to a payor with an explanation of the overpayment.

I worked with a dentist whose clinical notes were inadequate to support what was billed. The acting dentist didn’t take x-rays, note what teeth were affected, and didn’t clarify why the work was done. When we uncovered that, they had to figure out how much was paid and return the money.

You have to do that to protect your integrity when you don’t meet the criteria of what is expected of you. When the OIG comes knocking on your door because of a complaint, they can see your history of integrity. It could save your bacon. What do you do if your practice conducts a review and must notify the OIG? What process do you follow? What is the definition of an overpayment? Listen to find out.

Ingrain chart auditing and monitoring into your practice You have to find time in your busy schedule to do chart audits. You have to do this. It’s not that difficult to create an audit checklist. You can train your staff how to conduct an audit and assign each of them 10 records to go over. Have them report back to you with the feedback you need to reduce your number of inaccurate claims.

I also recommend auditing some of your own records—and be tough on yourself. Allow yourself to be your own worst critic to get better at charting. If you find a problem, fix the errors with that record (with a note—do NOT change the original record). Do some additional snooping to make sure it’s not a systemic problem. Dig until you find more and figure out how to report it.

Compliance is a scale. It might not be possible to hit 100% compliance. But my goal is to get you to a higher percentage on that scale. It’s about putting systems into place to help you sustain positive changes long-term. If you’d like one of my sample checklists, shoot me an email! We cover this topic in-depth, so for more detail, listen to the whole episode!

Resources & People Mentioned * OIG Compliance: Auditing and Monitoring * OIG Self-Disclosure Information * The Next Generation of Corporate Integrity Agreements * Third-Party Medical Billing Compliance Program Guidance

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Years ago, the federal judiciary realized that federal judges needed sentencing guidelines for healthcare fraud. In the process, they issued compliance guidelines for different healthcare industries. Each incorporates the seven elements of compliance to combat healthcare fraud. The ramifications of violating the false claims act are tremendous. So what do you need to do to protect your dental practice? What are the seven elements that need to be incorporated into compliance programs? Listen to this episode of Talking with the Toothcop to find out!

Outline of This Episode * [10:22] The evolution of compliance programs * [12:27] The 7 elements of compliance programs * [16:21] #1: Implement written policies and procedures * [21:50] #2: Designate a compliance officer * [24:53] #3: Provide effective compliance training * [30:16] #4: Develop effective lines of communication * [36:08] #5: Conduct internal monitoring and auditing * [43:38] #6: Enforce standards through disciplinary guidelines * [44:56] #7: Respond promptly to violations and take corrective action * [47:54] #8: Whistleblower protections in New York state * [50:41] Give us some feedback! How can we serve you better?

What are the seven core elements of a compliance program? Every healthcare provider that participates with Medicare or Medicaid has to establish a healthcare compliance program that incorporates these seven elements:

Implement written policies and procedures
Designate a compliance officer and compliance committee
Conduct effective compliance training and education
Develop effective lines of communication
Conduct internal monitoring and auditing
Enforce standards through well-publicized disciplinary guidelines
Respond promptly to violations and take timely corrective action

Any organization that has been busted for healthcare fraud—rather than being kicked out of the Medicaid program—has to establish a compliance program. It also comes with a babysitter for 5 years and compliance with a Corporate Integrity Agreement. It’s five years of probation. It’s also why it’s imperative that you read, understand, and implement each of these elements.

Implement written policies and procedures You need to create policies and procedures for whatever compliance risks you face as a practice. Some of the risks you might face could be related to sedation (general anesthesia), patient information and HIPAA regulations, infection control, electronic billing reference materials (CDT coding books), controlled substances/drug policies, medical emergencies and much, much more.

You need to identify your risk areas and write policies and procedures to serve as a reference guide for your staff. How do you establish them? Write down a brain-dump list of every risk you can think of that your dental practice might face. Ask the questions: Can I lose money? Can I lose my license? Can I lose freedom? If you can answer yes to any of those questions, it’s time to frame up some policies and procedures.

The bottom line is that the government wants to see that you have policies and procedures in place to deal with overpayments and your response to an identified overpayment. Andrea and I take a deep-dive into element #2—so keep listening.

Provide effective compliance training and education There are certain things every staff member should be trained on including code of conduct training, fraud, waste, & abuse training, continued education for billing staff, OSHA and HIPAA training, infection control training, and more. It’s your job to figure out what needs to be done and who needs to complete it. It’s not an excuse to say “I didn't know.”

The code of conduct is somewhat of a catch-all. You can’t predict every situation that might happen in your practice. It’s just not possible. Your written code of conduct is a set of principles that you want your staff to use to problem-solve. It should communicate your practice’s values, mission, vision, and purpose. Train your new employees on your code of conduct immediately. Effective training isn’t just giving someone information—you have to make sure they’re retaining the information, too.

Keep listening to hear why element #4—developing effective lines of communication—is so important.

Conduct internal monitoring and auditing AND enforce corrective action Two elements absolutely HAVE to be implemented—number #5 & #7. They involve checking your work—and fixing your mistakes. Having both processes in place is important. You need people in place to keep things in check. Put systems in place to track and stay on top of those things that you need to monitor.

Review your employee handbook periodically and update it to reflect current regulations. It should outline disciplinary guidelines. Many follow a progressive guideline such as a write-up, suspension, time off without pay, etc that leads up to termination—while reserving the right to fire when necessary. It needs to be well-published and applied evenly and fairly at every level of the organization. If you have a bad apple, you have a responsibility to carve them out of your organization before they harm someone.

Listen to the rest of the episode to hear about element #6 as well as the important topic of exclusion monitoring—if you don’t do this you can bankrupt your business.

Resources & People Mentioned * Healthcare Fraud * The False Claims Act * Office of the Inspector General Website * Corporate Integrity Agreements * OIG Compliance for Individual and Small Group Physician Practices * HEAT Provider Compliance Training Videos * Measuring Compliance Program Effectiveness: A Resource Guide

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Did you know that October is the National Substance Abuse Prevention Month? In keeping with that theme, this episode of Talking with the Toothcop is all about drug regulatory issues and updates, schedule II drug monitoring, and substance abuse prevention. We share some helpful resources and DEA regulation updates—don’t miss it!

Outline of This Episode * [1:33] DEA drug regulatory changes * [3:53] Medicare consolidating credentialing in TX * [4:28] Electronic 222 forms for schedule II drugs * [6:36] Why you NEED to keep inventory * [9:34] The topic of background checks * [12:27] Substance Abuse Prevention Month * [13:32] Controlling patient information * [14:42] Annual DEA CE now required * [15:17] How to check a patient’s drug history * [21:36] The Professional Recovery Network

The DEA is making bank The DEA is raising their fees. Effective 10/1/2020, the DEA registration fee is going from $721 to $888 per registration. For those of you that have multiple practices or registrations, it will get expensive.

What else is changing? The DEA will now require electronic 222 forms. You must fill out a 222 form to send to the DEA to order controlled substances for office use. You can use up the paper 222 forms until 10/31/2021. But what you don't use will have to be shredded.

We recommend that you don’t keep too many of these forms on hand—or too many controlled substances. If they expire, you have to send them to a reverse distributor. You can’t send them to the supplier you purchased them from. The fees you have to pay for expired drugs costs more than purchasing them in the first place.

Why you NEED to keep inventory There are TWO things I recommend you do consistently:

You need an up-to-date drug log and inventory. The DEA requires an inventory count every-other-year. Track the total on-hand. Track each concentration and form separately.
Routinely get out your receipts and 222 forms and check your math. Make sure you aren’t missing anything.

Doing these things help prevent improper use and abuse of controlled substances. I’ve seen situations where staff members order extra bottles that disappear. If someone is using your credentials to perform duties related to controlled substances—trust but verify. They’re called controlled substances for a reason.

Do your background checks Dental offices need to do background checks on employees. Some states are only allowed to allow full background checks in limited situations, such as when you’ve made a conditional job offer. But the DEA requires that anyone who works with controlled substances has a background check done on them. Ideally, it’s a full criminal background check.

If you won’t do a background check, you must do a basic screening for abuse or misuse potential. Secondly, if a staff member handles or prepares subscriptions, put the designation in writing and maintain a record of that. Most dentists are more comfortable doing the ordering themselves and I support that. If you use a designated agent or a power of attorney, you’re still responsible for overseeing their activities.

How do you check a patient’s drug history? When do you need to? What are some unexpected schedule II drugs? Listen for the details.

The Professional Recovery Network If you or a dentist you know has a drug problem or mental health issue, there are professional recovery networks available. If you turn yourself in, you can get services confidentially. If a staff member turns you in it becomes a public health issue and it will be attached to your license. Keep yourself accountable. Don’t face emergency suspension of your license. If you or someone you know has a problem, be proactive and get help.

If you’re going through a rough time in your life they can help. It doesn’t have to be severe drug abuse. It’s okay to say you’re not okay and reach out for help. Don’t wait until you get arrested for a DWI. Substance abuse isn’t the number of times you’ve done it. It’s the reason why you’re doing it and the fact that you did it in the first place.

Andrea points out that everyone is human. No one plans on becoming an addict. It takes one opportunity. One bad decision. No one says “I’m probably going to get hooked on it, but it’s okay. It’s worth it.” Don’t give yourself or someone else the opportunity to make one bad decision. Put systems in place to protect you from yourself as much as you keep your staff accountable. It doesn’t matter if you claim you’re a good guy, you have to walk the talk. Learn what else is changing and more valuable resources by listening to the episode!

Resources & People Mentioned * Pizza Hut Commercial * Designated Agent Screening Form * DEA Power of Attorney Format * Goodhire (background check) * PMP CE Option * Controlled Substances * Professional Recovery Network: 800-727-5152

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Every five years, Texas conducts inspections of any practice that uses sedation. Some practices have recently undergone their initial inspections. From what I’ve heard, most have gone pretty well. Some are getting busted for things they consider nit-picky—like missing information on their preoperative checklist—but that the state board takes seriously. So in this episode of Talking with the Toothcop, Andrea and I chat about preoperative checklist requirements, the Electronic Prescribing of Controlled Substances (EPCS), as well as continuing education requirements. These are things you NEED to stay on top of—so don’t miss it!

Outline of This Episode * [4:10] Texas: Updates regarding sedation * [10:34] Physical examination subsection C * [13:09] Anesthesia-specific examination subsection B * [13:48] Special pre-op considerations: pediatric or high-risk * [15:25] Rules on equipment and use * [16:24] EPCS: Electronic Prescribing of Controlled Substances * [29:48] Continuing Education: Human Trafficking Training * [33:17] How to keep everything straight

The required preoperative checklist for nitrous oxide + sedation + anesthesia You can find the preoperative checklist in its entirety HERE. I’m referencing specific line items in this checklist that must NOT be neglected. Firstly, do NOT remove anything from the pre-op checklist. If you don’t heed this warning, the state board will make you fix it.

At a minimum the preoperative checklist must include documentation of the following when applicable (summarized):

Medical history (allergies, surgical history, review of family surgical history, medications)
Confirmation that pre and post-operative instructions were delivered to the patient
Medical consults were conducted if needed
Physical examination and documentation (weight, blood pressure, pulse, respiration rate)
Anesthesia specific physical exam (airway assessment, ventilation and respiratory rate)
Pre-procedure equipment readiness check
Confirmation of pre-procedure treatment review
Special preoperative considerations as indicated for sedation/anesthesia administered to pediatric or high-risk patients.

So where are things getting missed? The physical examination section clearly states that you must obtain: preoperative vitals, including height, weight, blood pressure, pulse rate, and respiration rate. This applies to every level of sedation, from nitrous oxide to general anesthesia. The issue that’s coming up most frequently during inspections is that dentists and their staff aren’t documenting the respiratory rate.

Now, a lot of pediatric dentists are not taught that they’re required to document the respiratory rate. You may not be accustomed to it—but you need to start doing it. Not only that, but vital signs need to be recorded every ten minutes or less. It’s the rules. So is recording the height and weight of an adult patient every appointment. It may not feel necessary, but you can’t just say “It’s not that big of a deal because it’s only nitrous.” You have to comply with the rules to stay out of trouble.

You must also make sure you’re recording the Mallampati score and/or Brodsky score. The state board is looking for how you verified the respiratory or ventilation rate. They want that to be clear (and it can be documented by observation, auscultation, or capnography). Keep listening to hear more about pediatric and high-risk patients as well as equipment and use instructions that are being missed.

Want the latest version of my checklist? Shoot me an email at toothcop(at)dentalcompliance.com and I’ll happily share it with you.

EPCS: Electronic Prescribing of Controlled Substances Electronic prescribing of controlled substances is already a requirement in many states. As of January 1st, 2021 Texas will join the list. It will require dentists, physicians, and healthcare providers to e-prescribe schedule 2 drugs. If you need help finding a prescribing platform that works best for you, I’ve linked many options below.

But wait—don’t confuse this with your PMP responsibilities. According to the state board rule 111.2: “Each dentist who is permitted by the Drug Enforcement Agency to prescribe controlled substances shall annually conduct a minimum of one self-query regarding the issuance of controlled substance through the Prescription Monitoring Program of the Texas State Board of Pharmacy.” You can log in to PMP Aware to check your prescribing history to make sure there haven’t been mistakes. If you find something blatant, figure out if you need to address it.

Another change? Until September 1st, you were required to do a 2-hour CE once every 3 years (use and prescribing in the course of dentistry). Now it’s an annual requirement to do the CE and a self-query check. Every time you issue a prescription it needs to be justifiable and you have to perform a patient history search—every time. What are the exclusions from this? Who can do the PMP check? What is the maximum you can prescribe? Listen to find out!

Continuing Education: Human Trafficking Training Human trafficking is becoming a pandemic in its own right. Texas isn’t the first state to require it, but every healthcare provider—who is not a physician—is now required to complete a course on human trafficking. There are a lot of courses available online, but as of right now the state requires a Health and Human Services Commission approved course. It’s required training before your next license renewal.

Are you wondering how you’re supposed to keep everything straight? How do you track all the training, continued education, and compliance measures you’re supposed to take? I’ve linked a detailed list below that should help you stay on track!

Resources & People Mentioned * Required Preoperative Checklist * iPrescribe * Allscripts * iCoreConnect * Veradigm * MD Toolbox * Surescripts * https://texas.pmpaware.net/login * Texas State board rule 111.2 * Blx Training CE * Dental Anesthesia CE * Human Trafficking Training * Continued Education Requirements

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Water is the lifeline of your dental practice. If your dental unit waterlines are covered in biofilm, you’re in trouble. How do you test your water lines properly? How do you treat your systems? What do you do if you don’t have a closed system? With the heightened awareness of spreading germs due to the Coronavirus crisis, it’s more important than ever to be mindful of prevention in your practice. In this episode of Talking with the Toothcop, Dwight and I chat with Mike Rust and Kellie Thimmes from ProEdge Dental about what dentists can—and should be doing—to prevent infections.

Outline of This Episode * [0:21] Mike Rust + Kellie Thimmes on the Toothcop * [1:19] What people don’t know about Kellie + Mike * [4:27] How to test your water lines properly * [11:40] The CDC will revise dental infection control guidelines * [20:40] Indicators that a dental office does or doesn’t care * [28:28] Where does the problem originate? * [31:58] Pro Edge’s new Flow-Cytometry technology * [38:15] The Anaheim case that changed everything * [42:01] What could happen when the CDC reviews their guidelines? * [43:33] What do you do about open systems * [55:17] UV disinfection technology * [58:25] How to connect with Mike + Kellie

Why biofilms originate in water lines Biofilms usually form in waterlines because they’re small, plastic, and the water sits stagnant. The bacteria sits there and thrives. It can also be found in anything with a filtration system—which can remove solids (like minerals and chlorine) but not small bacteria. So everything just sits there in their little pod and it’s the perfect breeding ground for bacteria. That’s why it’s so important to purge anything connected to your waterline unit. The extra flow of water in between patients helps move the germicide through the system and helps keep it clean—and prevents biofilms.

The Texas dental board recently relaxed its Cavitron regulations to allow dentists to start using them again. Most dentists haven’t been using them since mid-march of 2020. Why? Kellie points out that firstly, they create aerosols. Secondly, water lines tend to hold a lot of bacteria. Dentists don’t want to worry about COVID and other bacteria. It’s also because Cavitrons are harder to shock. The failure rate is over 50% and they have higher counts of CFU’s than any other water line.

How to properly test your dental unit waterlines You have to collect the water for the test from the right place. 9/10 times dentists that say they’re testing pull a sample from an air-water syringe. But dentists should be testing from the dirtiest thing(s) in the dental practice: a water sample from the Cavitron or Ultrasonic. If you’re passing your water test with samples from those you know you’re doing well.

Kellie recommends taking a collective sample from each room in your dental practice If there’s a failure, then you shock everything. Both Kellie and Mike advise using an aseptic technique when you’re taking a sample. Take the handpiece off and use a new air water syringe tip. It’s not as messy and easier to collect the sample. Test your water as if you were doing it for a new patient.

Are the current infection control guidelines enough? It was recently announced that the CDC will be revising dental infection control guidelines—which has been overdue for a while. It makes you question: Are the current guidelines as effective as we think they are? The CDC recommends periodic testing but doesn’t define the timeline. They say to defer to the manufacturer's instructions. You have to monitor your water regularly—at least quarterly if not monthly. Kellie and Mike agree that you must use an EPA approved shock product.

If you’re not aware, the EPA regulates drinking water standards and anything that could impact groundwater. The FDA regulates medical devices (they review and approve). Everything you use in the dental office is a medical device. For you to use it, the manufacturer had to get approval from the FDA. Whenever you deviate or use a device other than its intended use, it’s considered off-label use.

There are a lot of treatments for removing biofilm, so you have to find what works for your practice. Follow the IFUs for the products you’ve chosen and ask for help if you need it. Kellie states “I wish there was a magic bullet, but there’s just not. It’s called waterline maintenance for a reason—because it takes work.” If you’re committed to monitoring, you’ll get better results.

What are indicators that a dental office is doing what they’re supposed to for infection prevention? Listen to hear their take!

Sometimes you have to humanize the problem The case that happened in Anaheim, CA impacted 71 families. 70 of the kids had major surgeries and some lost parts of their jaw from preventable infections. All because ONE dentist office didn’t properly test or treat their water lines.

Some dentists don’t want to test because if they find out there’s a problem then they have to do something about it. But it is your responsibility to know. You have to humanize the problem. It’s not about devices—it’s about those child’s faces.

No dentist goes to work and says “I want to hurt someone today.” But do they go to work today and say “I want to make sure that we don’t hurt anybody, ever.” It’s a huge difference. That’s why it’s so important that the CDC reviews its guidelines.

What to do if you have an open water system Many older dental offices still use city water and can’t introduce a germicide or antimicrobial into the system. You can treat your water, but you can’t efficiently shock the water. What do they do? You should retrofit your open systems so you can shock the water. Add a closed bottle system for $200 a chair + labor. In 10 minutes you can shock them with bleach and sleep at night. You just have to take the time to do it.

Recently, In Corpus Christi Texas, they had water-boil advisories. Municipal water was contaminated. If you don’t have a closed system, that effectively shuts down your practice. It’ll cost you way more than converting your dental unit to closed bottles. Plus, you have to keep tabs on your city's boiled water advisories.

Keep listening to hear our conversation about tap water versus distilled water and what Kellie and Mike recommend using.

Pro Edge’s new Flow-Cytometry water testing technology Proedge has launched a Flo™ Dental Unit Waterline Testing Service Kit that allows you to get same or next-day test results. It takes one hour for them to process the results. They’re counting the bacterial cells in the water with laser technology and fluorescent dye. Why does it matter so much? Other tests can take days or even weeks to get results.

Some practices have to remain closed when their water lines are being tested—only to find out they failed. That means they have to shock their systems, restest, and wait all over again. No longer. The price of this test is only a couple percent more. It’s a premium service without the premium price. Check out the resources for a link to an amazing deal on this new product. I want people to do the testing, work with good people, and save money while doing it.

Resources & People Mentioned * Special Dental Compliance ProEdge Offer * Flo™ Dental Unit Waterline Testing Service Kit * Dental Infection Control Washington state * Mike Rust on LinkedIn * Kellie Thimmes on LinkedIn * ProEdge on Facebook * Call ProEdge at 888-843-3343 * Environmental Protection Agency (EPA) * U.S. Food and Drug Administration * Boil-Water Advisory * Dental Unit Waterline Contamination in Anaheim

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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HIPAA security compliance isn’t talked about often in the dental community. But the Office for Civil Rights (OCR) can and are investigating dental offices. If you’re not properly or adequately protecting your patient’s protected health information (PHI) you’re at risk of a hefty fine. In this episode of Talking With The Toothcop, I talk about the HIPAA security rule, business associate agreements, and how a data breach can impact your practice.

Outline of This Episode * [1:20] HIPAA Security Compliance * [4:43] The HIPAA Security Rule * [9:00] Consistently work toward compliance * [10:13] The Business Associate agreement * [14:57] Have adequate cyber insurance in place * [17:38] Will OCR hit practices harder because of COVID?

HIPAA Security Compliance: What a breach looks like I received an email from OCR (AKA the HIPAA Police) titled: “Small healthcare provider fails to implement multiple HIPAA security rule requirements.” So I opened it. Essentially, Metropolitan Community Health Services has to pay a $25,000 fine to OCR and has to adopt a corrective action plan to settle violations. Why?

Because on June 9th, 2011—9 years ago—Metro filed a breach report that affected 1,263 patients. The OCR investigation revealed long-standing non-compliance. Metro failed to conduct risk-analysis and failed to implement any security rule policies, procedures, or training until 2016. Providers are supposed to safeguard their patient’s information.

The moral of the story? We need to implement measures so we don’t have to report a breach affecting 500+ people. This is a classic example of where prevention could’ve made a world of difference.

The HIPAA Security Rule The HIPAA privacy rule states that you must have agreements with vendors who have access to information, train your staff properly, and establish notice of privacy practices (how we can use and disclose patient information). The HIPAA Security rule is what people seem to have trouble with. It deals exclusively with the security of protected health information.

One of the key components of the rule is to have someone appointed as the security officer. They establish access control for authorized users and set up firewalls, firmware, antivirus programs, updates, etc. They are tasked with risk analysis and mitigation:

1 Identify the potential threats and risks to PHI
2 Address the higher-risk or potential risks areas

This is where dental practices have significant gaps and fall short. OCR started conducting audits of covered entities and found that more than ¾ of providers had not addressed security issues or implemented security measures to address the rule. What should security training include? What issues do I see in dental offices? Listen to find out!

