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DPH outlines expanded compliance program and interactive training ahead of EHR rollout
Summary
Maggie Rykalski described a department-wide compliance program aligned to federal OIG elements, an interactive compliance/privacy/data-security training to launch in January, a confidential hotline, internal auditing, and plans to add a population-health compliance officer; commissioners requested annual reporting and progress updates tied to EHR deployment.
Maggie Rykalski, director for the Office of Compliance and Privacy Affairs, presented an overview of the San Francisco Department of Public Health's compliance program and upcoming training plans.
Rykalski said the program follows the Office of Inspector General's seven elements for an effective compliance program and highlighted a new interactive training module combining compliance, privacy, and data-security topics that the department plans to roll out in January. She described existing components — designated compliance officers in major service areas (ZSFG, Laguna Honda, Behavioral Health), a confidential 800-number hotline and email for reports, regular internal audits and risk assessments, disciplinary guidelines coordinated with Human Resources, corrective-action plans, and a newly expanded 20-page Code of Conduct with a short summary for staff.
Commissioners asked how training would be delivered and tracked; Rykalski said the module will be on the department's learning platform and that staff will have to participate (the module is interactive and not skippable). Commissioners also asked about EHR and data-security training; staff said EHR-specific training will be required before anyone receives EHR access and that the compliance module will include data-security elements. The department plans additional targeted on-site trainings and a recurring compliance bulletin.
Rykalski said the department will provide an annual compliance report on a calendar-year basis and will add a compliance officer focused on population health. Commissioners suggested the annual report include progress updates on the new training rollout, audits, and metrics related to conflicts of interest and other priorities.
Next steps: the department will launch the interactive compliance module in January, integrate data-security and EHR-specific training as the EHR rolls out, and include compliance reporting on the commission calendar.
