The Importance of Having an Office Policy Manual

The importance of having a written office policies and procedures manual in a dental practice cannot be overstated.  Documenting the rules of the workplace allows the practice owner to hire and terminate employees without fear of unjust discharge suits based on a variety of causes of action, whether they are justified or not.  Also, there are statutory rules that dental offices must follow as far as HIPAA privacy and security laws, OSHA regulations, the Massachusetts Dental Regulations, and employment laws that employees should not only be aware of, but must acknowledge in writing that they will abide by them or face discipline or termination.

Since dentistry is a profession that regulates the training required to perform specific procedures, the Massachusetts Dental Regulations has a large section devoted to specifying exactly what dentists, the four categories of dental assistants, and hygienists can and cannot perform, and what supervision is required.    To be able to memorize and keep track of all these specific rules while still conducting a smooth running practice is extremely difficult without having some written reference that dentists or any personnel can consult to see if they can or cannot perform specific procedures with or without the general, direct or immediate supervision of a licensed dentist.   And with new rules on expanding the abilities of trained personnel who are non-dentists to perform certain procedures always changing, having that reference in a policies and procedures manual is essential.

HIPAA, the HITECH patient information security rules, and the Massachusetts Data Security Regulations have just been updated and are restrictive than ever about the handling and possible illegal releases of Protected Health Information of patients as well as other private information.  All offices must have their office policies and procedures updated as of September 23, 2013 to ensure they are abiding by the new 2013 rules.  Enforcement of the new rules is rising dramatically too, and office personnel must be aware that not only are they jeopardizing their own job security within the dental office with violations, but that they can be individually penalized for breaches of patient privacy, starting with minimum  $100 penalties.  Dental practices that don’t  give employees the proper training in these regulations, required to be documented annually, and don’t make sure employees acknowledge in writing that they have been trained and know the privacy rules risk stiff penalties by both federal and state government agencies.

OSHA has always been an important regulation that identifies dentists specifically to ensure proper sterilization of instruments and equipment, disposal of waste, and handling of hazardous chemicals that are part of the running of any dental practice.  These rules must be in writing, and including them in a policy and procedures manual along with stated discipline which will be handed down for noncompliance by employees is important to protect the dentist in case OSHA inspectors stop by.   Firing an employee after they don’t obey OSHA rules, but before documenting that the dental practice has made them aware of office policy concerning obeying OSHA standards is asking for a lawsuit by a disgruntled ex-employee who claims he or she is actually a whistleblower for general office violations.

Written office policies ensuring compliance with employment law statutes as well as for general rules concerning lateness, misconduct, workplace grooming and dress, etc. should be in effect and acknowledged by employees in writing.  A section prohibiting harassment because of gender, age, race, sexuality, or disability, and explaining specifically what kinds of actions will not be tolerated should be in any policy and procedures manual.  Written disciplinary procedures which include first, second or final warnings before dismissal should be in place to allow for terminating employees without them later saying wrongly that they should get unemployment benefits in spite of misconduct, or if they are a member of a protected class, that the termination was discriminatory and not for justified reasons.

The policies and procedures manual for a dental office should be more extensive than for other employers, and training in the variety of rules that must be followed in a health care setting is important in effective implementation of a good manual.