The Business Associate Agreement You need to understand who your business associates are: Who are the vendors you work with who have access to your patient information? IT people? Coaches or consultants? Software providers? Identify those business relationships and make sure you have a signed Business Associate Agreement (BAA) with them. It’s required before they gain access to your patient information.

Let’s drive the point home: A data backup service was audited by OCR and they were connected back to a medical practice. The medical practice couldn’t produce a BAA—and got slapped with a $30,000 fine. It’s a big deal. There was another case in Florida: A former employee of a business had access to patient PHI. A BAA wasn’t in place and they were fined $150,000.

I don’t want to scare you—I want to motivate you. I want you to understand the importance of addressing these issues. How many tooth fillings, root canals, and crowns would you have to do to cover a $30,000 or $150,000 fine? The preventative measures are worth every minute of your time.

How does cyber insurance play a role? Will they cover fines? Keep listening...

OCR takes their job seriously Very few dentists are in compliance. If they were audited by the OCR it would be a blood-bath. While perfection cannot be expected, there’s room for improvement for the industry. You must show consistent and periodic effort. OCR just loves to kick people’s butts, pandemic or not. They are proactive on the educational side and actively involved from a preventative standpoint. But they will take heavy-handed action when there is a breach of compliance. It is so important to protect your patient’s information. Hear all about it in this episode!

Resources & People Mentioned * Office for Civil Rights (OCR) * HIPAA Security Rule

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In this episode of Talking with the Toothcop, Dwight Shreve joins Andrea and I to cover some of the most-asked questions that have accumulated during the Coronavirus pandemic. We talk about face masks and respirators and how to use them properly. We also talk about addressing issues in your practice and the proper procedure if a staff member is diagnosed with COVID-19. If you have unanswered questions swirling around in your head, don’t miss this episode!

Dwight Shreve worked at Crosstex for a couple of years as a Sales Manager and Infection Prevention Advisor. Now Dwight is an Independent Consultant with us at Dental Compliance Specialists. He has a passion for supporting patients and helping to make sure their needs are being met.

Outline of This Episode * [0:21] Andrea and I are joined by Dwight Shreve * [1:58] Lockdown in Texas has been lifted * [3:20] What is a face mask anyway? * [7:02] Guidelines to follow in dentistry * [12:17] Respirator Medical Evaluation Questionnaire * [15:35] Complete a respirator fit test * [18:56] The pandemic uncovered a rift * [30:00] CDC return to work Criteria for staff * [32:52] Do I have to pay my staff PTO? * [34:28] Just because you don’t HAVE to do something… * [35:45] Texas Dentists: get consent for every procedure you do * [45:42] Surround yourself with a good team

The difference between face “coverings” surgical masks, and respirators A face covering—which is being mandated almost everywhere right now—can be a bandana, a neck gaiter, or a homemade mask made of whatever fabric you have on hand. There are surgical masks (level 1, 2, or 3) and then there are different types of respirator masks such as N95 and KN95 masks. They are regulated by the FDA and the use is mandated in certain environments.

One of the biggest questions I get is, “Do I have to do it, or is it recommended?” Currently, this is federal law and stuff you HAVE to do. OSHA has standards (which are effectively law) and they have guidelines that are recommended (you should do it). If you don’t do it? The bottom line is that you can get in serious trouble.

Everyone working in a healthcare environment—even the dental office—should be wearing a surgical-grade face mask—NOT a face covering. You must focus on prevention to minimize the impact on the practice if someone is diagnosed with COVID. Why is it important? Listen to hear our discussion on the topic!

Dentists: You HAVE to use a respirator correctly! Did you know that before you even put a respirator on, you’re supposed to have a medical evaluation and a fit test? If you haven’t done that yet—go back and get it done. OSHA provides a medical questionnaire for the medical evaluation that should be completed for each staff required to use a respirator mask.

The evaluation needs to be completed by a licensed healthcare provider. I suggest you send your staff with the eval to get cleared by a physician (to control your liability). Why is it important? If you are not medically fit to be wearing a respirator then you shouldn’t be wearing one. In some instances, that means you cannot carry out the duties of your job. Only once a staff member is medically cleared do they get fitted for a respirator. What does that look like? Listen to find out!

Address issues that can negatively impact your practice You have to look at issues that crop up for the potential that they have to dramatically and negatively impact your practice. You need to be proactive and look at things in advance while anticipating and weighing the risk versus benefit of applying a protocol—or disregarding the protocol and just continuing as is. Sometimes you have to put your personal feelings aside about things and do what's in the best interest of your practice.

You have to implement these steps so you can defend yourself if someone does get sick and it’s linked back to you. it's always easier to prevent problems than it is to deal with them in the aftermath. Andrea emphasizes that there are laws and regulations in place you have to follow regardless of how you feel about the situation. Dwight points out that “Your practice is only as safe as your patients perceive it—and perception is reality right now. So if your patients don't perceive it's a safe environment to be in, they're not coming back.”

What can you do to encourage open communication? Listen to find out.

Current guidelines on a team member who contracted COVID Another question that we’ve been asked frequently is: We have a staff member that’s sick, what do we do? How long until they can come back? Do we require them to get tested?

As of July 17th, 2020 changes were made to the guidelines to conserve tests. So the CDC is moving away from requiring tests to return to work and simply monitoring symptoms. There are three requirements a staff must meet to return to work:

There needs to have been at least 10 days since symptoms have first appeared AND
At least 24 hours must have passed since the patient has had a fever AND
Symptoms such as cough and shortness of breath must be improved

The guidelines will likely change again, but you need to be familiar with them. Who pays for the tests—the employer or the team member? Listen to hear our answer.

A Note for Texans Participating in Medicaid: Get Consent While this applies most specifically to my Texan listeners, I believe every dental practice should embrace these procedures.

Make sure you have consent forms for every single procedure you carry out, for every patient, every time. This includes preventative procedures and things you don’t normally need to get consent for (fluoride treatment, x-rays, etc.). You must also make sure your clinical notes and all chart documentation reflect the service you’re providing. If it’s not written, it didn’t happen, and it will be presumed fraud.

Ignorance is bliss—until you get caught. Get auditing and monitoring processes in place to make sure your clinical charting is being done properly. Dwight implores you to get your house in order and keep up-to-date on compliance issues. Dentists may not have known what they signed up for when it came to all the business aspects of dentistry but they’re all inherently important to the small business that you operate and must be learned.

Resources & People Mentioned * Families First Coronavirus Response Act * FFCRA Employee Rights Poster * CDC Return to Work Criteria * CDC Potential Exposure at Work * OSHA Respirator Medical Evaluation Questionnaire * Connect with Dwight Shreve on LinkedIn * BOOK: Rich Dad, Poor Dad

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

Rich Dad Poor Dad: What the Rich Teach Their Kids About Money That the Poor and Middle Class Do Not!

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The impact of the Coronavirus is leading to heightened emotions and increased tension. I’ve been fielding a lot of phone calls from dentists who’ve had patients test positive for COVID-19—after they’d been seen in office. Some dentists have had staff who have been exposed or are testing positive for the virus. Dental practices are immersed in chaos and navigating through conflict has been difficult. Some dental offices function like one big dysfunctional family. So in this episode of Talking with the Toothcop, Andrea and I will cover some conflict resolution strategies to keep your practice running as smoothly as possible.

Outline of This Episode * [0:21] Conflict resolution strategies for dentists * [2:29] Find someone in your corner * [6:03] Communication is the key to overcome conflict * [17:04] Consider each point of view as valid * [20:36] How COVID-19 has impacted the dental industry * [20:36] Limit your exposure to minimize your impact * [23:47] Reference the links below for NEED to know info

Find someone in your corner The first conflict resolution method I sort of stumbled upon when a dentist called me to walk through a situation. I was able to be a sounding board that wasn’t passing judgment and could help them reason through the situation—even though they did the majority of the problem-solving themselves.

Working through a difficult situation can be easier if you have someone in your corner who can help you muddle through the possible solutions. Andrea points out that having someone to talk to can give you peace of mind, even if they aren't part of the solution.

Conflict resolution strategies must include communication Of all of the conflict resolution strategies you could utilize, communication should be at the top of the list. I work with a dentist who was wrapped up in a situation where a staff member came to work sick—with a cough—and was later diagnosed with COVID-19. The staff hasn’t been diligent with wearing their face mask, so the doctor was stuck trying to figure out who had been exposed. She ended up furloughing part of her staff for two weeks while they quarantined at home.

One of the exposed staff members that were sent home was extremely upset and hurled some colorful hurtful words towards the dentist. The dentist knew they were upset and responding emotionally—but it was still hurtful. This staff member completely ghosted her and refused to return phone calls. The dentist finally had to call her and let her know that if she didn’t return her call she wouldn’t be receiving a paycheck. The staff member returned her call, completely embarrassed by her actions and profusely apologetic.

The situation started with a completely emotional blow-up, but the dentist and her staff members got their butts back to the bargaining table, cleared the air, apologized, and found a way to move forward. You MUST be willing to sit and do the work and figure out a workable solution. If you’re not willing to do that, it’s an easy decision—leave.

Step back from your emotions and exhibit empathy Are you being driven by fear? Are you anxious about keeping your job so you can provide for your family? Have you been personally impacted by the coronavirus? Everyone has a different frame of reference that dictates how they handle crises. To resolve conflict—or prevent it from reaching the point of conflict resolution—you need to step back from your knee-jerk emotions and exhibit some grace and empathy. It doesn’t mean anyone is right or wrong—but just have differing opinions.

Andrea points out that you can combat emotional outbursts with even more vile opinions and feelings, or you can empathize and put yourself in those persons’ shoes. You only have power over how you respond to the situation—so respond with grace. Give them the opportunity to apologize or leave. Be raw, real, transparent, and bridge the gap—in an appropriate way. Communicate on a different level to overcome conflict and misunderstandings.

Conflict resolution begins with a willingness to listen to your staff and understand their viewpoint and try and find some common ground. Consider their point of view before you dismiss their contribution—because they likely are trying to help you. Likewise, dental staff must work to gain understanding if you don’t understand what you’re being asked to do. Don’t allow your confusion or frustration to fester. Be willing and open to be educated and change your viewpoint if necessary.

Limit your personal exposure so you can minimize your professional impact COVID-19 has made a significant negative impact on the dental industry. We can hope and pray this doesn’t happen again. But in the meantime, we can work together to minimize the personal and professional impact it has on our lives. Be cognizant of the choices you make in your private life. If you take unnecessary risks and expose yourself to the virus it doesn’t just impact you. It impacts the practice you work in and it WILL have a cascade effect—so keep that in mind. Protect yourself, minimize exposure, and don’t expose your coworkers.

But what do you do if your office—patients and staff—are exposed to the Coronavirus? Do you need to close your office or furlough staff? We don’t have all of the answers, but we’ve linked to some of the best resources below to help you decipher what your next step should be. Always feel free to reach out with any questions. At the very least, I can be your sounding board.

Resources & People Mentioned * Framework for Healthcare Systems Providing Non-COVID-19 Clinical Care During the COVID-19 Pandemic * Families First Coronavirus Response Act: Employee Paid Leave Rights * FFCRA Poster * ADA Steps to Take if a Patient Reports COVID-19 Exposure After Treatment * What to Do if Someone on Your Staff Tests Positive for COVID-19

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Are you looking for a tax consultant for your dental practice? Do you understand the necessity of tax planning and preparation for your business? Even better—are you aware of the tax savings you’re missing out on? Tax Consultant Craig Cody joins us to talk about financial planning & taxes.

Craig Cody is a Certified Public Accountant (CPA) and the President & Founder of Craig Cody & Company. He was formerly a cop with the NYPD and ended his career as a Lieutenant after 17 years on the force. Listen to this episode for some expert advice—and maybe a few cop stories.

Outline of This Episode * [2:33] From law enforcement to tax consultant * [5:03] Strategies to manage tax savings * [12:02] What can a CPA do for you? * [14:20] Dentists should NOT double as bookkeepers * [16:05] Craig and I share a cop story or two * [22:30] Connect with Craig Cody & Company

From law enforcement to tax consultant Craig was an Economics major in college, but after 3 years he left to join his dad at the NYPD. After 17 years on the force, he decided it was time to move into something else. He wasn’t unhappy, he loved his time with the NYPD, but it was the right move. Now, his son is with the NYPD, already at the rank of sergeant.

Many cops transition to lawyers when they retire from the force. But Craig Cody decided to go into financial planning. He thought getting his CPA would be the ideal way to stand out. But in the process, he fell in love with taxes and tax planning. Now he runs a firm that specializes in helping YOUR business keep more of what you make. Sometimes, $20,000, $30,000, or $40,000 a year.

What is the biggest tax mistake you can make? Craig points out that when we shop for a vehicle we do a lot of research. When we plan a vacation we research where we want to go. But what research went into the entity you chose for your business? Do you communicate with your CPA? Do you HAVE a CPA? Your CPA isn’t an expense. With the right tax consultant, they can be an income item. Instead of worrying about what you have to pay, they can help you think about what you can save.

Maximize the legal deductions you’re allowed to take Before even forming a practice you should consult with your attorney and a CPA to decide which entity to operate under (LLC, S Corp, partnership, etc.). Choosing the wrong one could mean you lose out on the Qualified Business Income (QBI) deduction—a 20% deduction.

What about deductions for a home office? Or a home gym (if you have a pool, gym equipment, etc.)? Do you have a medical expense reimbursement plan? Craig helps his clients maximize the legal deductions they’re allowed to take and keep more money in the business.

Once you hit the Married Filing Jointly income limit of $315,000 of taxable income, that 20% deduction starts to phase out. But if you plan properly, you can keep more of that deduction. Keep listening to hear more of Craig’s tips.

Why Dentists NEED a tax consultant I learned early on that I should’ve talked with a consultant before even opening a bank account. Once I hired a CPA, my bank of choice wouldn’t give them access. Craig agrees—it’s important to start conversing with a CPA early. Not only can they help you avoid costly tax errors, but they can help you build a tax plan, go through your P&L and balance sheet, and even help with monthly bookkeeping.

Craig admits when he sees the books of a dentist who’s handled it themselves, he prays they’re a better dentist than they are bookkeepers. Even if they think they’re correct, they’re typically not even close. Craig states: “There is a reason they went to dental school—and it wasn’t to do accounting.”

Dentists often breathe a huge sigh of relief when Craig & Company step in and help take over their books and tax preparation. The value they offer is insurmountable. Listen to the whole episode to learn more about WHY you need a tax consultant. Craig and I also throw in some hilarious cop stories you don’t want to miss!

Connect With Craig Cody * Get Craig’s FREE Book * Craig Cody & Company * Craig’s LinkedIn Profile * The Progressive Dentist Podcast * Craig(at)CCodyCPA.com * Call at 516-869-4051

Resources & People Mentioned * Voices of Dentistry Conference

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Many dental practices have been sitting closed, deemed non-essential businesses during the coronavirus crisis. Or they’ve only seen patients on an emergency basis. States will soon slowly start reopening businesses. But that begs the question—how will this crisis change dental practices? Will there be new standards put in place? Will infection control finally get the attention it deserves? Mike Rust with ProEdge Dental and India Chance with Learn2Prevent join me to talk through the implications for dentistry in this episode of Talking with the Toothcop.

Outline of This Episode * [0:22] OSHA regulations: respiratory protection program * [4:02] Pent up demand for dental services coming? * [6:13] Interim guidelines for dentists * [8:57] Upcoming concerns dental practices face * [12:22] When will dental offices start opening? * [18:50] Aerosols have ALWAYS been a problem * [28:27] Why is their resistance to change? * [32:45] Who is closing their practices? * [38:43] Preparing to reopen your dental practice * [41:40] Ways to make the transition positive * [48:33] Dental Line Water Unit Safety

Have a plan in place for your dental practice India shares an example of a client who saw a patient and found out after the fact that the patient was asymptomatic, but tested positive for the Coronavirus. He had rushed to reopen his practice and was immediately exposed to the virus. Now he’s suddenly faced with notifying everyone he’s come in contact with and closing his practice for another two weeks.

Do you have a plan in place to protect your practice? I’ve been telling clients to have a go-bag ready. If they’re exposed and can’t risk returning to their families, they need somewhere to quarantine for the next 14 days. Vaccines won’t be released anytime soon and dentists must implement everything possible to protect themselves, their staff, and their patients.

Respiratory protection programs and proper PPE Dental offices often see patients who are ill, and exposure to aerosols and bodily fluids are unfortunately par for the course. But little has been done to rectify the problem. It’s sad that it’s taken a pandemic for people to open their eyes—but I’m amazed by the innovation and creativity that’s ensued. Solutions are being created and proposed and that needs to continue.

Patients need to be assured we are doing everything possible to protect them—So do your staff.

We’ve heard talk that many hygienists aren’t planning to return to their jobs because the risks they face are too great to overcome. Their PPE isn’t sufficient to protect them from the aerosols they’re exposed to. That’s why it’s imperative you do your research and make sure you and your staff are equipped with the proper PPE. Communicate to them that your practice is doing everything possible to maintain their health and safety.

How should you prepare for reopening? I instructed most of my clients to drain their dental unit water lines before the shut-down ensued. If you weren’t able to, I highly recommend doing shock treatments at least 1 week before reopening. That gives you time to test the water lines and make sure they aren’t overgrown with biofilm. Mike shares some updates on ProEdge and the innovations they’re making to deliver faster results.

You also need to prep your autoclave and do any necessary maintenance, cleaning, and disinfecting. The CDC is making posters available that describe symptoms of the virus to post in your waiting rooms. They created another infographic for staff members that shows the symptoms staff must keep watch for. To hear more ideas and changes being recommended, keep listening!

Will the dental industry bounce back? Many practices are considering closing their doors instead of reopening. In Maryland, dentists usually finish school with over $250,000 in debt. Opening a practice costs anywhere from $500,000 to 1.2 million. New dental practices can’t sustain long-term closures. Some practices who had just opened faced months with no income and are going to be filing bankruptcy.

Dentists who’ve been in the industry for years are considering moving into DSO positions with no patient contact. Others who are close to retirement are simply retiring early. But on the flip side, there is likely some pent-up demand for dentistry. Most people haven’t been able to receive routine care and cleanings. Perhaps dentists will see an intense influx of patients that will help offset some of the time spent closed.

Whether dentists like it or not, necessary change is coming. The Coronavirus pandemic is affecting the infection control standards that are in place—and hopefully improving them. Many dentists are hesitant to make changes. Change is uncomfortable, scary, and even expensive—but imperative. Listen to the whole episode for our full discussion on the future of dentistry.

Resources & People Mentioned * The CA Workplace Guide to Aerosol Transmissible Diseases * COVID-19 Health Care Worker Protection Act of 2020 * OSHA Respiratory Protection Guidelines * The Shield Group * Learn2Prevent * ProEdge Dental Waterline Labs * India Chance on LinkedIn

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Critical Incident Stress Management. Unless you’re in the military or a first responder, you’re likely not familiar with this terminology. It is a protocol developed specifically for dealing with traumatic events. I’ve shared many times that I was a cop before becoming the Toothcop. But what many don’t know is that I was also a chaplain. I was trained to help fellow first-responders through physical and psychological trauma.

In this episode of Talking with the Toothcop, Andrea and I talk about grief and the grieving process. We talk about critical incidents and how to recognize the signs and symptoms that you’re dealing with psychological trauma. We also share some stress-management strategies and resources for yourself and your team to work through critical incident stress.

Outline of This Episode * [0:22] Critical Incident Stress Management * [9:06] Grief: experiencing psychological trauma * [13:35] We must move through the 5 stages of grief * [16:41] The pandemic: A series of incidents * [21:42] Critical incident stress management system * [25:08] Signs and symptoms of psychological trauma * [33:49] Reduce the effects of trauma for yourself and your teams * [38:48] What does this have to do with OSHA?

The psychological trauma we’re all facing We’re all grieving right now. Some of us have physically lost someone to COVID-19. Many have lost their jobs, their businesses, and their independence. We are mourning our loss of connectedness and dealing with severe loneliness. Whether you recognize it or not, we’re dealing with unprecedented levels of stress. Even though we can’t SEE the damage, the damage is just as pervasive, certain, and severe as physical trauma.

Andrea points out that losing a job is a normal occurrence in society—but we can’t cope with the repercussions the way we normally would. It isn’t as simple as going out and getting another job. Everyone is being affected emotionally. In most instances I’ve witnessed, it’s harder to come out of emotional trauma than physical trauma. I want to emphasize that it’s okay to feel how you’re feeling—but you need to recognize that you’re grieving to move through the 5 stages of grief (denial, anger, bargaining, depression, and acceptance).

The critical incident stress management system Critical incident stress management (CISM) is “an adaptive, short-term psychological helping-process that focuses solely on an immediate and identifiable problem”. The way people respond to emergencies and disasters strains their ability to function. Their future depends on learning how to manage the psychological stress and impact of those incidents. The system is geared towards:

Normalizing your instinctive reactions
Lessening the impact of the incident
Encourages the natural recovery process
Restores adaptive functioning skills
And helps determine the need for further support

No one signed up for the trauma we’re all facing. We are grieving our old way of life—because when things return to “normal” they’ll never be the same. We may not all be dealing with death, but we are still dealing with loss. We must seek to understand it to lessen the impact.

Signs and symptoms of psychological trauma Stress is a mental phenomenon that can be manifested physically. Some of the symptoms include: Exhaustion, nausea, vomiting, weakness, chest pain, rapid heart rate, headache, excessive thirst, fainting, elevated blood pressure, exacerbate allergies, symptoms of shock, and more.

Our bodies are trying to tell us there’s something wrong. We can also experience cognitive, emotional, and behavioral reactions.

Cognitive reactions: blaming others, confusion, reduced attention span, poor concentration, troubled thoughts, nightmares, and so forth.
Emotional reactions: frustration, anxiety, guilt, sense of loss, anger, denial, fear of loss of control, feelings of isolation, and more.
Behavioral reactions: Emotional Outbursts, changes in activity level, disturbed sleep, increase in smoking or drug use, easily startled, anti-social, withdrawn, change in eating habits, fidgety and restless, change in sex-drive.

The odds are everyone is dealing with some of these symptoms in one form or another. You have to recognize that this is normal right now, but YOU have the power to change how you react and move forward.

