By Dennis W. Murphy, MD, Medical Director, Occupational Health Services, Self Medical Group
After years of struggling with bloodborne pathogen (BBP) management like so many others in healthcare organizations around the country, our group has developed an easily implemented system that works very well and has reduced incomplete follow-ups to a very small percentage of cases. A surprising fact about these cases is that victims usually are not spontaneously compliant with follow-ups and frequently have to be called multiple times for each additional visit.
You would think that after exposure, particularly when the source is positive for one or more infections, affected parties would be worried enough to follow up. You would think but you’d be wrong. As a result, we’ve developed a packet that gets printed out when the exposed patient presents. The first two pages are instructional, for providers that don’t encounter this very often. The packet includes the following:
- A checklist of actions and documents to ensure all the bases are covered
- The form for documentation of the event
- A worksheet for calculating the date for subsequent vaccinations and/or labs
- A form to lay out the schedule for follow-up – one to keep in the office and one to give to the victim. This same form serves to track subsequent labs as they come in so that all the labs are collated in one place.
- A second form for laying out the schedule when HIV PEP is prescribed(which is mercifully very rarely)
- The consent forms
- The counseling form, which is discussed with and provided to the victim
- The report forms to send to the victim informing them of the source individual’s infection status (anonymously) and their own status
- The employer notification letter (and accompanying summary of the pertinent OSHA regulations which must accompany the letter)
At the time of the initial encounter, victims are entered on a tracking spreadsheet with their planned dates for follow-up labs and immunizations. This is the tricky part, because
The follow-up sometimes changes over time, based on events along the way. The spreadsheet can be edited over time to accommodate these changes. This is reviewed weekly, and calls are made to patients who are due for labs in the next week and to those who are delinquent on follow-up. Only very occasionally do we end up closing a case with missing follow-up due to a victim’s refusal to attend. The main liberty (non-compliance) that we’ve taken in all this is that our employer notification letter includes information not dictated in the regulations.
Our version includes the dates of all subsequent scheduled visits (although it does not disclose the purpose of the visits for labs and/or immunizations). The rationale behind this is that the employee is likely to have to leave (or be late for) work to go to those appointments, and it relieves them of having those absences without an excuse. Also, this extra information does not impact the amount of protected health information disclosed.
During the time I was in private practice, we never encountered another local office to evaluate our own employees when they had an exposure that could provide both the management and the reporting requirements properly and consistently. The most common mistake we encountered was when other offices would send us information beyond what the regulations say that the employer is entitled to (e.g. –the actual laboratory reports).
For any offices interested in developing their own system, we’ve provided samples of our BPP protocol patient evaluation packet and our protocol log to NAOHP.
They are available at the following links: https://www.naohp.com/articles/
