The Mihalik Blog

Nonna Tata

Earlier this week, on a cold and rainy evening, Melinda and I were sitting in a darkened car on a ramshackle street in Fort Worth with a bottle of wine between us.  The bottle wasn’t open, mind you, just sitting there.  As were we.

In Fort Worth on business, we planned to have dinner at a small restaurant called Nonna Tata.  The restaurant has 21 seats—quite literally.  We counted them, including the four that were piled in the corner next to our table. 

Being not much bigger than a phone booth turned on its side, the restaurant doesn’t take reservations.  There’s really no place to wait inside till one’s table is ready.  Hence for us, and I suspect several other patrons, our car became our waiting room.  We were called on the cell phone when our table was ready. 

Nonna Tata doesn’t have a beer and wine license, so when we put our name on the waiting list, we were told we could buy wine at the shop across the street.  The shop across the street turns out to be a vegan coffee shop, the Spiral Dinner, that stocks one type of red and one white wine.  Both organic.  The red was quite drinkable.

Dinner turned out to be an unexpected delight.  Our antipasto platter was well portioned for two and featured an array of superb quality Italian meats and cheeses.  The spaghetti with spinach and lemon was perfectly cooked and had just enough cream to keep it from being dry but not overly rich.  The lemon juice provided a spike of excitement to the flavor.  The salad was disappointing, but not because it wasn’t good.  It just wasn’t Italian.  The dinner salad included with each entrée, was packed with an array of fresh vegetables plus a sprinkling of canned corn kernels.  It was a great American salad but out of character with the rest of the meal.  Neither of us had room for dessert. 

We planned to go back the next evening to try a few other items on the menu but when the weather got even colder and rainier, we decided that we weren’t up for sitting in our makeshift waiting room till a table cleared out but we’re eagerly awaiting our return to Fort Worth in better weather when two outdoor tables are added to the mix. 

On to the business of accreditation…

As noted in a previous blog, NCQA came out with its clarification to CR 6B on November 19^th. 

Thinking about HIPAA

Does anyone think about HIPAA much any more?

The Privacy and the Security Rules require periodic assessments of privacy and security practices and modification of systems and processes based on the results of the assessments.

Larger organizations have teams of people who can address these issues.  It’s more challenging for smaller organizations that need to spread complex functions across a small pool of staff.  This is especially true for the security provisions—which are quite technical—but even a periodic assessment of privacy practices can be permanently relegated to the “back burner” by busy staff.  After all, there aren’t any HIPAA police, right?

Privacy and Security assessments make good business sense.  Think of all those agreements you’ve signed agreeing to comply with HIPAA.  Could you prove that you’re doing what you’ve agreed to do if asked?

I’m also seeing HIPAA issues show up in the work that I do as an expert witness for medical malpractice and other types of legal cases.  Think about what might happen if there was an alleged breach of confidentiality and you were asked to produce evidence of your compliance with HIPAA, including periodic assessments.

If you haven’t gotten your privacy and security policies and procedures completed, don’t wait!  It’s way past the deadline.  If you haven’t done your periodic assessments, make it a New Year’s Resolution to begin early in the first quarter. 

Suitable for smaller organizations, The Mihalik Group has comprehensive sets of policies and procedures—one set for privacy and one for security—should you need to jump-start your efforts.  We can even do an assessment of privacy practices and a security risk analysis. 

NCQA Clearinghouse

A while back, I discussed using this blog as a forum for discussing NCQA-related compliance issues.  I got some positive responses, both here and directly from some client organizations. 

Let’s see if we can get this started.

My suggestion is that you use the comment feature at the bottom of this post to submit topics or questions that you’d like to see discussed.  I’ll use the suggestions to create topic threads, solicit feedback through the comment feature, and moderate the posts. 

This could be a really good way to pool collective expertise regarding how to meet some of the challenges of complying with NCQA accreditation standards. 

So, send in your NCQA-related questions, concerns and comments, please…