How to reduce the effects of trauma—for yourself and your team There are a few simple recommendations for dealing with the effects on an individual level:

Limit exposure to noise and odors
Take 15-minute rest breaks
Drink non-caffeinated fluids (water)
Don’t eat excessive sugar or fat
Don’t rush back to work
Talk through your feelings

Whenever we eventually return to our offices, owners and managers need to keep these things in mind. Many people may be hesitant to return to work and it’s your job to help them feel safe. You must also convey to patients that your office is safe.

One way you can help your team transition back to work is to facilitate a structured critical incident debriefing with your team. It’s a 7-step phase that helps you work through the psychological trauma together—because none of us are in this alone.

Listen to the whole episode for an in-depth discussion on each of these topics. For more resources, visit some of the links below for dealing with critical incident stress management or setting up a critical incident debriefingfor your team.

Resources & People Mentioned * International Critical Incident Stress Foundation * OSHA’s Critical Incident Stress Guide * Maslow’s Hierarchy of Needs

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Sterilization processes are always important in dental practices to protect your staff and your customers. During the Coronavirus pandemic, everyone is especially concerned about proper procedure. You have to follow Instructions for Use (IFUs) and properly sanitize and sterilize your instruments. In this episode of Talking with the Toothcop, Stephen Kovach—whom I am now referring to as the “Godfather of Infection Control”—joins Andrea and myself to chat about the importance of sterilization processes.

Stephen Kovach is Educator Emeritus at Healthmark Industries and has been in the medical field since 1975—now celebrating his 45th year in Healthcare. He is a member of IAHCSMM orthopedic council for loaner instrumentation and a voting member on various AAMI committees. He’s published numerous articles varying in subject matter from perfusion to the importance of cleaning surgical instruments.

Outline of This Episode * [0:22] Stephen Kovach joins Andrea and I * [2:14] Stephen’s tremendous wealth of experience * [4:05] Instrument sterilization and cleaning * [10:13] The importance of IFUs * [19:03] Stephen’s thoughts on hinged instruments * [26:55] The legal precedent for following IFUs * [34:45] Get rid of rusty instruments * [37:25] What to monitor with water quality * [50:31] Why you need 2 full-sized sterilizers * [52:20] Coronavirus and infection control

The importance of proper sterilization and cleaning According to my research—which I will publish at some point here—9/10 offices aren’t doing a good enough job cleaning their instruments. When I recently heard Stephen speak, he pointed out that “When you sterilize dirty instruments the end result issterile dirt”. Every dental office NEEDS to have a quality management system in place—and most don’t.

Stephen points out that dentists need to be referencing the AAMI ST79—The “Comprehensive Guide to Steam Sterilization and Sterility Assurance in Health Care Facilities”. But most aren’t. Why? Stephen and I agree it’s because the high price ($400) is a barrier to entry. While their information is proprietary, it would be wise to have this information widely disseminated for the safety of our patients.

What you may not know about Instructions for Use (IFUs) I’ve talked about IFUs before and have emphasized the importance of acquiring and referencing them for proper instrument sterilization. They outline the exact cleaning and sterilization process step-by-step to ensure proper cleaning of the tools. What you may not know is that device manufacturers have tested this repeatedly, and to get their products to market the FDA HAS to approve the IFUs they’ve submitted. They don’t just slap instructions together willy-nilly. It is a well-researched process that you need to follow.

I’ve been surprised how many dental professionals have no idea what I’m talking about when I ask them if they’re using their IFUs. Turns out, IFUs can be hard to obtain. I’ve even asked a device rep for an IFU and was told point-blank it was only provided to clients. Some can be found online—but not all are readily available.

Stephen and I agree you must seek out and obtain IFUs for any tool or instrument you use. Follow at the very least the minimum requirements for sterilization and go above and beyond when possible. Keep listening for our discussion on cleaning hinged instruments.

Document your procedures to protect your practice Stephen has been a part of many depositions where professionals are asked how they documented their process and how they followed their IFUs. If they stray from the directions on the IFUs they must state why they think their cleaning procedure was superior to that of the manufacturer.

If you stray from the proper sterilization procedures and a patient's illness or even death is traced back to you—you’re in serious trouble. You must be able to prove in a court of law that you followed the instructions properly and show documentation.

Some professionals claim they were told something different by the manufacturer—but have no concrete proof. Stephen recommends that if you contact the device manufacturer and they verbally tell you a process that contradicts the IFU—get it in writing. Ask them to outline the company letterhead and mail it to you for records. But if all else fails, following the IFU is the ultimate protection.

Why following instructions are SO important during the Coronavirus Pandemic Stephen was quick to point out that he sees some of the best pre-infection control in dental offices. His personal dentist washes his hands in front of him, uses hand-sanitizer, puts on a mask and safety shield, and protective eyewear. Continue to practice these basic means of infection control—but do it correctly.

Stephen has noticed that most people don’t even know how to properly use Clorox wipes. The contact time of the solution on the surface is of the utmost importance. Most people quickly wipe down surfaces with a wipe and call it good. But if you read the instructions (which vary) it states that the surface must remain visibly wet for up to 4 minutes to properly sanitize. Read the instructions people!

Contact time is also important for hand-washing. The longer you wash your hands (experts say you can sing the “Happy Birthday” song in your head) the more effective you are removing bacteria, viruses, etc.

Proper sterilization techniques are more important than ever during the pandemic—not because it was less important before—but because it brings you and your patients peace of mind in a time of chaos. Listen to the whole episode for our discussion on critical water, proper training, and how many sterilizers are necessary.

Resources & People Mentioned * Stephen Kovach on Instagram * Stephen on LinkedIn * CPD Guy Website * Dryshield * Onesource * OSAP.org * AAMI ST79 * Healthmark

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Today I talk with my good friend and compliance colleague India Chance.

This podcast is a way to update you on the rapidly changing situation in Dentistry as it relates to the Coronavirus.

We are updating you on the changes and how to access information to help your practice.

If you need help with compliance or have questions about infection control call us at 817-755-0035

www.dentalcompliance.com

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We can all agree, things are going badly right now. Times are tough. This podcast is a group effort- an attempt to help you re-focus your efforts and turn this downturn into a profitable time for your business.

Our think tank Duane Tinker- AKA: "The Tooth Cop" CEO of Dental Compliance Specialists, Andrea Baysinger, Chief Client Happiness Officer and co-host extraordinaire and Jacque Tinker, COO of Dental Compliance Officer put their heads together to bring you a message of hope and help in this difficult time.

Here is a quick a dirty list of things you can do to put your practice in a good place come the end of this mess we are facing now. Check it out.

This is a fun one guys!

OUTLINE OF THE EPISODE:

[7:05] Review and update OSHA safety plan and written infection control plans. Understand the difference between them
[7:45] Update compliance Training- Take our 4-hour Infection Control CE. Bone up and take the time to update annual compliance training. Your staff can complete training online on their pjs on their phone.
[9:45] Do your Medical Emergency Training and practice scenarios.
[10:45] Audit your records.
[11:50] Train.
[13:00] Virtual Team Meetings.
[14:15] Call your patients.
[15:10] Update your lobby.
[16:15] Support your staff during this time of insecurity. Support your team and give them something to work on in the off time.
[19:00] Make videos for your patients.
[19:30] Get on videos on social media.
[21:50] Complete your compliance inspections, especially the infection control inspection and certification!
[23:00] Get Infection Control Certified.
[31:15] Update your marketing plan. Create an Avatar and re-focus your efforts.
[34:15] Update your forms.
[35:45] New W4 forms.
[36:15] Clean your office with EPA disinfectants.
[37:15] Update your systems, fix problems in the practice.
[38:00] Check your posters and things that need to be posted in the practice.

We love you and wish you and your business and family the most peace in the coming weeks.

Let us know if there is anything we can do to help you.

817-755-0035

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Leadership in dentistry is severely lacking in this day and age. I’m not talking about governing bodies—but dentists who are true leaders in their field and practice. Steve Dove, DDS, and Bryan Crawford join me to have a raw and real discussion about cultivating leadership, our heart for dentistry, and our shared vision of growing leaders in the industry.

Disclaimer: we recorded this at the Voices of Dentistry Conference.

Outline of This Episode * [0:21] Steve Dove, DDS and Bryan Crawford join the Toothcop! * [4:42] Why an ounce of prevention is worth it * [10:37] Budget for compliance and prevention * [13:45] Steve points out that we live in a numb society * [16:10] Dentists need to be passionate about people * [18:18] Why Steve and Bryan are launching a leadership podcast * [20:15] Cultivate a heart for people—empower and equip them * [21:18] Where to follow the ‘Dental Leadership Academy’ podcast

Where does leadership in dentistry begin? In our discussion, Steve and I agreed that a leader must acknowledge their shortcomings and know where their vulnerabilities are. The next step is actively improving on your weaknesses—or delegating them to someone. Steve struggles with organization tasks but his wife (also a dentist) excels at them. So she tends to take on organizational tasks while he focuses elsewhere.

The key is knowing when to leverage your strengths. Steve points out that you don’t always want to focus on bringing your weaknesses up to average. Instead, focus on your strengths—and the strengths of those around you—and improve those. You can make your strengths incredible. People notice when you’re different—not when you’re average.

An ounce of prevention Steve shares some kind words in this episode about the value that he sees in what I do as a compliance expert. I’m working to step in as an advocate to make sure dentists are compliant. The goal is to empower them to do better and be better. While you can’t always see an immediate ROI, I do help prevent problems from happening. Dentists aren’t always aware of things going on in their practices that could ruin them, but a focus on compliance and prevention can change that.

Steve points out that dentists don’t often get thanked for the preventative services that they do. People turn down or ‘poo-poo’ getting a sealant put on their teeth. What they don’t realize is that it can prevent cavities down the road. It can prevent needing a root canal in 5 years. An ounce of prevention will save them from using hours of PTO over multiple appointments.

If dentists are preaching to their patients that they must take preventative measures to protect their teeth, why aren’t more dentists taking preventative measures to protect their practice? To protect their livelihood? Or become better leaders? Dentists need to know the repercussions of the things they don’t do.

Learn to be passionate about people Why do I care so much about dentists? Why am I invested in helping their practices thrive? Because most dentists have giant hearts. They are full of compassion. They do amazing things for people every single day. After all, a beautiful smile is worth more than words can describe. When you notice what’s different about a confident person, more often than not it’s rooted in caring about other people above themselves.

Steve points out that we live in a society that has become numb to what’s going on around them. We snap at the person who hands us our Starbucks coffee. We treat others like crap simply because we can. We need to learn to take a step back and realize they are people. We need to see them for who they are and treat them with respect. We need to reignite a passion for caring for people—and our patients.

Why Steve and Bryan launched their podcast A dentist can truly make an impact on someone’s life. You have to grow and learn to be a good person—expound on that strength and passion that you already have. At the time of this recording, Steve and Bryan were about to launch their podcast—the ‘Dental Leadership Academy’.

They are passionate about helping dentists grow into leaders. They hope that their podcast can help cultivate a desire for growth in fellow dentists. It all starts by reaching just one person who can reach others. Steve, Bryan, and I all have a heart for dentistry. We want to empower and equip others to be better dentists and leaders.

According to Steve, “A good leader is measured by how many leaders he or she creates”. If you’re ready to become a better leader and dentist, you have to go check out their podcast, the ‘Dental Leadership Academy’—linked below!

Resources & People Mentioned * Dental Leadership Academy on Apple Podcasts * Dental Leadership Academy Website * Dental Leadership Academy YouTube * Dental Leadership Academy Facebook

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Have you considered adding a dental membership plan to your practice? Have you looked at the pros and cons but just haven’t pulled the trigger? My guest today, Jordon Comstock, has simplified the process by creating BoomCloud—Dental Membership Software. In this episode of Talking with the Toothcop we talk about why a dental membership plan is worth it, having systems in place, and the BoomCloud interface.

Both Jordon’s parents were in the dental industry and he started as a lab tech. Most of his immediate and extended family are in dentistry. He grew up surrounded by the struggles of dental offices and sought to create a plan to help simplify their business—but amplify their results. The software he created helps dentists easily manage a membership plan. Listen to this episode for details!

Outline of This Episode * [1:10] Jordan’s history in the dental industry * [6:18] The benefits of a membership program * [10:25] Solving the access to care issue * [12:09] Regulations regarding memberships * [15:05] Dental practice success stories * [21:27] What membership programs do for your practice * [24:07] What to understand from a compliance perspective * [27:13] The benefits of working with BoomCloud * [33:41] Jordon’s automatic insurance verification app

What are the benefits of a dental membership program? Dental providers—and patients—often vent about how miserable it is to work with dental insurance. They often deny payment on claims or reduce reimbursements and can make a dent in your revenue stream. Starting a membership program in your practice is a way to offset troublesome insurance issues—and provide care to patients without dental insurance.

Jordon shares that an average membership a practice will offer is $30 a month or $350 a year, but that it varies from practice-to-practice. It would cover things such as exams, cleanings, and x-rays and offer a percentage off procedures. You can look at it as the Amazon Prime of dentistry. Jordon has noticed that patients enrolled in a membership spend 2-3x more than someone using insurance would.

Above all, it provides you a consistent recurring revenue stream for your practice. It can also offset slow months when a practice is billing fewer procedures.

3 case studies that show the membership model works Jordon shares about 3 practices who adopted a membership program and how they made it work:

The first practice had 500 patients sign up throughout one year. They looked up how many patients they treated consistently who were without dental insurance and offered them the membership at their next appointment. They combined this with an email blast to all of their patients. Now, they have $12,000 of recurring revenue month, whether or not any work is done.
The second dental practice enrolled 1,000 patients in their program with $25,000 in recurring monthly revenue. On top of talking with their uninsured patient-base, they focused on Facebook ads. One particular year they grew by 370% percent.
The 3rd practice had 2,000 people sign up with $40,000 in recurring revenue. They used direct mail marketing and targeted communities ages 55+ who would be looking at retirement and facing the loss of dental insurance.

Every strategy works, you just need to pinpoint what’s best for your practice. And with approximately 180 million Americans without insurance, your program can offer dental care to those without access.

Smart business owners don’t start from zero A traditional dental practice starts from scratch every month and must work their way up to the cash flow needed to support their business—and cash flow is a huge problem in the dental industry. A membership program removes the problem. Small business owners need to focus on reducing risk. A membership program removes your reliance on PPOs as a revenue-stream.

It gives your practice stability. Many successful practices adopt a hybrid approach: they stop working with difficult dental insurance plans with while launching their program. They continue working with the policies that afford them a decent profit margin. It’s a win-win for your dental practice and your patients.

Launching a program also reduces issues with insurance companies. You still need to keep records for patients and procedures—but your risk of recoupment from insurances due to “record-keeping problems” will be reduced. Keep listening to find out the simple thing you need to do to protect your practice from a compliance standpoint.

Systems help you scale I asked Jordon to talk about BoomCloud and some of the benefits their platform offers. Here’s a snapshot of what you get:

BoomCloud offers a dashboard that shows monthly and yearly revenue, active patients, cancellations, and more.
They have tools/systems to remind patients of bills, if a credit card was declined, etc.
ACH function—patients can connect their bank account and their monthly fee can be automatically withdrawn
The ability to choose a proven membership template
You can easily verify that a client’s membership is active and that they’re paying their fee
They even offer a patient portal

Anyone can start a membership program for their practice, but it is far easier to manage when you can rely on software—and not a team member trying to track the details on their own. The more members you add, the harder it will become to manage on your own, and that’s where BoomCloud simplifies the process.

Listen to the whole episode for complete details on Dental Memberships, BoomCloud, and Jordon’s automatic insurance verification app for dentists—JetPack.

Resources & People Mentioned * The Insurance Extravaganza Conference * Connect with Jordon Comstock on LinkedIn * BoomCloud Dental Membership Software * BoomCloud Free eBook * BOOK: The Automatic Customer * JetPack Dental Insurance Verification * Jordon’s podcast: Say No To PPOs * Jordon(at)BoomCloudApps.com

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

The Automatic Customer: Creating a Subscription Business in Any Industry

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While it’s a phrase straight from the mouth of Paul Blart: Mall Cop, it holds true. Safety never takes a holiday, and the safety of your staff and patients should be first and foremost in your mind. Dental professionals need to be educated on proper procedures for cleaning and sterilizing the tools that they’re using every day so they’re not exposing people to pathogens.

Over the course of this next quarter, I’m dispatching to different dental offices that we work with to conduct a series of experiments. The goal is to find out if the most stringent infection control procedures that we utilize are doing enough. If they aren’t, then it’s time to make some changes to our checklists and procedures as well as in the dental industry as a whole.

Outline of This Episode * [1:30] Infection prevention and control and my upcoming project * [11:09] The importance of sterilizing your equipment * [17:59] Learn how to read and follow IFUs * [26:36] Addressing lack of formal infection control training * [32:22] Learn how to properly use your ultrasonic * [41:01] Make sure you’re receiving the proper vaccinations * [42:48] Wear proper protective gear: gloves * [46:56] The alarming biofilm being found in dental waterlines * [1:02:49] How does infection control apply to ortho?

Texas—and all states—should require infection prevention and control training There is no infection control training in Texas and quite honestly, they’re behind the times. Admittedly, they aren’t as forward-thinking as other states. I believe that very few schools—and not just in Texas—are teaching current standards in their curriculum. It begs the question, are our dental assistants getting the proper training?

What about dentists? I’ve found that some schools of dentistry have their dental students go through a rotation where they learn how to process and sterilize their instruments. But most instrument processing is done by a paid staff and dentists are never educated on the proper procedure for cleaning their tools.

This has got to change. There is a gross lack of knowledge and a whole lot of misunderstanding in the industry. Many dentists and their assistants are learning techniques and procedures from sales reps who don’t know what they’re talking about. They’re often the only outside contact that dentists have which is a problem in and of itself.

Very few dental offices properly use their ultrasonic Dental staff often overlook one simple thing that will give them the answers to proper sterilization procedures—Instructions For Use (IFUs). It’s a user manual for your instruments that lays out the exact procedure to properly use, clean, and sterilize your tools. It’s pretty idiot-proof.

There’s an amazing product called SonoCheck—it’s a tablet that you drop into your ultrasonic to test if it’s working properly. You drop it in green and it should come out yellow. If there are major problems with your Ultrasonic cleaner, it won’t change colors at all.

I’ve seen time and time again that offices just crank the dial on the ultrasonic to whatever time it lands on and expect it to clean their instruments. Most are only doing half the time required in their instruments IFUs. Dental offices NEED to start using them for the correct amount of time. They also should use critical water, the right amount of water at the right temperature, and enough of the right kinds of enzymes.

The bottom line is if the instruments aren’t processed long enough and in the proper manner, they won’t be clean. You’ll be using dirty instruments on your patients.

The often overlooked tactic to protect your staff It’s simple and highly effective: wear the right kind of protective gloves. Most dentists, hygienists, assistants, etc. are required to get a Hepatitis B vaccine. Most do it before they finish school but some don’t finish the series. They don’t get tested to make sure they have the antibodies if they’re exposed. It’s currently the only required vaccination.

But if you’re not wearing protective gloves and get stuck by an instrument used on a patient, you’re exposing yourself to other pathogens as well. It could be hepatitis B, Syphilis, Malaria—anything bloodborne. You must assume that everyone is sick and that every instrument is trying to kill you until proven otherwise.

Gloves are inconvenient, sure. But you CAN learn how to process instruments with gloves. Train until you get comfortable with them, but for heaven’s sake wear the dang gloves!

Treat your water lines regularly and monitor them for biofilm We’ve talked about this before, but biofilm is a buildup of bacteria (both good and bad) that can adhere to water lines. They’re terribly difficult to kill and the longer they go unnoticed the more difficult it becomes. I believe states will start mandating water line testing. My advice? Don’t wait until it’s mandated.

In 2016, a dental unit water line in Anaheim, CA was contaminated with a mycobacterium. It was discovered when dozens of children showed up complaining of facial swelling and pain. Their faces and jawbones were infected with this bacteria. One child had the bacteria progress so severely that she had to have part of her jaw bone removed—all because of an untested waterline in a dental office.

The hassle it may cost you is not worth the PR nightmare. It’s not worth losing your license, your practice, and perhaps your freedom. Test your water lines, treat them with shock treatments, and replace them if necessary. You must know how to monitor and maintain control of your water quality.

Jacque and I discuss in-depth testing and cleaning of water lines, proper use of ultrasonic equipment, how these strategies apply to ortho, and much more. Be sure to listen to the whole episode to learn how to better protect your practice!

Resources & People Mentioned * OSAP * OSHA * AAMI ST79:2017 * Sonocheck * Brandmax Triple Enzyme Cleaner * ProEdge Dental Water Labs * Aquasept

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In this special Q&A episode of Talking with the Toothcop, Jacque and I will tackle questions we’ve been receiving from listeners. We want to preface this episode by saying that we never intend to promote our business with this podcast. First and foremost, we want to focus on educating the dental community about compliance. However, we’ve received so many questions about what we do that we thought we’d address them all in this episode! Listen to hear how I became The Toothcop, what exactly it is that we do, and some specific things to watch out for in your office.

Outline of This Episode * [0:21] Answering Listener questions * [1:45] How Duane got started in Dental Compliance * [5:05] Starting a business that didn’t exist * [8:30] The chief nerd at Dental Compliance Specialists * [10:00] The business at the beginning * [12:58] Building relationships with dental offices * [19:11] Do everything we tell you to do * [28:54] How to get your staff on board * [35:59] We help monitor and train * [40:45] What exactly is it that we do? * [47:20] Chart and record audits * [51:40] What happens when you don’t heed our advice * [1:01:07] What you need to know about exclusion checks * [1:08:50] Corporate Integrity Agreements (CIA) * [1:10:55] Above all—don’t panic!

My journey from street cop to toothcop People are often curious how I got into dental compliance. It doesn’t seem like a natural segue from being a deputy sheriff to a dental compliance specialist. However, it truly was a natural progression. After being a street cop, I had the opportunity to work for the state dental board investigating cases for them. I really was a toothcop—I still wore a gun and carried handcuffs when I walked into a dental office.

As I investigated dental fraud and other concerns that arose, I began to realize that I could do something to help prevent these issues from happening. These dental offices weren’t necessarily intending to commit fraud or allow patients to be harmed—they just didn’t know what they didn’t know. So I quit being a cop. Then I started reaching out to offices that I had investigated, offering to help them learn how to prevent what was wrong.

We started a business in a space that didn’t really exist. Even now, there is only a small group of people that do what we do. We were simply armed with an idea and blind faith that we could make it happen. We believe what we do matters and truly makes a difference in people’s lives—even if we can’t quantify it.

