Disadvantages of Spreadsheets – Obstacles to Compliance in the Healthcare Industry

Most of the regulatory compliance issues we talked about concerning spreadsheets have been related to financial data. But there are other kinds of data that are stored in spreadsheets which may also cause regulatory problems in the future.

In the US, a legislation known as HIPAA or Health Insurance Portability and Accountability Act is changing the way health care establishments and practitioners handle patient records. The HIPAA Privacy Rule is aimed at protecting the privacy of individually identifiable health information a.k.a. protected health information (PHI).

Examples of PHI include common identifiers like a patient’s name, address, Social Security Number, and so on, which can be used to identify the patient. HIPAA covers a wide range of health care organisations and service providers, including: health plan payers, health care clearing houses, hospitals, doctors, dentists, etc.

To protect the confidentiality, integrity, and availability of PHI, covered entities are required to implement technical policies such as access controls, authentication, and audit controls. These can easily be implemented on server-based systems.

Sad to say, many health care organisations who have started storing data electronically still rely on spreadsheet-based systems. Those policies are hard to implement in spreadsheet-based systems, where files are handled by end-users who are overloaded with their main line of work (i.e. health care) and have very little concern for data security.

In some of these systems, spreadsheet files containing PHI may have multiple versions in different workstations. Chances are, none of these files have any access control or user authentication mechanism whatsoever. Thus, changes can easily be made without proper documentation as to who carried out the changes.

And because the files are normally easily accessible, unauthorised disclosures – whether done intentionally or accidentally – will always be a lingering threat. Remember that HIPAA covered entities who are caught disclosing PHI can be fined from $50,000 up to $500,000 plus jail time.

But that’s not all. Through the HITECH Act of 2009, business associates of covered entities will now have to comply with HIPAA standards as well. Business associates are those companies who are performing functions and services for covered entities.

Examples of business associates are accounting firms, law firms, consultants, and so on. They automatically need to comply with the standards the moment they too deal with PHI.

More Spreadsheet Blogs

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Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

How Internal Auditors can win the War against Spreadsheet Fraud

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

Still looking for a Way to Consolidate Excel Spreadsheets?

Disadvantages of Spreadsheets

Spreadsheet woes – ill equipped for an Agile Business Environment

Spreadsheet Fraud

Spreadsheet Woes – Limited features for easy adoption of a control framework

Spreadsheet woes – Burden in SOX Compliance and other Regulations

Spreadsheet Risk Issues

Server Application Solutions – Don’t let Spreadsheets hold your Business back

Why Spreadsheets can send the pillars of Solvency II crashing down

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Becoming Nimble the Agile Project Management Way

In dictionary terms, ?agile? means ?able to move quickly and easily?. In project management terms, the definition is ?project management characterized by division of tasks into short work phases called ?sprints?, with frequent reassessments and adaptation of plans?. This technique is popular in software development but is also useful when rolling out other projects.

Managing the Seven Agile Development Phases

Stage 1: Vision. Define the software product in terms of how it will support the company vision and strategy, and what value it will provide the user. Customer satisfaction is of paramount value including accommodating user requirement changes.
Stage 2: Product Roadmap. Appoint a product owner responsible for liaising with the customer, business stakeholders and the development team. Task the owner with writing a high-level product description, creating a loose time frame and estimating effort for each phase.
Stage 3: Release Plan. Agile always looks ahead towards the benefits that will flow. Once agreed, the Product Road-map becomes the target deadline for delivery. With Vision, Road Map and Release Plan in place the next stage is to divide the project into manageable chunks, which may be parallel or serial.
Stage 4: Sprint Plans. Manage each of these phases as individual ?sprints?, with emphasis on speed and meeting targets. Before the development team starts working, make sure it agrees a common goal, identifies requirements and lists the tasks it will perform.
Stage 5: Daily Meetings. Meet with the development team each morning for a 15-minute review. Discuss what happened yesterday, identify and celebrate progress, and find a way to resolve or work around roadblocks. The goal is to get to alpha phase quickly. Nice-to-haves can be part of subsequent upgrades.
Stage 6: Sprint Review. When the phase of the project is complete, facilitate a sprint review with the team to confirm this. Invite the customer, business stakeholders and development team to a presentation where you demonstrate the project/ project phase that is implemented.
Stage 7: Sprint Retrospective. Call the team together again (the next day if possible) for a project review to discuss lessons learned. Focus on achievements and how to do even better next time. Document and implement process changes.

The Seven Agile Development Phases ? Conclusions and Thoughts

The Agile method is an excellent way of motivating project teams, achieving goals and building result-based communities. It is however, not a static system. The product owner must conduct regular, separate reviews with the customer too.

Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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Green Business!

Carbon emissions reduction has evolved beyond simply good citizenship to being a business tool. Implementing ?green? initiatives is now a competitive weapon which defines real business opportunities and bottom line savings that can contribute significant financial value to the organisation while meeting demanding customer requirements for sustainable and low-carbon products.

Energy efficiency is a low cost resource for achieving carbon emissions reduction. Better energy efficiency simply translates to lesser carbon emissions and less energy usage which translates into saved costs.

Reduction of an organisations carbon footprint is each and everyone?s responsibility. Human activities are the key responsibility for the release of greenhouse gas emissions into the atmosphere. These include usage of electricity generated from fossil fuel, heating or driving.

At the corporate level, various measures can be instigated to increase energy efficiency. Some of these can be, having zone lighting with sensors to minimise unnecessary office lighting, timers on large IT equipment, promoting energy efficient behaviour in the office, asking staff to switch off and unplug appliances when not in use and minimising staff travel.
At the individual level; it is the small habits that count; cultivating the habit of switching off unnecessary lights, plugging out appliances that are not in use, using video conferencing or online chatting instead of having to travel to meetings, using public transport instead of taking a taxi/ personal car and using energy efficient cars.

All these initiatives assist organisations in their corporate social responsibility reports and play a role in sustainability rankings which is instrumental to customers who are increasingly considering sustainability rankings in investment decisions, while achieving the goal of cost reduction internally.