What exactly do we do at Dental Compliance Specialists? When I dove headfirst into dental compliance I did a lot of traveling. I was in dental offices with my checklist in hand covering state board requirements, observing staff, and answering questions. We were continually adding in more checklists that covered OSHA, HIPAA compliance, infection control, and more. I would find issues, take notes, and train as I went along. I was going into offices every quarter and running into the same issues—no one was retaining what I taught them. Talk about frustrating!

I was on the verge of complete burnout and told Jacque I didn’t think I could do this anymore. If they don’t remember the training or implement changes, what was the point?

Jacque said “give me a year” and we got to work, brainstorming how we could streamline the process. Now, we have a system in place for everything. We broke our compliance training down into 12 modules. Each month a dental office is given a virtual module to cover. We leverage technology and do inspections in small pieces (i.e. one visit is just for radiology training). Doing this gave them manageable chunks to learn and retain, and we were interacting and answering questions monthly vs. quarterly.

It’s about building relationships based on confidentiality Our entire business is based on confidentiality. We want to work with dental offices to improve their compliance, not penalize them for existing issues. We don’t disclose who we work with or what the compliance issues are. Even if clients permit us to share that we’ve worked with them, we won’t share anything we’ve done. We want to build trust to facilitate dialogue—to make you feel comfortable and not judged.

No one is perfect and no office is perfect. In all of the years we’ve been doing this, maybe 2-3 offices have come close to passing my initial compliance inspection. I’ve seen some pretty horrendous things in offices full of pretty great people. I remind them things are fixable and help them figure out how to implement changes and often see significant changes for the better in “before & afters”.

We can’t tell you how many patients or staff members didn’t get sick. We can’t tell you how many fines or recoupments we helped you avoid. But we can help give you peace of mind. We can train your staff to reach the highest level of compliance standards. You can rest easy knowing that you’ve done everything you can to protect your business and your patients.

Most common question: What is required vs. recommended? This one just makes us shake our heads. We understand that some people are comfortable in gray areas and others prefer black and white. But we would never recommend something if it was just optional. Everything we put in our checklists and training modules help you obtain the highest level of compliance. It protects you, your staff, and your patients.

It’s not just about “best practices” anymore. You can get fined. You can go to jail. Even if you don’t have malicious intent, you will be held responsible for mistakes made. So we don’t skip steps. Our system for nailing down compliance failures and integrating guidelines to implement change is tested, tried, and true. So you need to ask yourself the question, “is it legal, ethical, and does it reflect my values? If the answer is no, it’s time to make some changes.

Jacque and I dive deep into specific questions covering chart and record audits, exclusion checks, corporate integrity agreements, and so much more—be sure to listen to this important and educational episode. We don’t want you to feel overwhelmed, but equipped. Above all, don’t panic. If some of these topics leave you with a sinking feeling in the pit of your stomach reach out to us! We’d love to help.

Resources & People Mentioned * Blog: 7 Key Elements of a Compliance Plan

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Dental insurance billing is something many dental offices struggle with because it can be so complex. When do you bill? What rates do you bill? What if the patient has two insurance coverages?How do you keep your office organized and implement a system? It’s a lot to remember. Colleen Huff joins me in this episode of Talking with the Toothcop to answer some of those questions—and help you simplify the process.

Colleen Huff has been everything from a bookkeeper to a scheduling coordinator, with extensive experience managing practices. In her management role, she saw a severe lack of training—to the point dental offices were engaging in illegal billing practices and didn’t know it. So she started educating others on proper practice. Colleen has been a dental insurance coach for the last 17 years.

Outline of This Episode * [0:20] Colleen Huff’s background * [5:05] Can you simplify the dental billing process? * [15:45] The biggest mistake dental offices make * [19:20] Anyone engaging in fraudulent billing is liable * [22:10] Understanding insurance breakdowns * [26:20] Dealing with multiple insurance coverages * [28:05] Common issues offices struggle with * [30:55] How do you systematize and organize? * [34:20] Connect with Colleen

How do you simplify the verification process? We’re at the beginning of the year right now, when many clients have switched to new insurance—which typically means a mad scramble to verify coverage. Coleen does everything she can to make sure insurance is verified weeks before a patient’s appointment so they can contact them about any problems that arise.

If a client has a Medicaid policy—which can terminate at a moment's notice—you must be sure to verify it the day of the appointment. She also recommends doing this for commercial insurance plans because they no longer run on just a calendar year. Many are contract year, benefit year, or even a rolling year based on employee hire date.

It is preferable to know ahead of time whether or not there will be a financial challenge for you and your patient. You can notify the client upfront, instead of billing them later and dealing with an angry client. With the real-time eligibility systems in place, the process has become much easier. Listen as Colleen and I chat about how she documents the process and communicates problems with patients.

The biggest mistake dental offices make The #1 problem Colleen sees in dental offices is not submitting claims on the proper completion date. Many offices send claims before the work isn’t completed, citing that “everyone does it” or “no one ever gets caught”. Doing so is dangerous for your practice. You need to submit the claim for the proper date the procedure(s) was completed or face the consequences when you’re caught. It will be jail time.

It’s not just the Dentists that can be prosecuted. A billing staff who knowingly submits fraudulent claims can be found at fault. Whining that “The Dentist told me to!” will not protect you. If you are part of the billing staff you must be reviewing claims before you send them.

It comes down to integrity. The more you allow and the more “little” discrepancies that you let slide will make an impact. Make sure your morals and beliefs align with how you are operating your practice. We talk about an incident where a provider did end up in prison and the reason behind it—keep listening.

Why insurance breakdowns are important Colleen and I agree: you must know how much a procedure will cost a patient. Run the verification, make whatever calls necessary, and print out a breakdown of what a client will owe. Then, collect whatever copay is necessary. Your billing will be more accurate. This also removes the chance of most—if not all—surprises and helps you avoid a patient getting an unexpected bill.

Some offices struggle with moving into the 21st century and claim that “Patients should understand their insurance and what they charge”. Colleen is more familiar with insurance than most people, but even she doesn’t know everything—and you can’t expect your patients to either. Gathering information on the front end is important.

Is it time-consuming? It can be. But most insurance companies have a way for you to check verification and coding online. Sometimes it may take a phone call. But it saves you future hassle and makes your patients feel relieved and secure in your ability. Referrals come from happy customers, and the more you simplify the process for them, the happier they’ll be.

Your dental insurance billing questions answered Colleen took some time to answer common questions and issues that dental offices struggle with:

If a client has two insurance policies, which is primary and which is secondary? There are a few simple rules. First, a Medicaid policy is always secondary (except for a few rare circumstances). Your plan is always primary to your spouses. For a minor child, unless court-ordered differently, the parent with the earliest birth date in the year is the primary insurance.
Should you bill your full fee or the contracted rate? Always bill your full fee. The insurance company will pay the contracted rate and you adjust off the rest based on the contracted fee schedule.
How do I negotiate fee schedules? Colleen notes that you must be billing your full rate. If you don’t, an insurance company will see that they’re already paying you what you’re asking, and you have no leverage for negotiation. It takes time, but if you go through the proper channels you can see a fee schedule increase.
What is the difference between a write-off and an adjustment? A write-off is when you bill the insurance for something that’s not covered according to your contracted agreement or the patient’s policy. If the service was carried out, you may NOT bill the client for the cost and must write it off. An adjustment is an amount that is adjusted off the bill sent to the insurance company. They pay you the rate your contracted for and nothing more.

Listen to the whole episode as Colleen shares her background in the industry, strategies for staying organized, things to keep an eye out for, and much more!

Resources & People Mentioned * Colleen Huff’s Facebook page * NADP Conference * Colleen’s Website * Colleen’s email: DentalInsuranceCoach(at)gmail.com

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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How to Utilize Instructions for Use in Infection ControlInstructions for Use (IFUs) should be included with any and every medical device that you use in your practice. Learning how to properly use and follow IFUs will aid in proper infection control. As we are rolling into 2020, improvement in infection control in dentistry is at the forefront of my mind. So in this episode of Talking with the Toothcop we’re going to cover how to properly clean and disinfect medical devices (and how to reference the IFUs). Check it out!

Outline of This Episode * [0:20] Welcome to 2020! * [4:55] Infection control and room for improvement * [6:30] Policy to practice book from OSAP takeaways * [7:45] Properly use IFU’s (Instruction for Use) * [13:30] You need written policies and procedures for infection control * [17:45] Enzyme solution and critical water * [22:55] Proper care of hinged instruments * [24:45] Spot-testing in dental offices * [26:30] Infection control testing coming in 2020! * [31:00] Move in one direction and never backward

Why Instructions for Use are SO important Instructions for Use teach you how to properly use any and all medical devices that you use in your practices. Everything is regulated by the FDA—each product HAS to provide an IFU to remain compliant. They’ll tell you how to use it, care for it, clean and sterilize it, and how to store it. They are comprehensive guidelines for the proper care of your devices to increase longevity and protect your patients.

The process of cleaning your medical devices I want to just walk through the general steps (and everything you need to consider) as you clean and sterilize your medical devices:

Transporting the instrument(s): When you are transporting devices from the operatory to the sterilization room you must consult the IFU. For example, If it’s a sharps device, you must transport it in a closed container that cannot be permeated and label it as a biohazard.
Rinsing the instrument(s): Does your devices IFU specify that it needs to be rinsed in a certain type of water? Many now require that they are rinsed in critical water.
The Ultrasonic bath: Are you sterilizing hand instruments? Drills? Cavitron tips? For each item, you have to consult their specific IFU to properly clean and sterilize them.
Enzyme solution: What type of enzyme solution to you need? Protease, amylase, or lipase? All three? How many squirts or tablets per amount of water being used? Guess what—your IFU will tell you everything you need to know. You also need to de-gas your ultrasonic by running it for 10 minutes before putting your instruments in.
Second Rinse: You NEED to use critical water again! Most people are using tap water, and it’s probably not doing the job.

Instruments are expensive. You want to properly care for them and the best way to do that is by following their instructions for use. Andrea and I talk about considerations for hinged instruments, so keep listening!

Written policies and procedures Most offices don’t have written policies and procedures in place for infection control. Or, they’re so generic that they’re useless as a guideline. But you need one for your practice. I’ve found that the best infection control guidelines that you can find online come from dental schools. But you can’t just grab their manual and call it good.

You need to take their baseline and edit it. Structure it for the proper verbiage for your practice. Make sure it addresses policies for stages of the instrument process, sterilization, transport, storage, to reuse or not reuse, surgical milk—the list goes on.

This is its own training manual. You can’t tuck into an OSHA manual. You need to have systems in place to properly update it and make sure all staff are reviewing it consistently. Keep listening as Andrea and I chat about the specifics.

Infection Control in 2020: Where are we headed? Good enough isn’t good enough. I’ve spent hours researching infection control and am investing in some tests that I will use this year. I’ll be able to see in-the-moment if a dentist’s office is properly cleaning and sterilizing their instruments.

My goal is to track my testing and make the data consistent, measurable, and reliable. We don’t want to see what we think are water spots or rust on instruments and find out that they are biological. We need to set a higher standard for ourselves and our patients. That begins with proper infection control.

The CDC doesn’t spend time studying dentistry, so we need to make sure that our standards go above and beyond what is in place. Listen to the whole episode as Andrea and I chat about our plan for 2020.

Resources & People Mentioned * Ole and Lena Jokes * OSAP * FDA format guidelines for IFUs * Supercritical Water Oxidation

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Airborne diseases in dentistry are unfortunately prevalent but preventable. Protecting yourself, your staff, and your patients from aerosols should be a priority in your practice. We are all up-in-arms about bloodborne pathogens and do everything in our power to prevent them, but we neglect airborne diseases. That needs to change! Michelle Strange joins me in this episode of Talking with the Toothcop to start the conversation.

Michelle has been in the dental industry since 2000, and a licensed hygienist since 2005. At one point, she was an OSHA Compliance Manager and Director of Clinical Education at O2 Nose Filters. She left private practice 5 years ago and is now an Educational Consultant for TePe Oral Hygiene Products. Michelle also co-hosts a podcast, “A Tale of Two Hygienists”.

Outline of This Episode * [0:20] I introduce my guest, Michelle Strange. * [3:05] Research on dental aerosols * [4:05] The conversation about airborne diseases * [6:40] Personal Protective Equipment * [10:25] Protect your patients and staff * [16:00] The psychology of bias * [19:30] Transparent conversations with your patients * [24:15] The dangers of chemical aerosols * [27:55] How different personalities deal with change * [32:35] Wrap your head around the why

The lowdown on airborne diseases There are many safety protocols in place to prevent the transmission of bloodborne pathogens. A standard has been set that professionals must follow to protect themselves. But when it comes to airborne diseases, most providers aren’t even using the correct protective mask.

Chickenpox, Measles, Mumps, Tuberculosis, Herpes, and the common cold are all respiratory diseases transferred in aerosols.

Bloodborne diseases can only be transferred if you are cut, and you are exposed to contaminated blood. Airborne diseases can be spread if someone simply breathes or coughs! The dental industry doesn’t address this as well as they should—that needs to change.

The importance of Personal Protective Equipment (PPE) Because of the ease of transmission, it is imperative that you’re utilizing the proper PPE. Michelle has always had a proclivity for proper infection control. She made sure to use the Ultrasonic and air polishers for every single patient.

But when she was working as a hygienist, she was always sick with a sinus infection or bronchitis. It got so bad that her patients would comment it was odd when she wasn’t sick! Michelle is convinced it’s because she never knew the proper level of mask she should be wearing.

When you are working with high levels of aerosols, you need to be using a level three mask. Not only for your protection but your patients as well. Michelle and I cover the topic in detail—keep listening!

The Dunning–Kruger effect: overcome cognitive bias in dentistry The Dunning-Kruger effect, simply paraphrased, implies that we as professionals believe we are more qualified than we actually are. Michelle contends that we need to consistently work to overcome our cognitive bias that we ‘know it all’. It’s important to remember that what you were taught in the ‘80s is going to be outdated.

Science is constantly evolving in the world of dentistry. We are constantly learning about new ways to treat and prevent disease. Keep an open mind and allow yourself to be challenged and always question the status quo. Your mindset must always come back to the proper protection of staff and patients.

Michelle and I believe there needs to be more transparent conversations with patients in the dental industry. It’s okay to admit that you’re not always the expert. Inform them that you’re staying on top of new research and new procedures and will always keep them in the loop on their treatment.

It’s not just biological—be aware of chemical aerosols as well While airborne diseases are the aerosol that can be the most concerning, Michelle and I felt the need to caution you about chemical aerosols as well. When you’re working in the lab carving dentures or trimming models those particulates are quite fine.

So are you wearing the proper mask? Are you breathing in those particles? Do office staff enter the work areas without proper PPE? People aren’t just getting sick, they’re getting really sick. You need to cultivate an awareness of these concerns and educate your staff and patients.

Dentistry is the highest producer of aerosols, but dental masks are based on medical standards. Michelle and I discuss the need for dental standards as well as some other concerns that impact change in the dental office. Listen to the whole episode for more important information.

Resources & People Mentioned * O2 Nose Filters * The Dunning-Kruger effect

Connect with Michelle Strange * Michelle on LinkedIn * Michelle’s podcast * TePe USA Educator

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Dental billing is an ever-changing process. As a dental provider, how do you stay on top of changing regulations and coding? Do you outsource your billing? Leslie Icenogle joins me today to talk about medical billing for dentistry and where it overlaps with dental billing. We also chat about outsourcing your billing and continuing education for your staff.

Leslie got her start in pediatric dentistry over 30 years ago and has worked in oral surgery for 32 years. She has extensive experience dealing with medical billing and started teaching dental practices how to integrate medical billing. After a couple of years of being asked to take on the work herself, Insurance Billing Outsourcing was born.

Outline of This Episode * [0:30] Leslie Icenogle’s background in dentistry * [3:05] ICD-10 Diagnosis in Dentistry * [8:00] SOAP notes: subjective, objective, assessment, and plan * [10:45] How do you make the process easier? * [13:50] Compliance and cash flow go hand-in-hand * [16:15] Outsourcing is sharing liability * [22:20] Cleaning up your billing practices * [26:05] High turnover in billing positions * [27:55] Connect with Leslie

Understanding medical billing in dentistry Dental and medical billing is at a crossroads, where many things will now be required to be billed to medical insurance primary to dental insurance. Many states already require claims to be submitted with the proper ICD10 coding in place. You’ll begin to see (or continue to see) dental insurance denying claims because they were looking for denial or payment from the medical insurance first.

A lot of treatment that dentists could be billing is not being billed—which is a win for the medical insurance and a loss for you.

It will be a learning curve to understand how to begin coding these claims properly. This is where Leslie would step in and offer proper training to your staff. You must learn how to correctly file with the proper attachments, write letters of medical necessity, and learn how to properly read Explanation of Benefits (EOB’s). If this is something you’re not ready to implement completely, consider outsourcing to a company such as Leslie’s.

SOAP Notes: The importance of documentation The ‘SOAP’ acronym stands for subjective, objective, assessment, and plan. It is a note-taking system that your practice will need to begin implementing. Medical insurance is all about documenting the details. If you’re doing anything other than a simple cleaning, they want to know why the patient is being seen.

What is the chief complaint? How did it happen? What is the history of the illness/issue and was it properly treated? Document their HPI (History of Present Illness) extensively.

Your notes must be clear and detailed. Leslie and I both recommend creating a template where you can input the proper patient information. It helps simplify the process and keeps you consistent.

Clean up and simplify your dental billing As Leslie has worked in the field, she’s found that most dentists are receptive to her feedback or criticisms. After all, the entire goal of cleaning up your billing and learning new processes is to increase cash flow! There are a few ways you can clean up your process as you’re learning the new coding:

Create a template that allows you to easily input a patient’s information and history.
Verify benefits for the medical and dental insurance on the front end, and do so correctly.
Assign someone—perhaps your office manager—to conduct an audit of patient files. They can assess if the notes are detailed enough, if the insurance was verified correctly, and that the claim was filed properly.

Is the person handling the billing truly able to dedicate all of their time to it? Or are they being pulled in different directions? Another option you can consider to reduce the burden on your staff is to outsource billing.

Invest in education for your billing team If your practice has designated billing staff—take good care of them. Leslie and I see high turnover rates in billing positions. Often, it’s due to improper training (or lack of training). You must invest in continued education for your billing staff and not let them fall to the wayside. We recommend implementing training annually.

This allows your staff to stay up-to-date on the changing rules and regulations in medical and dental billing. It also properly equips them for their job. Ignorance is NOT bliss and your practice could be hemorrhaging money. Spend a little money on the front end on training to amplify the cash flow coming in from proper billing.

Leslie and I talk about the benefits of utilizing ICD-10 coding and why you shouldn’t resist it. Don’t miss this engaging episode of Talking with the Toothcop!

Connect With Leslie * Leslie on LinkedIn * Insurance Billing Outsourcing Website * Call IBO at 317-565-4988 * Leslie(at)USEIBO.com

Resources & People Mentioned * ADA Lawsuit against Delta Dental * ICD Coding in Dental Claims

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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What are some of the security measures you need to have in place to protect your practice? In today’s day and age, security breaches can come from many different directions. In this episode of Talking with the Toothcop, Andrea and I will lay out some ways you can protect your business. From security breaches to controlled substance regulations—we’ve got you covered.

Outline of This Episode * [0:20] Cyber Ransom Attacks * [4:55] What does a breach mean for you? * [8:30] Prepare for potential breaches. * [13:20] HIPAA security and privacy officer * [14:40] Bootcamp will cover liability and compliance * [17:50] How to prepare for and handle “Never Events” * [23:10] Controlled substance rules and regulations * [27:15] Change in DEA regulations * [28:10] Controlled substance storage * [30:30] Stop over-prescribing antibiotics

Cyber attacks are the real deal It’s a new era, and cyberattacks are becoming more prevalent. A hacker will infect your system with an encryption virus, and to regain access you have to pay a ransom. This isn’t just a thing happening on TV shows anymore. It’s something that has to be investigated by the FBI, reported to the Office for Civil Rights (OCR), and potentially even media outlets.

Is there anything you can do to prepare? What do you are attacked?

Invest in a great IT company that will answer any questions you may have.
Obtain adequate cyber-insurance coverage.
Have legal counsel in place that you can call if it’s ever necessary.
Prepare as well as you can—make sure you have more than adequate website security.

Don’t let your practice be compromised and watch your reputation take a nose-dive. Do everything you possibly can to protect your practice and your clients. We give you a few options in this episode!

HIPAA breaches and how to prevent them If you do indeed experience a breach of protected health information, you must have systems in place to handle the situation. You need a designated privacy officer and security officer. If you’ve done your due diligence and have systems in place, it can be taken into consideration if there is an investigation. A forensic investigation is recommended (especially in the case of a cyber-attack) to determine the scope of the breach and what information was affected.

Assess where your vulnerabilities may be and take preventative action. Was there a change in technology? Where are your gaps? Don’t simply rely on your IT company telling you that you’re safe—ask questions so that you understand and know you’ve done everything possible.

How to prevent “Never Events” “Never Events”, usually referred to as “Sentinel Events” are unanticipated extraordinary events that incur serious injury, illness, or the death of a patient. Unfortunately, events like these can and do happen (we talk about prevention and preparedness in depth in this episode).

Even if you do everything right and are a great clinician, the litigation and stress involved in the process can be debilitating. You can’t turn back time—but you can be proactive. Have checklists in place to make sure life-saving medical devices are checked regularly. Practice life-saving procedures with your staff. Be prepared for the unexpected.

Controlled substance rules, regulations, and safety measures A state board rule was enacted in Texas eff. September 1st requiring providers to check a patient's substance history before prescribing controlled substances. There are also whispers that a law will be enacted in 2020 that will only allow prescriptions for controlled substances to be done electronically. Do your research now to find a compatible software to have in place by the time this is state law!

It’s an added safety measure that will protect you from some liability as well as protect your patient’s life. In the meantime, if you prescribe or utilize controlled substances they must be securely locked up (behind TWO locks and TWO keys). You must have a log to track dispensing that is stored safely with the drugs.

Andrea and I talk in detail about security measures, HIPAA breaches, drug regulations and much more so be sure to listen to the whole episode for details!

Resources & People Mentioned * Allscripts * Office for Civil Rights (OCR)

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Everyone lives by the mantra that medical emergencies in the dental office will “never happen to us”. Patients certainly don’t think about that when they schedule a dentist appointment. But it is your job as a provider to be prepared for the unthinkable. Failure to plan is a plan to fail. There is risk in what you do whether you think about it or not. We cover medical emergencies in detail in this episode of Talking with the Toothcop—be sure to listen!

Outline of This Episode * [1:30] Preparing for Medical Emergencies * [6:00] Do scenario training until you don’t fail * [7:55] Combating opiate abuse in the dental office * [13:50] Use your intuition and don’t make stupid decisions * [17:15] Sedation Rules: Pre Anesthesia Checklist * [21:20] Opioid addiction resources for Texas * [24:10] Tracking claim denials and implementing systems * [26:00] Learn proper administration of emergency medications * [35:50] Why do we do what we do? * [39:00] DEA Registration and resources * [40:10] ‘Trust but Monitor’ in practice * [46:40] People can’t afford for us to get it wrong * [48:30] Details about the annual Dental Compliance Bootcamp!

Do scenario training to prepare for medical emergencies in the dental office Run through scenarios with your team. What do you do if a patient goes into cardiac arrest? What do you do if they have an allergic reaction or don’t handle sedation well? Strategize what you would do in these scenarios and talk about how emotions will play a factor in your ability to carry out what your plan.

Run through your weaknesses extensively—because a patient can’t afford the luxury of you only playing to your strengths.

The only way to truly prepare for an emergency is to make a plan and test your plan extensively. You cannot run a one-and-done test. You must practice until you don’t get it wrong. Practice doesn’t make perfect. Practice until you reach perfection. Remember that it could very well be someone’s life that is at stake and plan accordingly.

Combating opioid addiction in the dental office Dentists and dental staff deal with the same problems everyone else does. Unfortunately, due to the nature of their professions, they have easy access to addictive substances. If you’re a dental provider struggling with a problem but claim to have it “managed”—it will catch up with you. Don’t risk your license, your practice, your family, or your life. Get help now. Check out the resources in our show notes.

On the flip-side, you must carefully monitor the controlled substances that you are prescribing. You must check your patient’s consumption history and make sure they are not abusing the system. You have an obligation—both morally and ethically—to treat your patient’s pain, while not jeopardizing your license. Bottom line? Use your intuition and don’t make stupid choices.

Listen as Andrea and I discuss in detail specific stories of opioid abuse and the consequences suffered by those involved. We also talk about DEA registration and why it’s needed for every location you practice at.

Know how to properly use life-saving medications You must have an emergency drug kit on hand to deal with whatever medical emergency you feel could arise—and know how to properly administer them. You NEED to be proficient in Basic Life Support (BLS) and Pediatric Advanced Life Support (PALS). But don’t just stay up-to-date on your certifications, be sure you consistently practice the procedures.

It does you and your patients no good if you have a certification, but when the time comes that you need it, you fall short. You must provide the highest standard of care and prepare for the worst-case scenario.

If you offer sedation at your practice, you must have the medications on hand to reverse the sedation. Typically you’ll also need to know how to set up an IV and administer medications that way. So practice practice practice.

Why do we do what we do? Our Mission: build authentic relationships we build our legacy of making dental practices safer for patients, dentists, and staff by holding quality-focused professionals accountable to their standards.

Our Vision: is not merely to exist but to be better, do better, and live better so that no one is harmed by a dental practice.

Our goal is to equip you to think for yourself and practice the “trust but monitor” mantra. Always be sure to locate the source of the information—even when it’s coming from me. Remember, our patients can’t afford for us to make mistakes!

Resources & People Mentioned * Professional Recovery Network Website * PRN’s phone number: 800-727-5152 * DEA’s Practitioner’s Manual * Check out our Dental Compliance Bootcamp!

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Today’s episode of Talking with the Toothcop is all about the fascinating topic of staying up-to-date with your equipment evaluations and dental policies and procedures. Yes, I think compliance IS fascinating! Andrea and I cover everything from blood-borne pathogens to X-Ray equipment—don’t miss this important episode.

Outline of This Episode * [0:23] What Andrea and I are going to cover * [3:20] X-Ray law updates in Texas * [7:05] Written policies and procedures * [15:50] HIPAA and monitoring PHI * [35:25] Hepatitis B Prevention and vaccination * [37:05] Minimizing exposure & safety protocols * [41:20] 75 Hard update * [45:00] PPE provided at no cost * [50:00] You can’t always see your enemy * [53:50] Provide proper post-exposure care * [56:45] Sterilization of single-use items

Dental policies, procedures, and prevention! The whole reason you have written policies and procedures is to protect yourself, your staff, and your patients. In theory—really though, in practice—you should have a written policy to address every risk area you may encounter in your dental office. These are a few of my favorite things:

HIPAA manual
Infection control handbook
OSHA policy
Proper billing procedures
Clinical policies
Medical emergency policies

The list goes on! It can be in multiple manuals or one large handbook, but it’s important that you know what’s in it and that your staff knows where to find it. As a general rule of thumb, you need to review your policies and procedures annually and update them as needed.

Make sure that your manual is legal, ethical, and reflects the values of your organization.

I always feel like somebody’s watching me… ...and I got no privacy! Seriously though—you NEED to make sure you are monitoring your office’s server access logs. Is a login being used outside of business hours on a normal basis? Did you notice the login of a former employee is being accessed? It is important to monitor for irregularities and anomalies so you know when and if you’ve been hacked.

It’s all about protecting your patient’s protected health information (PHI).

This is why it is the law that everyone in your practice has different usernames and passwords for the systems in place that are not shared. This allows you to monitor access, as well as only allow access to certain roles that fit an employee’s role. You must keep audit logs of your servers for 6 years in case of an audit.

Down to the nitty-gritty: Blood-born pathogens and prevention You must offer Hepatitis B vaccinations to your staff at no cost to them. You want your employees to get the vaccination within 10 days of being hired and have them sign a document stating: they’ve had the vaccination, they’ve previously been vaccinated, or they acknowledge it’s been offered and decline the vaccination.

So what can you do to prevent the spread of a blood-born pathogen? You can minimize exposure by:

Using High-Volume Evacuators
Use needle-capping devices
Use puncture-resistant sharps containers
Provide hand washing/hand sanitizer stations
Provide Personal Protective Equipment (PPE) at no cost

Follow the policies and procedures you’ve set forth and you’re 99% of the way towards protecting your staff. Andrea and I cover a whole lot more—keep listening.

What do you do when the unthinkable happens? Protecting your staff isn’t just about prevention. Sometimes, mistakes happen and you or a staff member may have been exposed to a blood-borne pathogen. What you do next matters. First, take care of your staff! Document the incident. Document the route of exposure. Make sure the staff is immediately tested for blood-borne pathogens.

Secondly, get consent to test the patient’s blood as well. Unless, of course, you already know if they have Hepatitis B or HIV. Be sure that the proper channels are in place to take care of your employees. This includes medical evaluations and treatment, and counseling if they test positive. Listen to the whole episode for more valuable policies and procedures!

Resources & People Mentioned * Dental Cone-beam * OSHA * HIPAA

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Do you know how to properly care for your nitrous oxide equipment? Are you properly following instructions for use (IFU) documents when cleaning your Accutron? Knowing how to properly care for your equipment—and therefore your patients—is important for their longevity and functionality.

Here to chat with me today is Steve Nugent from Professional Sales Associates. One of his specialties is Accutron nitrous oxide products. He reached out to me about a recent episode I did to give me some feedback and I’m so glad he did. He’s got some insightful tips on protecting your equipment. Be sure to listen to this important episode of Talking with the Toothcop!

Outline of This Episode * [0:22] I welcome my guest Stephan Nugent to the podcast * [4:45] Centrally plumbed and portable nitrous oxide manifolds * [7:20] Inspection of equipment—follow the instructions for use! * [11:35] Disinfecting Flowmeters * [16:00] Don’t let complacency seep into your office * [19:30] Maintenance of nitrous oxide equipment * [21:55] Single-use MEANS one and done!

Pros and cons of a centrally plumbed or portable manifold According to Steve, both systems are fairly durable and robust. A centrally plumbed system is going to allow you more flexibility and can be available in every room needed. It’s going to be at a higher price point to install, but resupplying the gas is fairly affordable.

On the flip side, a portable manifold system has a lower price point. But it does come with some limitations. It is moveable but cumbersome—and it can’t be in two places at once. So you’ll either need multiple manifolds or have to schedule patients accordingly. You’ll also be constantly refilling canisters, and it isn’t as affordable when you go that route.

Either way, both options are suited for the task at hand. You just need to take into consideration your budget and intended use.

Follow Instructions for Use (IFU)—they are the letter of the law Nearly every device used in a dental practice is regulated by the FDA with strict guidelines for use. Therefore, it is extremely important to follow the IFU’s that accompany the product. Not following the instructions could cost you—and is technically breaking federal law. IFU’s give you one less process that you need to develop yourself, so take advantage of that!

Even something that seems simple, such as cleaning your devices, is clearly laid out for you. Steve recommends only utilizing the cleaning products outlined in the IFU. If you go rogue and use a stronger chemical, you risk damaging your equipment and impacting its longevity. For more details on how to properly clean your dental tools—keep listening!

Don’t let your dental office become complacent I’m a firm believer that if you work in the dental industry, you need to become an expert on infection control. It is a complex thing to tackle, but there are resources available—I certainly provide some! Make sure you stay up to date on the latest FDA guidelines. Do not let your practice become complacent. If you do, you’re setting yourself up for lawsuits.

Also, don’t go off-script. You may have the best of intentions when purchasing a heavy-duty well-reviewed cleaning product. But when put to use you could inadvertently destroy expensive equipment. You always need to consider the long term affects your actions have—even when it comes to something simple.

Evaluating your nitrous oxide equipment You know me—I’m all about compliance. Evaluating and monitoring your equipment is high on the list of things you must do. Steve and I both recommend using a barrier to help alleviate disinfectant concerns, as well as spraying cleaning chemicals on a cloth. DO NOT spray chemicals directly on your equipment (unless, of course, your IFU states to do so…).

Evaluate your rubber goods regularly. If there are holes in them you’re exposing yourself and the patient unnecessarily. If there’s a hole, duct tape is not your friend—it’s time to replace it. Likewise, single-use nasal hoods mean single-use. Throw them away when you’re done!

For more discussion on proper product usage, properly cleaning your Accutron equipment, and MORE listen to the full episode of Talking with the Toothcop!

Resources & People Mentioned * Professional Sales Associates * CaviCide Disinfectant * Accutron

Connect With Stephan * On LinkedIn * snugent(at)profsales.com

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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HIPAA Compliance—protecting your client’s information—NEEDS to be an important practice in your dental office. This topic is just as pressing as protecting the health of your patients and staff. Managed Service Providers (MSP) are a great way to help you maintain HIPAA compliance. In this episode of Talking with the Toothcop, I talk with Nancy Sabino of SabinoCompTech about technology and protecting patient information.

Nancy and her husband founded SabinoCompTech in 2008 out of a desire to help people. They primarily focus on Medical and Oral Healthcare—so she KNOWS the ins and outs of the dental industry. They focus on the “Awesome IT Way” and providing excellent care to their businesses. Listen for some great advice on keeping your dental practice HIPAA compliant.

What is a Managed Service Provider (MSP)? I’m going to be honest—you should know what an MSP is, but if you don’t, it’s easily described as an “outsourced IT department”. They offer technical support, advice, cyber-security, cloud services and much more. Your MSP stays up to date on technology so that it’s one less thing that you as the provider have to worry about.

This gives you the freedom to focus on what you NEED to do.

The IT world is constantly changing, and unless you and your staff are completely savvy in all things technology, I recommend utilizing the services of an MSP. SabinoCompTech is based in Katy, TX but local service providers can be found everywhere.

Remediation is ALWAYS more expensive than being proactive People often jump to “how much is this going to cost me?” but fail to consider the ramifications of the cost if something goes wrong. It’s all about prevention! Being proactive allows you to better control costs. An example Nancy gave is that in 2020 Windows 7 will no longer be supported by Microsoft.

If you’re still using that operating system, it will no longer be issued important security updates.

Would you necessarily know that? Probably not. But your MSP will. If you continue using non-supported operating systems, you open yourself up for security breaches. If you don’t plan now to replace those computers—it will cost you. This year the lowest HIPAA violation will cost you a whopping $25,000. That’s enough to put most small practices out of business! Keep listening as Nancy and I talk about protecting and securing patient information.

What baseline technology and security measures should be in place? Nancy was kind enough to share some of the things that you need to have in place for your practice, here are just a few:

You need to pay for antivirus software that is updated continually
Encrypt any device that can be encrypted in case of theft
Your staff needs to be educated on the most common scams
Update Windows frequently and make sure the updates go through
Have backups of your data set in place and check them DAILY

The last point is extremely important—if your computer crashes and you lose all your patient data you need to have it saved elsewhere. This is something your MSP can help you manage and backup daily. They’ll also run tests to make sure the information is not corrupt and can be recovered.

The two most common problems that are preventable The first issue is that most dental practices don’t have security risk assessments done. If you don’t know where your weaknesses lie it leaves you more open to security breaches. Nancy’s company offers an annual risk assessment and then work with you to make needed changes to become HIPAA compliant. Remember, prevention costs you far less than cleaning up a patient data breach!

The second issue is that many businesses do not have proper policies and procedures in place. How can staff be properly trained on patient security when a comprehensive guideline isn’t in place? They can’t. An MSP can run a risk assessment and actively work with you to develop security guidelines for your practice.

This episode is a must-listen if you’re looking for ways to secure patient information and make sure your practice is HIPAA compliant!

Outline of This Episode * [0:22] I introduce my special guest, Nancy Sabino. * [1:40] About SabinoCompTech * [6:18] Being proactive allows you to control costs * [10:20] Protect and secure patient information * [13:30] Baseline for technology and security measures * [22:35] Two common issues that are preventable * [26:30] Things you can to immediately

Resources & People Mentioned * SabinoCompTech * The Office for Civil Rights

Connect With Nancy * Nancy Sabino on LinkedIn * SabinoCompTech on LinkedIn * SabinoCompTech on Twitter * SabinoCompTech on Facebook * Awesome(at)SCT-MSP.com * Call SabinoCompTech at 281-392-8802

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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You’re probably listening to this podcast because you know the importance of compliance standards in the dental practice. We want to control the cleanliness of our tools, limit the spread of bacteria and illnesses, and offer our clients the best environment. Just as important as quality control is HIPAA compliance with your electronic devices, records audits—and so much more. This important episode of Talking with the Toothcop will cover these often overlooked procedures.

Outline of This Episode * [2:16] Mobile devices and cybersecurity * [7:20] Claims and Record Audits * [13:35] Mitigating workplace violence * [22:50] Policy on service animals

Mobile devices and cybersecurity You want to make sure that any device used in your office—whether it’s a phone, tablet, or computer—is properly equipped to protect client information. Also, your staff needs to be properly trained to be HIPAA compliant and procedures must be in place. Set it up so that you don’t save patient information on the computer or there is a policy in place to consistently remove it.

If you use your personal laptop or mobile device to access client information, use a virtual private network (VPN) connection. Did you know some of your devices can be set to remotely wipe if stolen? There are so many tools you can utilize to protect client information. Andrea and I cover a huge chunk of tools you can utilize—you don’t want to miss it.

Don’t “set it and forget it” when it comes to record audits I’m just going to briefly touch on this topic because it will be covered fully in another episode. But it is inherently important that you are constantly reviewing your documentation. There needs to be a paper trail that shows you’re auditing your work, that billing procedures are being followed, and you’re rectifying any mistakes that have been made.

Make no mistake, you WILL be audited at some point or another.

It is not a matter of if, but when. Any insurance company, even if you’re not an in-network provider, can audit you. So make sure you’re doing your due diligence to stay up to date on billing policies and procedures. Take time to audit some of your files (making note that you did so). Remember—you will be liable for mistakes made.

Mitigating the effect of workplace violence: have safety protocols in place No one goes to the dentist expecting or anticipating that any form of violence may occur. Unfortunately, recently, a man in Florida pointed a gun at staff in a dental office because he was tired of waiting for his appointment. It’s rare, but workplace violence does happen, and your staff must be prepared.

99% of the time your policy won’t get used. Be prepared for the 1%.

Have you heard of the procedure ‘run, hide, fight’? If not, I’ll lay it out for you:

RUN: If at all possible, flee the situation that’s been forced upon you and escape.

HIDE: If you are unable to escape, find cover (you’re hidden and safe from bullets) or at the very least concealment (staying hidden).

FIGHT: If all else fails, be prepared to protect yourself by any means necessary with any tool available.

We cover ALL the details if you listen to the whole segment.

Are service dogs allowed in the dentist's office? This is a question straight from the mailbag, and the answer is yes. According to the Department of Justice and the American’s with Disabilities Act (ADA), service animals are allowed anywhere that the “public is normally allowed to go”. This does not mean you have to allow Emotional Support animals into your practice—they’re not the same thing. You are legally allowed to ask two questions to determine if the animal is allowed to enter:

Is the dog a service animal required for a disability?
What work or task has the dog been trained to perform?

You are not legally allowed (or required) to ask any other questions or request documentation. It is important to know these rules so that you are not discriminating against the disabled. Your community knows that your practice is accommodating and knows the law!

Resources & People Mentioned * OSAP.org * Department of Justice Service Animal Policy * Man Pulls Gun in Dental Office

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Compliance and risk management in your dental practice should be of the utmost importance. We have a responsibility to our patients to maintain their health and safety. Though it can often overlooked, it plays a crucial role in your practice. Your brand becomes worthless if you don’t have a standard of excellence in place. Linda Harvey is joining me today on Talking with the Toothcop to talk about all things dental compliance.

Linda is equally as passionate as I am about compliance. She’s been in the industry for over 20 years, starting her career as a dental hygienist. After finishing her master’s degree, she worked in medicine and gained risk management experience. She founded the Linda Harvey group as a resource for both medical and dental compliance. In 2014, she founded the Institute for Dental Compliance and Risk Management. Though technically a competitor in the space, Linda is also a colleague and a friend and I highly value her insight in the field.

Outline of This Episode * [0:40] Linda Harvey’s background in the industry * [4:45] Reliability and the era of responsibility in compliance * [10:10] Maintaining quality standards * [17:10] Instrument processing and monitoring equipment * [20:10] Monitor your equipment! * [26:00] Why it’s important to not make assumptions * [30:50] Dental water line cleaning * [39:50] Sterilization technician as a future job? * [41:00] How to connect with Linda

Entering an era of responsibility Years ago, the biggest issue facing dentistry was controlling the incidences of fraud. Now, with the new technology becoming available in the space, we are entering a time when we must face infection control head-on. The technology we have that allows for more accurate testing and accurate cleaning of tools places the responsibility for our patient’s health squarely on our shoulders.

I strive to make those resources available to you as well as consistently inform you of changes and strides being made in the industry. I hope that you embrace becoming as big of a nerd about compliance as I am! The Institute for Dental Compliance and Risk Management provides education and training for those looking to expand their skills—I recommend checking them out!

The standard of care should be your baseline Every practice has a brand and an image to uphold. Your community has a perception about you and it is your responsibility to go above and beyond that standard. Does your practice boast the best and latest technology? Do you offer exceptional care? Is your staff up-to-date with the latest training and certifications?

My greatest pet peeve is dental websites that tout they “Are compliant with all OSHA and CDC recommendations and requirements”. Of course you are, because your practice wouldn’t be open if you weren’t! I want to know that your standards go above and beyond what’s expected because as a patient, that’s what I deserve. As a practice, you should follow the most stringent requirements for safety—not the baseline.

Do not make assumptions Linda and I talk about multiple examples of instances where a dental practice wasn’t necessarily being non-compliant but they were allowing things to slip through the cracks. One practice had ordered Peel Packs from 4 different vendors and didn’t know how long they’d had any of them. So how do they know if they’ve expired? Compliance is in the details—so we encourage practices to keep those things in mind.

Linda was working with another practice who had a small metal trash can under the table in their surgery center. She noticed what appeared to be rust spots on the exterior of the can. So she put on some gloves, used a little elbow grease, and scrubbed off the spots. It was exactly as she had hypothesized. The trash can didn’t have rust spots—it was covered in blood. It’s a good reminder to focus on keeping your practice spotless and don’t make assumptions.

The future of infection control in dentistry Most of the sterilization processes in a dental office are delegated to a dental assistant. In most cases, these employees are also juggling patient responsibilities and administrative tasks. As of right now, I’m unaware of a practice that has someone on staff whose sole job is infection control. Linda hypothesizes that the future of dentistry includes some sort of sterilization technician.

With the dangers of biofilms in water lines and untreatable infections running cropping up, sterilization of all tools and equipment should be prioritized. A dental infection control certification could be required down the road and would be a great leap towards better client care. We don’t want to continue seeing reports in the media of people falling ill because of neglect on our part. Caring for our patients and their well-being is why compliance and risk management is necessary.

Listen to the whole episode to hear my conversation with Linda as we cover some great tools and resources!

Connect With Linda * Linda(at)lindaharvey.net * Linda Harvey * Linda on LinkedIn * Linda Harvey Group on Facebook

Resources & People Mentioned * OSAP * Juan Yepes * “The CPD Guy” Stephen Kovach

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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The topic of infection control in dentistry is important and should be at the forefront of your mind when it comes to patient care. It’s definitely something I’m passionate about! That’s why this episode is devoted to different resources you can use to ensure you and your patient are protected. I came across many of these at the recent Organization for Safety, Asepsis and Prevention (OSAP) conference. I’m excited to share them with you!

Infection control in dentistry starts by testing your equipment often Something that is always emphasized at the yearly OSAP conference is the importance of cleaning your tools as often as possible. The last thing you want is for a patient to get sick on your watch! Something we include on our personal checklist is testing your autoclave and making sure it is functioning correctly. You need to make sure the machine to clean your tools is operating properly at all times.

The Ultrasonic machine’s job is to automatically scrub your instruments, right? One of the most common ways to test that it’s working properly is the foil test (which, by the way, should be done at the end of the day). At the conference, I came across these capsules that you can drop in your ultrasonic. If it’s working properly, the SonoCheck will change the color of the water. Keep listening as Andrea and I cover some other safety devices now available.

The dangers of biofilm in your water lines Biofilms can contain harmful bacteria such as Pseudomonas, Tuberculosis, and even Legionnaires’ disease. You have to know the quality of the water that is going into your patient’s mouth. You need a protocol for cleaning water lines and you should be testing it regularly. Assume every patient you work with is immunocompromised and do your best possible work to remove and prevent biofilms.

Recently, one of our clients here in Dallas was testing their water and their tap water was coming back with numbers in the 1,700 range—safe is below 500. They were doing shock treatments and kept coming back with higher numbers. The problem is, old biofilm solidifies and is difficult to clean. Sometimes, for the safety of your patients, it comes down to replacing your equipment.

At the OSAP conference, I came across a booth for a product called Dentaqua. It’s a machine that you can rent (I believe for $200 a month) that is a dental line testing and cleaning system that supposedly can remove and prevent the formation of biofilms. It’s also chemical free. If anyone listening uses it, please let me know what you think, I’d love to hear some feedback!

Prioritize protective glasses as if they were a bullet-proof vest As many of you know, I worked as a cop for years. Safety on the job is highly important, and can be a matter of life and death! There was an instance where I didn’t wear my bullet-proof vest for two days, and when my wife found out she was very angry—and rightly so. I didn’t take the necessary precautions to protect myself. Moral of the story? Do not take unnecessary risks.

So wear your eye protection! It serves to protect your eyes from bodily fluids from your patient. You’re also supposed to use green glasses to protect your eyes when you’re using lasers. But did you know when you’re supposed to use orange tinted lenses when utilizing curing lights? Exposure to the ultraviolet light can and will damage your eyes. So the extra few seconds it takes to change to a different pair of glasses if 100% worth the inconvenience.

Make sure to listen to the whole episode as Andrea and I dive into the world of infection control and talk in-depth about what you can do to protect yourself and your patients!

Outline of This Episode * [0:55] Wrap-up from the last episode * [3:15] From the mailbag! * [7:25] OSAP: the infection control think tank of the dental space * [14:00] A tool for testing your ultrasonic machine * [15:45] Test your equipment every day! * [17:25] Safer device for your needles * [20:25] We discuss waterline safety * [27:10] An option for testing water safety * [30:15] Hygienic keyboards * [32:20] Eye-Protection

Resources & People Mentioned * The MFCEO Project Podcast by Andy Frisella * The Ed Mylett show * The Organization for Safety, Asepsis and Prevention (OSAP) * The Linda Harvey Group * Stephen Kovach * Healthmark Industries * Proformance cleaning verification - SonoCheck * Ultra Safety Plus XL Needle stick injury prevention device * SimpleCap * ProEdge Dental Water Labs * Dentaqua dental waterline disinfection system * Productive Practices Hygienic Keyboards * Ultrasonic cleaner foil test video

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Your integrity is a critical aspect of your reputation as a dental professional - are yourself doing everything you can to protect it? If you don’t stay proactive when it comes to protecting your integrity, your business could be in danger!

On this episode, Andrea and I discuss our experience with the 75 Hard Challenge and what it takes for dentists like you to protect your integrity. You’ll want to pay extra attention to this episode - it’s full of content I know you’ll find helpful!

The 75 Hard Challenge I’ll be honest - over the last couple of years; I’ve let my health slide. I’ve been so consumed with the dental compliance space that my attention to my health has taken a back seat. Recently - I’ve been starting to think about my health and a podcast I listened to really helped me see what I can do to get back on track. Andrea and I have started the 75 Hard Challenge - here is what it entails:

Pick a diet to follow and stick with it - no cheat days.
Drink a gallon of water a day.
Exercise twice a day for 45-minutes each session - one has to be outside.
Take a progress picture every day.
Read ten pages each night of a personal/professional development book.

I know the 75 Hard Challenge won’t be for everyone and that’s OK! I brought the 75 Hard Challenge up because I want to encourage and motivate dental professionals like you to stay in the game and pay attention to your health. Find out how Andrea and I have fared with the challenge by listening to this episode!

Why I started Dental Compliance As you know - I’m pretty obsessed with dental compliance. I totally geek-out when it comes to self-disclosure protocols, expired medical equipment, securing patient information, and a whole host of additional topics. When I started Dental Compliance back in 2011, my goal was to bridge the gap between government agencies and dental providers. In my experience, most regulators don’t understand dentistry - someone needed to step in with solutions - that’s why I got into dental compliance. We’ve got a ton of helpful resources that will help dental professionals like you stay at the top of your game - if you haven’t joined our email list - that’s a great place to start!

Your integrity is your greatest asset If you don’t have your integrity - your word - your reputation - what do you have? This might sound a little old school, but at the end of the day - your integrity is your greatest asset! If your patients don’t trust you to take care of them and always do the right thing - your business will fail. Too many dentists like to stick their head in the sand and assume that ignorance is bliss when it comes to patient billing mistakes - don’t do that! Time might heal all wounds, but if you mess up when it comes to your integrity - you can kiss your business goodbye! Join Andrea and as we go even deeper with the topic of protecting your integrity on this episode.

Outline of This Episode * [0:45] Andrea and I share our story about taking on a personal health challenge. * [20:00] Why you should connect with us on social media! * [21:30] The reason I started Dental Compliance. * [23:30] Andrea and I discuss self-disclosure protocols. * [25:15] Responding to detected violations. * [27:00] Don’t be stupid and blow your integrity! * [31:30] What is a corporate integrity agreement? * [34:20] Closing thoughts.

Resources & People Mentioned * 75 Hard Challenge on Facebook * Roy S. Shelburne

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Do you ever find yourself fascinated and terrified by a case of dental embezzlement? I’ll admit it - I find those type of stories so gripping! I wonder what the dentist could have done to prevent the fraud or I wonder how they didn’t see it coming. If you’ve ever wondered if your dental practice is really protected from dental embezzlement or other types of fraud - this is the episode for you!

On this episode - you’ll hear from my guest, William Hiltz. William is an expert in embezzlement detection, investigation, and remediation. He is also a published author and speaker on the subject of embezzlement in healthcare. William currently serves as the CEO and Founder of Hiltz and Associates.

Set the tone from the top! Whatever policy and controls you put in place at your dental office - they mean nothing if you don’t follow those standards yourself! Remember that old saying - money see, monkey do? It turns out that humans aren’t that different. You can’t have one policy for preventing dental embezzlement that applies to your staff and a separate one that applies to you. If you want your office to survive dental compliance checks and avoid other types of fraud - you’ve got to have your bases covered. To learn more about setting the tone from the top - make sure to listen to this episode featuring William Hiltz!

How to respond when you suspect theft from your staff It’s that day that every dentist fears - you’ve discovered that someone in your office has been committing dental embezzlement. What do you do? Do you immediately call the police and focus on apprehending the wrongdoer? Will you press charges? Don’t leave it all up to chance or a spur of the moment decision! You need to have clear and executable policies that everyone in your office knows about. In our conversation, William Hiltz suggested this helpful course of action.

Confirm the theft.
Sanction the individual.
Fire the individual responsible.
Document what happened.

Beyond covering your practice - following William’s course of action can also help future employers avoid the same scenario with that individual. Listen to William expand on this topic and much more by tuning into this episode!

Set and forget controls you can put in place While it’s great to have a process to deal with dental embezzlement once it occurs - an even better question is how do you prevent it from being a temptation for your staff in the first place? The easier you make it for people to steal, the more likely they are to steal! Why not put some measures in place to make it difficult to commit dental embezzlement? According to William Hiltz, there are several "Set it and forget it" steps you can take to protect your dental practice.

Secure your point of sale system so your staff can’t do unauthorized refunds.
Get rid of check payments as much as possible - go digital or direct deposit.
Emphasize the severe nature of any financial misconduct.

You can’t expect policy alone to protect your practice from dental embezzlement - you’ve got to make your people feel the enormity of the situation. After all - people on the road speed every day - but they don’t speed when a police officer is behind them! You are the police officer of your office - if people feel like they can get away with theft, it’s because you haven’t monitored them close enough.

Don’t hide your head in the sand! I know - you see all this information, and you hear William’s dire warnings, but the truth is - running a business is difficult. As much as you’d like to cover all the bases - sometimes ignorance is bliss - right? No! While you don’t have to have it all figured out tomorrow - this isn’t an issue you can sweep under the rug. If you want to protect your reputation and give your patients the best service possible - you’ve got to take steps to prevent dental embezzlement and forms of fraud. Reach out to William and his team if you’d like more information - their website is located in the resources section at the end of this post.

Outline of This Episode * [0:28] I welcome my guest, William Hiltz. * [4:00] What William looks for with unauthorized refunds. * [12:20] Set the tone from the top! * [18:15] What should you do if you suspect a staff member of stealing? * [32:30] Why you need controls and monitors in place. * [35:30] Set and forget controls you can use. * [37:30] Ignorance is not a solution! * [39:20] Closing thoughts.

Resources & People Mentioned * Hiltz & Associates • Dentistry's Embezzlement & Data Audit Specialists * Dental Fraud Busters - Facebook Group * William on LinkedIn

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Let’s face it - expired medical equipment and expired drugs are NOT the sexiest of topics to cover, but it is SO important. On this episode - Andrea and I talk about expired equipment, expired drugs, why you need to have written policies and procedures, the danger of getting too comfortable sedating a patient, and much more. You don’t have to struggle to find the right resources on these topics - we’ve got you covered. There is a ton of helpful information, Andrea, and I cover - grab pen and paper - you are going to need it!

Keeping track of expired medical equipment and expired drugs I know - keeping track of expired medical equipment and expired drugs is a chore. You might even be tempted to think that expired medical equipment and expired drugs are covered by your spreadsheet or list - think again! Time and time again, I discover the most dental offices that assume their expired dates are covered by their processes are actually wrong. Don’t let an assumption get your office in trouble! Make it part of the process to go to the physical product, and double check those expiration dates regularly. To hear Andrea and I discuss this critical topic in further detail - make sure to listen to our full conversation on this episode.

Why you need written policies and procedures If all this talk about expired medical equipment and expired drugs has you concerned about your policies and procedures - good! Principled dentists like you can use that fear and extra concern as fuel to serve your patients. When was the last time you scheduled a day to review and edit your policies and procedures? If it’s been a while - now is the time! We’ve got a helpful resource called the Medical Emergencies and Training Program that will help dental offices like yours tighten things up and stay in compliance - take a look in our products and services section to learn more!

Don’t get too comfortable sedating a patient! In all my years in the dental industry - I’ve found that the best dentists are the ones who approach patient care with the utmost seriousness. The truth is - the moment you get comfortable and let your guard down is the moment where mistakes start to creep in. Fight complacency and comfortably in your dental office. Not that you want everyone going around sad and depressed, but you want them (including yourself) to recognise that they have people's lives in their hands. Make sure to listen to this episode as I expand on this subject with Andrea!

Stumped? Send us your question. From exploring the topic of expired medical equipment to sedating a patient - I want to resource excellent dentists like you to provide the best care possible. Remember - this podcast and our website is a resource for dental offices’ like yours. If there are topics you’d like Andrea and I to cover or concerns you’d like us to address - let us know! We love getting your feedback (and constructive criticism), so don’t be shy - we are rooting for you!

Outline of This Episode * [0:43] I introduce the topics covered in this episode. * [2:30] Why you should watch out for expired equipment and expired drugs. * [5:30] How damaging is it to be found using expired drugs? * [7:00] Make sure you have written policies and procedures. * [10:20] Don’t get too comfortable about sedating a patient. * [14:15] Why you need to follow a pre-operation checklist. * [18:20] Mailbag questions and answers! * [26:35] Closing thoughts.

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Do you really need legal representation shortly after a patient death or hospitalization? While it’s a scenario that no dentist ever wants to face over the course of their career you need to have a plan in place. Here to help you understand what you can expect and how to prepare for dealing with a patient death or hospitalization is Laura Diamond.

Laura is an administrative and healthcare law attorney with experience representing healthcare providers in administrative proceedings. She is a partner in the firm of Dalrymple, Shellhorse, Ellis & Diamond, LLP. Laura’s practice focuses on assisting individuals and businesses in defending their occupational licenses.

She represents clients at the agency level (complaint, investigation, and informal settlement conference) as well as before the State Office of Administrative Hearings (SOAH). Ms. Diamond advises dentists, nurses (RN, LVN), physicians, respiratory therapists, radiologic technicians, psychologists, and mental health providers including social workers and counselors (LPC, LCDC, LMFT, LSOTP).

In our conversation, Laura explains how the self-reporting process works when a patient death or hospitalization occurs, the best way to protect yourself when that happens, why you need legal representation when you appear before a regulatory body, and much more. Don’t miss a minute of this valuable episode featuring Laura’s expert perspective!

When to report a patient death or hospitalization. It may sound like an obvious answer, but there can be challenges when deciding when to report a patient death or hospitalization to a regulatory body. Of course, you need to report a patient death to law enforcement right away when it happens in your office, but you do have time before you need to report it to an organization like the State Board of Dental Examiners.

When a death occurs as a direct result of a dental procedure or if they are admitted to the hospital due to that procedure, you are required to report it to your state regulatory body. To get the full discussion on this critical topic with Laura, make sure to listen to this episode!

Why you need legal representation. Many dentists are so eager to comply with state or federal law when a patient death or hospital admittance occurs that they fail to protect themselves with legal representation. The point of securing legal representation at this crucial time is not to hide the facts or hinder the investigation it’s to make sure you are telling the full story.

Too often dentists and their staff will volunteer information to state investigators without consulting with legal representation and unnecessarily open themselves up to liability. Don’t let that happen to your office! Have a plan in place, so your practice is covered and prepared.

Use the timeframe requirements to prepare your documents. On a similar note, you need to make sure that as you prepare to submit a self-report to your state’s regulatory board that you do so only when you’ve got all your documents ready. This doesn’t mean you should file a report past the required deadline; it just means that you should use the full 72 hours or whatever time your state requires to your full advantage.

Remember, you’ll need to submit copies of your patient’s chart, emergency protocols, electronic images, and a whole host of additional documents. Once you’ve self-reported, you’ll need to provide that information right away, that is why using the full timeframe is in your best interest. To learn more about this complicated process, make sure to listen to this episode!

Make sure you have your bases covered. If it has been some time since you last reviewed your office’s procedure for a patient death or hospitalization, let this episode serve as your reminder. Take the time today to schedule your procedure review and put it on the calendar for the next review too.

You can never be too careful when it comes to patient safety, legal representation, and dental compliance. If you’d like to follow up with Laura about specific questions or to get connected to legal representation for your practice, make sure to check out the links in the resources section at the end of this post.

Outline of This Episode * [0:22] I welcome my guest, Laura Diamond. * [3:00] Laura and I talk about self-reporting patient deaths and hospitalizations. * [5:30] How do you know when you should self-report a death or hospitalization? * [8:30] Why you need legal representation when you appear before a regulatory body. * [13:00] I share a story about a dentist that self-reported a patient death. * [16:00] What you’ll need to provide when you self-report a patient death or hospitalization. * [21:00] Understanding how the timeframe requirements work. * [24:00] Closing thoughts.

Resources & People Mentioned * Dalrymple, Shellhorse, Ellis & Diamond, LLP * Laura on LinkedIn * Laura’s email address - LDIAMOND[at]DSEDLAW.COM * Texas State Board of Dental Examiners - Texas.gov

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Is your dental office using the best methods for securing patient information? When was the last time you reviewed your process and made an update? On this episode, Andrea and I jump into an important conversation about securing patient information, controlling designated agents, electronic record-keeping, and much more. If you are ready to up your game and make sure your office is ready for any dental compliance issue, have pen and paper ready, you don’t want to miss a minute of this informative episode!

Using designated agents properly. I get it, you want to delegate as many roles and responsibilities as possible in your dental office but how do you make sure you are following the right guidelines? Do you have a process in place when it comes to designated agents? There are a lot of different aspects of controlling your designated agents that you need to consider and it can vary from state to state. Listen to this episode as Andrea, and I discuss this critical topic and make sure to check out the link to the blog post I wrote about this topic - you can find it in the resources section at the end of this post.

Don’t cut corners when it comes to securing patient information. One of your most important roles as a dental care provider is to ensure that patient information is kept safe and secure. Did you know that many dental offices have habits and common practices that put patient information at risk every day? It’s true! You can avoid that from happening in your office by taking a few simple steps.

Make sure everyone who uses a computer has their own login credentials.
Do not allow anyone in your office to use a computer without logging in with their credentials.
When someone leaves the room, make sure they lock their computer!

These steps are by no means an exhaustive list of things you should do to secure patient information, but it can serve as a helpful starting place. To learn more about this critical topic, make sure to listen to this episode!

Paper or electronic record-keeping? With the constant flow of updates and new regulations do you find it easier to stick with your old paper record-keeping system? Or do you find it easier to have all of your patient information digitized and available on a cloud? Currently, you don’t have to pick one way over the other! If you prefer the old-school method of paper records, that’s fine, but I do suggest moving to digital. To get a good grasp on this topic, join Andrea and I as we dig deep on this episode - you don’t want to miss it!

Know your plan and update it. Too often I’ve seen dental office after dental office assume they had a rock-solid plan to secure patient information only to find that it was severely outdated. I don’t want you to be overwhelmed with fear about securing patient information, but I also don’t want you to be lulled into a state of complacency. Make sure you are familiar with your plan and have it on the calendar for review annually. You’ll never get in trouble for over preparing and over planning! Learn more about securing your patient information and ensuring your office is in good shape by listening to this episode!

Outline of This Episode * [0:22] I introduce this week’s topics, designated agents, securing patient information, electronic data records, and more. * [3:30] Why you need to have controls in place when it comes to controlled substances. * [7:00] Critical questions you should ask when it comes to the use of Designated Agents. * [13:20] Make sure to use a Designated Agents authorization form. * [17:30] Andrea and I talk about securing patient information. * [23:50] Do you have to store your data electronically or are paper records still OK? * [32:00] Make sure to have access to your data off-site. * [34:00] Closing thoughts.

Resources & People Mentioned * The Use of Designated Agents * The National Institute of Standards and Technology (NIST)

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Let’s face it; you never can be too careful when it comes to writing prescriptions and taking into account all the details of your patient's medical history. Are the processes and procedures at your dental office up to date?

On this episode, you’ll hear from Andrea and I as we discuss codes of conduct, firewall, and antivirus protection, reviewing medical history, and much more. If you want to make sure your practice is operating at the top of dental compliance, you’ve come to the right place! Have pen and paper ready; you don’t want to miss a minute of this helpful and informative episode.

Don’t skimp on network security. While technology and computer networks might not be in your wheelhouse, when it comes to protecting patient data, you can’t skimp. Time and time again, I hear that staying in compliance is a difficult thing to do, and I get it, but you’ve got to prioritize certain aspects like network security. Don’t try to get by with a “Free” version of anti-virus software or a less than stellar firewall. Take the time to do your research and protect your patient's data, trust me, it’s worth it!

What is the Prescription Data Monitoring Program (PMP)? A few years back I noticed that Arizona had adopted a strict policy that required all dentists in the state to check their patient’s consumption history for controlled substances before writing a new script. Fast-forward to today and almost every state in the country has adopted a similar requirement often referred to as the Prescription Data Monitoring Program (PMP).

The PMP is an excellent tool that allows dental offices like yours to make sure they are taking their patient’s full medical history into account. You can learn more about the PMP by listening to this detailed episode!

Why you need to have an up to date record of your patient’s medical history. How often does your dental office update your patient’s medical history? Do you do it annually? How did you determine how often you’d request an update? I highly recommend getting an updated medical history of your patients every year. Why risk it when it’s just a little extra paperwork? Don’t just squeak by with the bare minimum requirements, I’ve found that the dental offices that set themselves apart from their competition are the ones that go the extra mile to ensure patient safety.

Make sure to get a custom fit for your office. Whether it’s network security, the Prescription Data Monitoring Program, updating your patient’s medical history, or something in-between, find what works for your office. There is no one size fits all solution when it comes to these complicated and challenging topics. Put in the time to do your research and customize a solution that is tailor made for your specific practice. I’ve seen way too many offices grab some template from the internet or the cheapest anti-virus software only to find that they regretted the choice when it was too late. Don’t let that happen to you!

Outline of This Episode * [0:22] Andrea and I introduce today’s topics, codes of conduct, firewall and antivirus protection, medical dental history, and the notice of privacy practices. * [3:30] Why you need to make sure your computer network is secure. * [6:00] How a cryptovirus can impact your practice. * [9:40] What is the Prescription Data Monitoring Program (PMP)? * [14:50] I share a story about looking up a patient’s history on the PMP. * [16:30] Why it’s helpful to get a detailed medical history on your patients. * [20:00] Make sure your notice of privacy practice is specific to your office. * [24:20] Where to get a template for notice of privacy practice. * [26:00] Closing thoughts.

Resources & People Mentioned * Model Notices of Privacy Practices

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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We’ve got a whole line up of super sexy topics to cover, from safety data sheets and safe injection practices to radiology infection control and more! While these may not be the most exciting topics, you know that proper attention to important subjects like these is what differentiates an excellent dental office from an average one. What are you waiting for? Have pen and paper ready for this detailed and informative episode of Talking with the Toothcop, you don’t want to miss it!

Safety Data Sheets What are safety data sheets and when are you required to use them? If you’ve been unsure of how to utilize and safety data sheets or why they are a tool you need to have available in your office, this is the episode for you! A safety data sheet, material safety data sheet, or product safety data sheet is a document that lists information relating to occupational safety and health for the use of various substances and products. As a shorthand, think of it this way, you need to fill out a safety data sheet for anything you purchase from your specialty dental supplier. For additional information on safety data sheets and why you need them in your dental office, make sure to listen to this episode!

Safe injection practices Did you know that one of the best ways to safeguard your staff from getting accidentally stuck with a dirty instrument is to recap it break it down yourself? While that may sound like a no-brainer, you’d be surprised at how many dental offices don’t make this simple adjustment to their procedures. It almost goes without saying but I’ll add it here anyway, make sure to NEVER reuse needles and ALWAYS use a Sharps Disposal Container for proper disposal. Don’t open yourself up to unnecessary risk, review your process and make sure you have all of your bases covered. To hear more helpful guidelines and best practices, listen to this episode!

Low-speed handpiece motors Do you really have to sterilize your low-speed handpiece motors or is that just an extra step that some dental offices take unnecessarily? According to CDC guidelines for infection prevention and control, the answer is yes, you do need to sterilize your low-speed handpiece motors.

The CDC guidelines state that “...between patients, dental health care personnel (DHCP) should clean and heat-sterilize handpieces and other intraoral instruments that can be removed from the air and waterlines of dental units. This recommendation is based on studies that have shown that the internal components of air-driven dental handpieces (both low-speed and high-speed devices) can become contaminated with patient material during use, and this material can then be expelled into the mouth of other patients during subsequent uses.”

Make sure your processes aren’t violating Federal law! For an in-depth explanation of this critical topic, make sure to listen to this episode of Talking with the Toothcop.

Join my 10-day challenge! Did this conversation give something to think about? Are you in good shape when it comes to safety data sheets, safe injection practices, low-speed handpiece motors, and the rest? Even if you think your office is completely up to snuff, I’d like you to consider taking my ten-day challenge. I challenge you, each day for the next ten business days at some point in the day to rifle through your drawer of sterile instruments and look for anything that might not be sterile. My guess is, you’ll find at least one unsterilized item a day. Are you up for the challenge? Let me know how it goes!

Outline of This Episode * [0:22] I introduce today’s topics, safety data sheets, safe injection practices, low-speed handpiece motors, and radiology infection control. * [9:40] What you need to know about safe injection practices. * [11:45] Why you have to sterilize your low-speed handpiece motors. * [16:30] How to protect your patients from radiology infection. * [22:20] My 10-day challenge for you.

Resources & People Mentioned * Centers for Disease Control and Prevention

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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When was the last time you addressed dental waterline maintenance at your office? Are you aware of the increased challenges that many dental offices are facing when it comes to waterline maintenance? On this episode, you’ll hear from Mike Rust and Monica Boldt from ProEdge Dental Water Labs.

ProEdge serves dedicated dental professionals by offering assurance with highly trusted waterline testing, expert consultation, and product solutions for your dental practice. They’ve been testing dental water for over fifteen years with over 160,000 tests, but more importantly, their dental water experts have helped thousands of practices achieve safe water.

In our conversation, Mike and Monica talk about why testing water lines are so important, how R2A helps make water safe, what causes biofilm to grow, upcoming changes to state regulations, how to order a waterline test, and much more. Don’t miss a minute of this helpful and informative episode!

Why dental waterline maintenance is so important. Everyone gets why water testing our drinking water is so important, but if that water is treated and tested regularly, why do we need additional dental waterline maintenance? According to the Centers for Disease Control and Prevention (CDC), safe water should contain less than 500 Colony Forming Units (CFU) per milliliter. Unfortunately, on average three out of ten dental waterlines tested have over 500 CFUs per milliliter. Dental offices that want to stay ahead of the curve need to make sure that they have a plan in place that will keep their patients safe.

Stay ahead of the curve and keep your patients safe! Even for those dental offices that put a plan in place, dangers still lurk in the water. The team at ProEdge has identified two reasons that lead to failed waterline tests.

Not all products are easily implemented
Some products are not as effective as advertised

Is your plan fool-proof? Could you be missing critical factors that will leave your practice open to liability? ProEdge has over fifteen years in the dental waterline maintenance industry, and they’ve completed over 165,000 waterline tests. To learn more about the amazing solutions they’ve created for dental offices like yours, make sure to check out the link to their website located in the resources section at the end of this post.

What to expect when you get your waterline tested. If you are ready to update your dental waterline maintenance program or put a plan on paper for the first time, you’ve come to the right place! On this episode, Mike Rust and Monica Boldt explain what dental offices like yours can expect when you decide to get your waterline tested. When you order ProEdge’s standard kit, you’ll receive one mailer kit, lab service, and one sample vial. Once you have the kit, you’ll proceed to collect water samples from each dental unit in separate test vials and place it in the provided mailer; the samples are then received and processed immediately. Once the testing has been completed, a full test results report is faxed or emailed to you after the samples are processed (7 Days). For a full breakdown on the waterline testing process and more details on this subject, make sure to listen to this episode!

Outline of This Episode * [0:22] I introduce my guests, Mike Rust and Monica Boldt. * [2:20] Mike talks about testing water lines. * [6:45] How does R2A work? * [9:45] What is biofilm and how does it impact our drinking water? * [14:00] Why it is important to take care of your water sources. * [19:30] Washington and California will soon have regulations regarding water testing. * [23:00] How to order a water test and what to expect. * [27:15] Closing thoughts.

Resources & People Mentioned * ProEdge * ProEdge on Twitter * ProEdge on Facebook

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Have you ever been tempted to respond to patients who had a negative experience and have taken to the internet to tarnish your business reputation? Did you give in to the temptation? What is the best approach in these type of situations? On this episode, you’ll hear about how to respond to negative feedback online, when to use patient consent forms for pictures, how to best serve patients with disabilities, and much more. If you have struggled with how to respond to less than positive feedback online, you don’t want to miss this episode!

Don’t let yourself get dragged into an online argument. If you spend very much time on the internet, you are likely familiar with review sites like Yelp. These type of sites can be helpful but often play to our worst instincts to blast others and complain without fear of facing the consequences. What should you do when you see negative public reviews or comments about your business? Should you engage and counter their argument or just let it roll off of your back?

Unfortunately, many of you won’t like my answer. While you can engage, I strongly caution against getting dragged into an argument!

The best course of action when dealing with negative feedback that attacks your business reputation is to acknowledge the response and thank the patient for providing valuable feedback. It is best to keep your response brief, professional, and positive or at least neutral. Remember, people on these sites are watching how you respond and they are judging your business accordingly.

Are patient consent forms for photo use really necessary? I’ll admit it, I’ve had to stop following many of my clients online because I cringe when I see them post pictures for promotional use that show their patient’s information or image. In this day and age, you’ve got to be extra careful about displaying the image of your patient for marketing or any other outside use. If you are going to post a picture to social media or in some other promotional use featuring a patient, it’s best to make sure you have a patient consent form filled out. You don’t have to make this step difficult, there are a ton of resources out there with generic forms you can use to make sure you and your business reputation are covered. For more information on this vital topic, make sure to catch this episode!

Serving patients with disabilities. Is your office prepared to serve your patients who have a disability? While most offices are prepared for those who have limited mobility or those who are blind, you might not be as prepared for other individuals with disabilities as you might think.

I recently received a call from a dentist who is trying to figure out how to best serve his patient who is deaf. The patient usually has their spouse accompany them to appointments to serve as their interpreter but they were unable to attend this upcoming appointment. In that situation, would you know what to do? Does your office have a plan in place?

While most offices won’t face this scenario, it is wise to have a plan written out and ready should the occasion arise. You need to know that you are required to accommodate all disabled patients and in this situation, that would mean that you have to provide an interpreter and you can not pass that cost on your patient.

To hear more about serving patients with disabilities while maintaining a positive business reputation, listen to this episode of Talking With The Tooth Cop!

Outline of This Episode * [0:20] Are you paying attention to your business reputation? * [3:45] How you should respond to patient reviews online. * [5:10] Why you need consent forms when using pictures of patients for outside purposes. * [7:10] Do you need to provide an interpreter for deaf patients? * [12:40] Remember, there are riches in niches!

Resources & People Mentioned * National Association of the Deaf

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Every year fines are levied against well-meaning, hard-working individuals in dental practices all across the country. Nobody wants to do things that put their staff members or patients at risk, yet these safety infractions keep happening. Why? It’s not because rules and regulations change, it’s because the practices that ensure safety in the dental office slip over time. It’s an issue of not effectively creating a safety culture.

On this episode, I’m chatting with Andrea about the most recent years of OSHA violations, going item by item through the violations to point out how and why they happened. We wrap up with some tips and strategies about how you can create something bigger than a commitment to enforcing the rules - you can and should create a safety culture among your team. It's way more powerful.

There’s not a Dentist alive who wants to put people at risk Nobody would even suggest that Dentists are overlooking safety issues because they don’t care. Every Dentist I know cares deeply about their patients and their staff. So what is it that causes offices across the country to be fined for safety violations? It’s a lack of consistent attention to the policies and procedures that keep people safe.

Listen to hear what causes the average Dentist’s commitment to safety to slip in practical ways, hear our suggestions about what needs to be done to keep things on the up and up, and to understand how you can protect yourself and your office from being the next to be cited for violations.

Some of the dental safety violations we see are simply paperwork There are true safety concerns among the things we note in this episode, but many of them are simply a failure to document the safety steps that have been taken in the practice. I’ll give you some examples. In many of the cases where OSHA has cited practices in the past 3 to 4 years, there were:

No written blood-borne pathogen plans
No proof of Hep B vaccinations
No hazard communication plans
No Safety Data Sheets in the workplace

Do you see what I mean? In most cases, these are one-time administrative tasks that simply need to be created and made available. It’s not hard, just time consuming and tedious. The worst part is that by NOT doing something so simple, hundreds or even thousands of dollars worth of fines are being levied, and patients and team members are being put at risk.

A clear example of why a culture of safety is the answer In some of the instances where dental practices were cited, the infraction was a fairly simple, easy to do task that simply wasn’t being done consistently. For example, it’s still the case that many of those serving in the office are not wearing the proper eye protection for the task they are performing. Still, others are not using other forms of PPE.

This is not a rule problem - it’s a culture problem. It’s sometimes harder to fix safety issues of a cultural nature but when you do, the slips tend to go away. Listen to find out how we suggest you go about creating a culture of safety in your practice.

A culture of safety begins with the leader I’m convinced that every Dentist wants their team and their patients to be safe from blood or body fluid-borne pathogens. The same holds true when it comes to exposure to hazardous materials or radiation in the dental office. If that’s true, then the primary motivator for creating a culture of safety is already in place. Dentists simply don’t know how to practically apply what they already believe.

Don’t think of this as an issue where you need to be the bad guy or bring the hammer down. It’s not that at all. What you need to think of is communicating your heart to your team, your desire to see EVERY team member and EVERY patient cared for in a safe manner. That will matter to your team because it demonstrates that you are in it for them. From there, you speak practically about what that concern motivates you to do (follow the prescribed guidelines for safety and ensure your team does too). Your team is smart, they’ll make the connection and get on board. Then THEY will be part of your culture of safety.

Then, and only then, you implement your no-toleration policy regarding adherence to the safety rules that have been established. Safety problems don’t typically happen because the rules change, they happen because attitudes and diligence change - when they shouldn’t. Listen, to learn more.

Outline of This Episode * [0:22] Creating a culture of safety in your office * [2:10] How active is OSHA in the dental industry? Not very. It’s * [5:59] What are the violations OSHA Is citing for? * [10:39] No eye or face protection violations * [12:55] Not requiring the use of PPE - Doctors don’t enjoy using it but they must do it * [15:56] Healthcare associated infections: a new law in California * [18:26] The little things that add up * [22:57] The takeaways: a line has to be drawn in the sand

Resources & People Mentioned * OCR - HIPAA violations

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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We like to have fun on these podcast episodes - which you’ll hear in this recording - but dental regulatory compliance is not a laughing matter. Tens of thousands of dollars in fines are levied against practices regularly for a variety of infractions and omissions. We thought it would be beneficial to share the most common mistakes we see when we do our compliance consults in client dental offices - so that’s what we recording on this episode.

Listen to hear OSHA and HIPAA regulatory requirements and how dental offices around the country are missing vital points of compliance. Much of it is tedious, but it’s all the law - and the fines are hefty if you don't comply. Be sure you listen.

A “BAA” - Business Associate Agreement is required in many cases to protect patient information Every dental office out there works with other service providers. “BAA”s or “Business Associate Agreements” need to be in place for every service provider your office works with.

HIPAA defines a business associate as any organization or person working in association with or providing services to a covered entity who handles or discloses PHI or personal health records (PHR). There’s a laundry list of companies or individuals you may work with who fit that description. On this episode, we provide examples and explain what you need to do to ensure your office is compliant with this regulation.

Did you know you need to keep an OSHA medical file for every employee - for 30 years? Every person who works in your dental office needs to have a handful of documents on file in your office - under lock and key. We commonly refer to these as the Employee’s OSHA Medical File. While there are a number of items that could be kept in the file, there are 3 that are must-haves:

1 - Hepatitis B Acceptance or Declination Form

2 - PPE Acknowledgment Form

3 - The Employee Exposure To Termination Form

And the file has to be kept for 30 years. 30 years!??? Yes, 30 years.

That brings up a valid question, “Can these records be kept electronically instead of in hard-copy?” We talk about that question and much more on this episode.

Are you transporting sharp instruments properly inside your office? One of the most common dental regulatory compliance issues centers around the issue of transporting sharp instruments within the office. Best-practice is to have all instruments in a hard-sided, covered container so that should a slip or fall occur, the instruments are contained and nobody is at risk of being cut or otherwise injured.

But very few dental practices pay attention to this regulation - mainly because it’s a bother. That’s not a good reason, so we encourage you to think through consistent ways you can train your office staff to comply with best-practices. If you’re found out doing this wrong, tens of thousands of dollars in fines could be levied against you.

Employee training has to be more important than the desperation to get the work done Every busy dental practice knows the struggle it is to find qualified, motivated team members. When you do find someone who fits your team, it’s tempting to get them rolling in the actual work of the job right away to relieve some of the pressure and stress within the office. But hold on - don’t forget there is a lot of mandatory disclosure and training that must happen before that new employee steps into the role they’ve been hired for.

Employee training on OSHA and HIPPA issues is vital to ensure that best practices are followed in every step of treatment, record keeping, and patient care. Our team can help you think through your existing systems and put adequate training in place. Or, for now, you can listen to this episode to hear our advice on how to address this important issue.

Outline of This Episode * [0:55] Is it cactus or cacti? We’re afraid to Google it… * [2:47] Is OSHA a not as scary as The Office For Civil Rights * [7:01] How these issues come onto the radar in the first place * [8:42] Top concerns we see in offices regarding OSHA consults * [19:01] Common trends relating to radiology equipment slip-ups * [22:55] The beauty of what we do at Dental Compliance * [23:58] Coming soon to your State (it’s happening now in Texas) * [27:14] Reasons potential employees might be on an exclusion list

Resources & People Mentioned * Texas regulation 110

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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On this episode of Talking With the Tooth Cop, I interview Santosh Patel, founder and president of Complete Specialty Solutions, a business dedicated to bringing high-quality dental specialists into your practice with as few logistical nightmares as possible. Throughout this episode, he explains the benefits of bringing in outside dental specialists and how you can leverage their expertise in your community. We discuss how to keep patients safe and protect their privacy while incorporating traveling specialists, as well as why relationship building is key throughout the whole process. It’s an episode not to be missed - listen now.

Complete Specialty Solutions offers practical services for independent dental professionals Many patients are unable to access the specialty care they need, particularly in smaller towns and rural areas. Santosh explains that the idea for CSS came from his background in hospital management, and his desire to inject great healthcare practices and organizational structure into dentistry. CSS provides many resources to dental practices in the Houston/Dallas area such as board-certified specialists, marketing strategies, patient recruitment plans, scheduling services, and many more.

Santosh and his team accomplish all of this through their network of part-time employees that work for their professional limited liability company. The professionals coming into the practices are not independent contractors, so each dental specialist carries their own certificate of specialty, malpractice insurance, etc. Essentially, CSS is a full-scale operations team that can "help be the how-to solution” for small practices looking to expand their services and offerings while still seeking to maintain their autonomy.

Having accurate record-keeping and proper workflow ensures dental specialists can be successful in your practice Many dentists are hesitant to bring in dental specialists simply because of the perceived logistical nightmare. However, Santosh’s team has developed a way to ensure all records, notes, and files are seamlessly kept up to date as a specialist moves from practice to practice. Typically, a GP fills out a referral form, which is then delivered to CSS. They then recommend a specialist to travel to the practice, where he or she provides all of their own personal documentation. The specialist performs the service and completes all necessary patient care. Billing goes through the practice’s tax ID number but is filed under the specialist’s National Provider Identifier number. The CSS method prevents multiple tech platforms from being used, resulting in a higher level of satisfaction from the GP, the practice’s staff, and the patients.

There are steps you can take to prevent liability and malpractice issues when bringing in additional dental professionals In addition to stellar record keeping, CSS can assist practices with preventing liability and malpractice issues. They encourage the GP to let their insurance carrier know that they’re bringing in dental specialists, as well as keep honest and direct lines of communication open. Santosh has also discovered that by using specialists that are local to the practice’s area, there are fewer chances of issues arising. If the specialist has a rapport within the broader community, and they fit with the overarching practice culture, it can go a long way towards preventing lawsuits and miscommunications.

Pairing independent practices and third-party dental specialists must be about building solid relationships Throughout this entire episode, Santosh explains the critical importance of relationship building between dentists, their staff, and dental specialists. Without a healthy rapport between all 3, the process is less likely to be successful and effective. CSS does not seek to have short-term contract work with practices, rather they’re striving to build long-term working relationships between specialists and dentists. CSS encourages all specialists to be diligent in follow-up care with patients, working with the practice’s staff to ensure their databases are accurate, and speaking honestly with everyone involved in order to make the specialist process as smooth as possible. For more, be sure to give this episode your full attention.

Outline of This Episode * [0:21] Santosh Patel explains what Complete Specialty Solutions can offer for your practice * [3:40] All about Complete Specialty Solutions and what they can offer to your practice * [10:20] The employment and organizational structure of CSS * [17:22] Auditing, fraud, and ensuring accuracy in your record-keeping processes * [25:00] Liability issues in the specialty dentistry industry * [31:20] The top things Santosh looks for when researching potential practice partners for CSS

Resources & People Mentioned * Connect with Santosh on LinkedIn * Follow Complete Specialty Solutions on LinkedIn * CSS website

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Successfully keeping dental records goes beyond preventing lawsuits and insurance headaches. It’s necessary to provide excellent patient care and operate the best practice for your patients and staff alike. Auditing is required by many regulatory agencies, and having proper audit records could prevent malpractice lawsuits and other issues. On this episode of Talking With the Tooth Cop, I explain 7 main reasons why you must be excellent in the way you’re keeping dental records. I also outline 3 main types of audits and explain why YOU, the dentist, must justify every decision you make regarding patient care. It’s an episode packed with need-to-know information that can’t be missed, so be sure to listen.

7 reasons why you need to evaluate how you’re keeping dental records Keeping accurate dental records is the best way to protect your patients, your practice, and yourself. To comply with regulations, minimize risk, and continually improve on the way you practice dentistry, consider these 7 reasons why keeping great records is essential.

To reduce and ultimately prevent improper payments
To enhance patient care
To speed up and optimize proper claim payments
To minimize billing mistakes in our practice
To reduce the chances of an external audit
To show good faith and due diligence (protect our integrity)
To send a message to your staff that everyone should positively contribute to the practice by reporting, correcting, and learning from mistakes

Various types of audits can be used when keeping dental records Even though it’s easy to become complacent in mundane office-keeping tasks, maintaining proper records are essential. You can ensure the quality of your records through regular auditing processes. There are 3 main types of audits that you can implement.

Prospective/pre-bill audits
Retrospective audits
Limited/problem-focused retrospective audit

The first type of audit is done on a daily basis, where your office staff examines end-of-day reports and verifies every pending claim with actual treatments administered. These audits are time-consuming but prevent administrative hassles later on. The second type of audit doesn’t look at every claim or chart, but rather a snapshot of a few different types of charts. It holds everyone accountable for consistent processes. Finally, the third type of audit involves pulling 10 records, selecting one evaluation area, and examining those records against the one specific area (i.e. HIPPA form completion). The next time you pull 10 records, select a new evaluation area. This method is faster, although not 100% complete. For the full explanation of different types of audits, don’t miss this episode.

Comparing clinical notes with your dental and billing records is a crucial step Every dental practitioner and their staff should constantly ask themselves, “Do our clinical notes describe every aspect of the billing records?” The balance between clinical notes and billing is immensely valuable when taking preventive action against unnecessary paperwork and insurance issues. It’s important to carefully examine the claims you submit to insurance providers and look for red flags that would point towards gaps in information. This episode is full of helpful information that will make your practice and your office run much smoother - you don’t want to miss it.

The onus is on YOU, the dentist, to justify which treatments you provide to your patients As the dentist administering care, the burden of proof for explaining treatment falls on your shoulders. YOU have to justify the need for a treatment and why it was necessary. This is achieved by supporting the necessity with the following pieces of information:

A clearly stated diagnosis
Presenting conditions that support the diagnosis
All risk factors
Materials used
How you completed the treatment
Expected vs. actual outcome

Essentially, you have to tell the whole story, leaving no detail unexplained. If you have a great way of keeping dental records, it will guide you through this documentation process. And even if the treatment was medically necessary, if your dental records don’t reflect that, the payees will assume that it was not medically necessary. Transfer all of your knowledge and patient history onto paper, and you’ll save yourself from inconveniences in the future. For even more great insights, don’t miss this episode of Talking With the Tooth Cop.

Outline of This Episode * [0:21] 7 reasons why you need to evaluate how you’re keeping dental records * [8:49] Why should you audit these record keeping processes? * [10:57] You can use these 3 types of audits in your practice * [19:57] Comparing clinical notes with your dental and billing records is a crucial step * [30:52] YOU have to justify which treatments you give your patient * [35:37] The latest info on dental record retention timelines

Resources & People Mentioned * Eaglesoft dentistry software * Dentrix software tool

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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The Texas State Board of Dental Examiners has released new regulations regarding nitrous oxide delivery. These regulations are going to change the way your practice handles routine business, and you need to be aware of them. On this episode of Talking With the Tooth Cop, I outline the new 3 main rules, what requirements have not changed, and why your office needs to take these changes seriously. Note that these rules apply to all levels of nitrous oxide delivery and sedation and they are applicable for patients of all ages. It’s a complicated subject with many details, so to get the full story listen to this podcast episode.

These requirements have not changed, even after implementation of the new regulations Even with the new regulations, a few staples of dental care have not changed. You must employ qualified, trained staff who can identify problems and emergencies in your practice. Evaluating patients prior to sedation, utilizing consultations if necessary, and having written, expressed, and informed consent is still required when using nitrous oxide or any other method of sedation. Equipment checks must be completed thoroughly and regularly and proper patient records kept. You must also ensure all staff members are aware of who can and cannot be involved in delivering sedative drugs. To hear the full list of regulations that are still in place, be sure to listen.

New rule #1 - Preoperative checklists must be completed This rule applies to sedating any patient via any method. The TSBDE now required offices to “create and maintain in the patient’s dental record” a checklist entitled “Preoperative Sedation Anesthesia Checklist.” Included in this checklist must be the following:

Medical history review
Confirmation of informed consent
Confirmation of delivery of pre/post procedure instructions
Physical examination
Equipment readiness check confirmations
Any special preoperative considerations
Documentation for any/all reasons why portions of the checklist were not completed

This checklist may physically or electronically stored and the same checklist should be used by the dentist and anesthesiologist. It may be completed at any time prior to delivery of nitrous, but it must be repeated prior to ALL instances of delivery. For all of the details regarding the new checklist, don’t miss this episode.

New rule #2 - Offices must write emergency procedures and hold training sessions Every office now must have written policy procedures in place detailing how they are to handle emergency situations. Special attention must be given to respiratory crises and how the office will stock, monitor, and restock emergency kits. Staff must be trained regularly on these procedures to ensure everyone knows their responsibility during an emergency. It’s important to remember to not assign specific individuals emergency duties, but rather assign it to a position. Annual review sessions should be held as well to revise these procedures as necessary.

New rule #3 - Permit holders must have the proper drugs on site and immediately available Every dental office must be diligent in the way they keep records on nitrous oxide delivery. Special attention should be given to medicine cabinets and storage units to ensure expired drugs are disposed of and restocked with fresh supplies on a regular basis. Emergency kits with reversal drugs, AEDs with fresh batteries, and other necessary equipment should also be carefully monitored.

These new rules were established to ensure dental patients are receiving the best care possible. To ensure your practice is compliant, be sure to get the full story by listening to this episode of Talking With the Tooth Cop.

Outline of This Episode * [0:22] New nitrous oxide delivery rules are covered on this episode of Talking With the Tooth Cop. * [2:33] Existing regulations on nitrous oxide delivery and office equipment * [7:25] Equipment checks are necessary and IFUs should be present at all times * [14:40] Preoperative documentation is required in these main areas * [19:01] The dentist is the sole person responsible for these duties regarding nitrous delivery * [21:57] Latest information on the AAPD guidelines for nitrous oxide delivery * [28:35] Post-operative discharge record-keeping requirements * [35:05] New rule #1 - Preoperative checklist must be completed * [40:22] Why are these new rules so strict? * [43:05] New rule #2 - All permit holders for nitrous oxide must create emergency preparedness procedure manuals and hold training sessions for all staff * [48:14] New rule #3 - Permit holder must have the proper drugs on site and immediately available * [50:53] These new rules are required for all levels of nitrous administration and sedation * [54:01] What comes next after these rules? * [56:00] Where to turn for resources about these new rules

Resources & People Mentioned * REPORT: “Blue Ribbon Panel on Dental Sedation/Anesthesia Safety of the Texas State Board of Dental Examiners” * Duane’s insider resource: “Medical Emergency Training for Dental Offices”

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Keeping data secure is essential for operating an efficient 21st century dental practice. On this episode of Talking With the Tooth Cop I speak with 3 top professionals from CentriServe IT Dental Solutions - Matt Stafford, Jack Wiley, and Jared Galovich. You don’t want to miss their insights on the importance of keeping data secure, how to train team members accordingly, and the best way to spend your security budget dollars. Be sure to listen!

Why do dental professionals need to worry about keeping data secure? Dental professionals need to worry about keeping data secure because practices contain sensitive information that must be kept confidential. You are ultimately responsible for the data you collect on your patients, and you also need to protect your practice and team members. Keeping data secure is accomplished through a variety of steps, all of which are covered in full detail on this episode. Remember, the easiest way to handle a data breach is to prevent it from happening in the first place. Don’t miss this episode - your practice will thank you.

What is an audit log, and why do they matter? The most common type of audit log tracks who logs into your computers, when they logged in, what files they accessed, etc. You can monitor this log for any unusual activity, and it’s an important asset in the event of an audit or data breach. Maintaining these logs and keeping them organized are critical in order for them to be useful in your practice. If you have audit logs in place and you do experience a data breach, your monetary fines will be much lower than a practice who does not utilize this technology. We discuss the benefits of audit logs in full detail on this episode, so be sure to listen.

4 main areas dental offices need to focus on in order to keep data secure When you begin your data security process, you need to focus on these 4 main areas first and foremost:

Training staff on security procedures
Securely store your physical and digital data
Maintain and update firewalls and digital security measurers
Limit data access points

These systems can be implemented for a few hundred dollars per month. Preventative measures are much cheaper than crisis fixes, and your practice will benefit from focusing on these areas. Be sure to catch the full details on this episode of Talking With the Tooth Cop.

Invest in THESE top areas to keep your data secure If you only invest in two areas to keep your data secure, make sure it’s in a stellar firewall and secure communications for email and file sharing. Upgrading these 2 areas will place you years ahead of most dental practices, and it’ll keep the majority of your data secure. If you combine these two strategies with limiting data access control points and an off-site server backup program, your practice will be better set up for success.

Outline of This Episode * [0:22] Top professionals from CentriServe IT Dental Solutions are my guests for this episode * [3:30] Why should you care about data and login tracking? * [13:39] What is an audit log? * [19:15] The importance of selecting the correct communication channels * 32:49 The top data security areas dental offices need to focus on * [41:00] Invest your security dollars into these top areas * [47:25] Considerations for antivirus and cryptovirus software solutions

Resources & People Mentioned * CentriServe website * Call the CentriServe IT team at: (469) five five one 3144 * Email CentriServe * Email Jack * Email Jared

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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Featured on this episode of Talking With the Tooth Cop is author, business coach, and mentor Chuck Blakeman. Throughout the interview, Chuck and I discuss the critical differences between management and leadership, how to avoid falling into the trap of always planning and never executing, and Chuck shares the two most important business words you’ve never heard of. He draws on his 35 years of experience and multiple best-selling books to give you the greatest knowledge in the dental industry, and it’s a conversation you don’t want to miss.

Doing business should not be a 30 year grind! And why money is not the ultimate motivator Contrary to the “old guard” mindset that doing business has to involve 30 long years of doing work you don’t actually enjoy, business doesn’t have to be that way! Chuck urges listeners of this episode of Talking With the Tooth Cop to consider the question, “what motivates me to get out of bed and come to work?” The answer to this question is very rarely solely money-focused. Making money is not the sole empowering motivation to be at work, for any person in any industry. Essentially, dentists who own their own practice should strive to own an actual business, not a job. Too many practices rely on the dentist to be the income producer. And if the income producer isn’t physically present at the site (i.e. not on vacation or doing work outside of the office), money isn’t being made. If this is the way your practice is being run, then you own a job. Be sure to listen to my conversation with Chuck to discover how to rejuvenate your motivation for working in dentistry and how to revamp your practice’s processes.

What do Leonardo Da Vinci and the dental industry have in common? Even though the famous artist Leonardo Da Vinci and the dental industry have seemingly nothing in common, Chuck changed that mindset for me on this episode of Talking With the Tooth Cop. Da Vinci trained an apprentice to paint in exactly the same manner as he, stroke for stroke. The end result was 2 identical Mona Lisa masterpieces. Up until a few years ago, the world thought Da Vinci himself had painted both pieces. Chuck explains that the lesson to be learned from this story is that if Da Vinci can find someone to train and mentor to that high caliber level, then certainly modern dentists can too. You have to avoid the voice in your head that tries to claim that you’re the only person who can do this work and do it well. This theory is commonly referred to as the “craft person’s disease,” or the Da Vinci Principle. This mindset will prevent you from moving onto bigger and better projects. For the full intriguing story, don’t miss this podcast.

The best 2 questions to ask yourself and how to find the answers that will lead you to success The biggest takeaway from this episode surrounds 2 main questions: 1) Is what I’m doing right now the highest and best use of my time? And 2) If what I’m doing isn’t the highest and best use of my time, then how do I do it for the last time? Chuck tells me that you have to relentlessly pursue finding these answers because they will set you free. No matter if it takes you 3 minutes or 3 months after you answer these questions you will be presented with a game plan that will take you into the next level of business success. If you have to hire a new worker, train your current employees, buy a new software, or find a new process, whatever it may be, just start doing it! Your practice and your life-work balance will thank you.

Why management vs leadership destroys engagement and why you should have stakeholders instead of employees When employees are managed and not led, their ability to create and engage with the work is destroyed. That’s the idea behind Chuck’s second major book, “Why Employees Are Always a Bad Idea.” He claims that no one should ever be managed - everyone should always be led. If you replace the idea of having “employees” with having “stakeholders” your practice will achieve higher levels of flow and success. Chuck is a huge proponent of the idea of “giving everyone their brain back” and empowering them to make localized decisions in their area of expertise. By leading your stakeholders you require them to bring their highest and best level of work to the practice every single day. And that’s how you achieve your goals. Chuck explains these stellar ideas and more on this podcast episode, and you don’t want to miss his insights.

Outline of This Episode * [0:22] I introduce my guest for this episode, author Chuck Blakeman * [2:16] Chuck explains his background and discusses his new book for dentists * [4:44] On why younger audiences “get” these ideas easier * [7:52] Why you can and should find someone who can do your work as well as you can * [10:20] Chuck’s idea of a “maxi-me” and how you can love your work and do business better * [14:21] The two best questions to ask yourself as a business owner * [17:26] Management destroys engagement, and leadership creates it * [20:48] How to avoid suffering from paralysis of analysis, and the two most important business words you’ve never heard * [26:07] Chuck’s way of looking at the world in a counter-logical, 100% intuitive way

Resources & People Mentioned * BOOK: Making Money Is Killing Your Business, How to Build a Business You'll Love and Have a Life, Too * BOOK: Why Employees Are Always a Bad Idea * Get Off The Treadmill summit website * Chuck’s website

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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It can be challenging to balance all of the aspects of pediatric dentistry practices. Patients, employees, industry trends, insurance requirements, and countless other areas all demand your full attention. That’s why people like Tonya Burns, owner of Complete Dental Practice Consulting are such assets in the pediatric dentistry industry. In this episode of Talking with the Tooth Cop, I ask Tonya to share her knowledge of pediatric dentistry management systems. She covers four main areas of focus: the key systems for running an efficient practice, how to be a high-volume practice without feeling like a clinic, the art of putting patients at ease starting with the first phone call, and how to take Medicaid insurance and still have a productive practice. Your practice will benefit greatly from hearing her insights, so don’t miss this episode!

The key systems for running an efficient, fast-paced practice Identifying systems to implement in your practice to ensure positive workflow is essential. The clinical and business sides of your practice must be balanced, and systems are critical in order for patients to be taken care of quickly while still making them feel valued. Tonya explains that some of the major system categories include: the new patient process, treatment plans, financial plans, appointment scheduling, and everything involving insurance companies. She walks you through each of these categories in an engaging, informative manner and her advice should be heard, so give this episode your full attention.

How to be a high-volume practice without feeling like a clinic In order to be the most efficient practice possible, you need to start by asking yourself and your employees the following questions. Do we have the appropriate number of staff? Are we training our staff effectively and giving them the tools they need to succeed? Are we appropriately utilizing each employee’s skill sets and talents within our practice? Are our scheduling methods up-to-date and effective? And are we consistent in our management systems and in our communications with parents? By addressing these questions, your practice will be better equipped to handle large amounts of patients while still providing top-notch care.

The art of putting parents at ease starting with the first phone call Unfortunately, many parents have a fear of the dentist that they inadvertently pass onto their children. Tonya explains that pediatric dentistry professionals need to be highly skilled in putting parents (and their young patients) at ease starting from the very first interaction. This starts with having consistent verbiage that is used by all employees in all forms of communication (phone calls, emails, and at the check-in desk). Your team members also need to be able to convey treatment plans, describe financial details, and answer all questions in a prompt, clear manner. Be sure to catch all of Tonya’s insightful information on this episode of Talking with the Tooth Cop.

How to take Medicaid insurance and still have a productive practice Your pediatric dentistry practice CAN overcome the Medicaid stigma! All of the systems and processes that Tonya discussed in the first three sections apply to Medicaid patients as well, and all of these details need to be tracked in order to be effective. To combat the “see hole, fill hole” scheduling mentality, she recommends scheduling Medicaid patients in low-demand time frames, but not creating exclusive Medicaid days. She also suggests not immediately focusing on what type of insurance a family has during the first few minutes of a new phone call. For the rest of Tonya’s suggestions on handling Medicaid in your practice, be sure to listen to this episode.

Outline of This Episode * [0:35] I introduce my guest for this episode, Tonya Burns, owner of Complete Dental Practice Consulting * [3:33] Why pediatric dentistry is Tonya’s greatest passion and the 4 main topics covered in this episode * [4:50] Why the best way to describe pediatric dental practice management is organized chaos * [7:11] Systematizing the new patient process * [13:09] The treatment plan and financial details phase in pediatric dentistry * [17:06] Insurance and financial expectations - don’t get caught in absolutes * [20:38] Overcoming scheduling challenges in a pediatric dental practice * [26:11] How to handle unscheduled treatments in your system * [28:47] Suggestions for your account statement and insurance update systems * [30:26] How to be a high-volume practice without feeling like a clinic * [37:41] Putting patients and parents at ease starting with the first phone call * [44:30] How to be productive while still taking Medicaid insurance * [49:31] I ask Tonya general questions surrounding pediatric dental practice management processes

Resources & People Mentioned * Complete Dental Practice Consulting website * Complete Dental Practice Consulting on LinkedIn * Tonya’s office number: (269) 783-5360 * Tonya’s cell number: (574) 304-2727 * tonya@competedentalpracticeconsulting.com

Connect With Duane * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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On this episode of Talking with the Tooth Cop, I explain seven of the most important things to look for in your dental records. I also describe different types of audits that can be used to ensure efficient and effective record-keeping practices as well as explain why all of these processes are critical in your dental practice. Keeping proper records goes beyond preventing lawsuits and insurance headaches. It enters into the realm of ensuring adequate patient care and doing your best to operate the best practice for your patients and staff alike. Be sure to catch the full episode for all the details!

Why you need to ensure exceptional dental records via auditing In my experience, I have learned that unfortunately, most schools do not teach the critical skill of writing good records. In a constantly changing regulatory environment, stellar recordkeeping provides an invaluable layer of security to your practice. Even though it’s easy to become complacent in mundane office-keeping tasks, proper records are essential. They provide an ongoing, chronological record of what you did, why you did it, when it happened, and how you performed the procedure. Essentially, they enhance patient care. Don’t forget to listen to the full audio to discover all seven items to look for in your records!

Types of audits used in dental practices On this episode, I explain a variety of different types of audits that can be used in your practice. Prospective/pre-bill audits occur on a daily basis and essentially check for missing line items in billing. It’s always easier to take the time upfront to check for accuracy, and I guarantee it’ll save your billing staff incredible amounts of time in the future. Issues with under and over-payments to insurance companies take away from the time you could be spending working directly with patients and building up your staff. Daily auditing is one thing you can do that can impact your bottom line. For more information on retrospective audits, comprehensive audits, and focused retrospective audits don’t miss this informative episode!

Comparing clinical notes with your dental records - a crucial step Every dental practitioner and his/her staff should constantly ask themselves, “Do the clinical notes describe every aspect of the billing records?” The balance between clinical notes and billing is immensely valuable when taking preventive action against unnecessary paperwork and insurance issues. It’s important to carefully examine the claims you submit to insurance providers and look for red flags that would point towards gaps in information. This episode is full of helpful information that will make your practice and your office run much smoother - you don’t want to miss it.

Dental records as justification for patient treatment For cases of restorative and needed treatment, dental records serve as a backup layer of information in the event of an audit. They describe why a particular diagnosis was given, why a procedure was recommended, and the follow-up care that was prescribed. When dentists are audited, the first layer is typically not done by a fellow dental professional. Having accurate records laid out in layman’s terms can exponentially speed up the audit process. It’s important to always be examining ways in which record-keeping habits can be tweaked and improved upon. You don’t want to miss the rest of this insightful episode of Talking with the Tooth Cop.

Outline of This Episode * [0:25] Introduction of this episode’s topic - 7 Things to look for in your dental records * [10:45] Types of audits - prospective/pre-bill audit * [13:38] Types of audits - qualitative retrospective audit * [14:27] Types of audits - comprehensive audit * [15:28] Types of audits - focused retrospective audit * [16:40] Dental records complying with regulatory requirements * [19:38] Examining records for clinical notes * [22:32] Overview for the top 7 things to look for in dental records * [26:20] Double-checking clinical notes and dental records * [30:24] Records as justification for patient treatment * [35:11] Timeline for record retention

Connect With Me * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

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In any environment where people are being served, customer service is of primary importance. Dental practice customer service needs to be a huge priority for every dental office because there is already a built-in “fear factor” of sorts that has to be overcome. My guest today is Dr. David Moffet, my long-time friend who is a Dentist and dental practice consultant who has literally made it his business to learn and teach excellent customer service in dentistry. This conversation is fun and filled with all kinds of insights about what it takes to be the dental practice of choice for your existing patients, making them your advocates to new patients. Find out more by listening.

Customer service in dentistry is all about the experience your patients have. Everybody seems able to recount a horror story about a visit to the dentist. Sometimes they are laughable and entertaining, but in the end, you don’t want them to be about YOUR practice, do you? Customer service in dentistry is all about the experience your patients have while they are in your office, and the way you set up your systems, train your staff, and even the number of people you have on the clock at any given time are the ways you create that enjoyable experience your patients will tell their friends and family about - in a positive light. Dr. David Moffet shares some of his many insights about how to create a dynamic dental practice that attracts customers instead of repelling them, on this episode.

Your dental practice needs to avoid communicating a nickel and dime attitude. We all know dental treatment can be expensive. It’s not something that can or should be hidden. But the negative feelings patients may have about the expense can be offset by the type of interactions they have with you and your team. Make their experience more valuable to them personally, more patient-focused so that what your patients receive makes a deeper, lasting impact. Practically, that means avoiding anything that communicates that you’re focused on the fees. How do you accomplish that? My guest, Dr. David Moffet has some great tips to help you make your practice different in those important ways, so don’t miss this episode.

There’s no new secret to success: Treat others the way you want to be treated. Imagine the typical dental waiting room. There are many patients waiting to be seen, sterile music is playing, hushed conversations are happening in the reception area, the phone rings now and then. It's pretty boring and definitely not fun. Is that what you're aiming for? What can you do to create a different experience for your patients? What can you do to make it enjoyable, different, and even fun? The effort you make in these unnoticed areas are what set you apart, making your practice the go-to office for dental treatment. Join me as I talk with Dr. David Moffet about how to create the ultimate patient experience, on this episode of Talking With The Toothcop.

It’s true in dental practices too: you have to spend money to make money. Too often, dental practices are run like assembly lines. Patients in, patients out. When it starts to feel that way to your patients, you’ve got a situation that needs to be remedied immediately. Yes, you need to be efficient in order to keep costs low, but not at the expense of the experience your patients have. On this episode, Dr. David Moffet shares some of the best ways you can spend money to create a better patient experience and how they produce a great return in terms of profitability and the ability to scale your practice, ultimately serving even more patients. Be sure you take the time to listen.

Outline of This Episode * [0:22] Introducing my friend, Dr. David Moffet and why he’s on the show. * [10:58] What good relationships with patients look like. * [14:17] Dave’s perspective on creative ways to get to know and serve patients. * [23:44] Different cultural backgrounds and effective use of gifts for patients. * [34:30] How to handle online reviews to make customers your advocates. * [38:25] How Dental practices can prepare new hires for difficult situations. * [44:02] Why it’s true that you have to spend money to make money.

Resources & People Mentioned * Connect with us at 817-755-0035 to register for the upcoming compliance event. * https://TheUltimatePatientExperience.com * http://www.BuildingYourDreamPractice.com * BOOK: How to Build the Dental Practice of Your Dreams (Without Killing Yourself)

Connect With Me * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

How To Build The Dental Practice Of Your Dreams: (Without Killing Yourself!) In Less Than 60 Days

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It’s pretty exciting to me to be bringing you this first episode of my new podcast, “Talking With the Toothcop.” I’ve been wanting to do this for a long time and finally decided it was time to get moving. You’ve happened upon the “zero episode” where I explain a bit of who I am, why I’m doing this podcast in the first place, and what you can expect from it week to week. Dental compliance is something all you busy dental professionals know is important but don’t have the time to learn inside and out. That’s why I’m here. I’m the toothcop.

Compliance has a lot to do with whether your dental practice is successful or not. All you dental pros out there know that building a successful dental practice isn’t as simple as graduating from dental school and turning on your "open" sign. You’ve got a lot of regulatory hoops to jump through in order to set up shop efficiently and in a way that isn’t going to get you into trouble. You could do the work to learn it all yourself, or you can let me help. I’m here to walk you through the headaches of OSHA and HIPAA compliance, the upkeep of patient records and more. My name is Duane Tinker, but you can call me Tink - and I’m the Toothcop. Join me for weekly podcast episodes and learn what you need to know about dental compliance issues.

Everybody needs an ally to help them know what they don’t know, so they can know it. I’m like anyone else, I don’t know what I don’t know. That’s why it’s helpful every now and then to put myself in the place of the student, to learn from someone who’s been down the path I want to go down. If you work in the dental industry you know that feeling because the regulatory burden of compliance is one of those dark, scary paths you need to walk down, but don’t really want to. My company, Dental Compliance Specialists is designed to serve as your ally, we are there to ensure that you are doing what it takes to avoid lawsuits and disciplinary actions. We are ready with our knowledge and expertise to help you get your practice in line with the law - and this podcast is your weekly pep talk and info download to let you know, you can do it!

Do you know what investigators are looking for when they look into your dental practice? One of the advantages I have in coming alongside as your audio dental compliance partner is that I used to be on the other side - I investigated dentists for noncompliance issues. So I know what the investigators are searching for when noncompliance is suspected, and I want to help you get through those investigations unscathed. I’ve assembled my own team of investigators that will come into your dental practice and complete a thorough audit. But short of that, I want to serve you on this podcast by sharing my experience with you, so you can be ready the next time they knock on your door.

Every dental professional has read the compliance laws that govern their practice, right? I agree with you. You don’t have time to read and understand every word of the legislation that governs your work as a dental professional. For that reason, it’s almost impossible to comply with the rules and regulations set forth by the agencies - unless you have some help. I lead a team of compliance specialists who want to help your practice follow the necessary laws so that you are never in any legal trouble. You worked hard for your dental degree, so don’t put it in jeopardy through a noncompliance issue you didn’t know about. Let us help. Subscribe to this podcast and get weekly info to help you stay out of trouble and in the black.

Outline of This Episode * [0:22] What is this podcast series about? And who am I, Duane Tinker? * [2:01] How I got into consulting through law enforcement. * [5:33] The power in a network as compliance experts and dental professionals.

Connect With Me * https://www.dentalcompliance.com/ * toothcop(at)dentalcompliance.com * On Facebook * On Twitter * On LinkedIn * On Youtube

Talking with the Toothcop: Recent Episodes

Duane Tinker

1 Identify the potential threats and risks to PHI

2 Address the higher-risk or potential risks areas