Assume your organization will begin offering synchronous telemedicine services and you have been asked to present information about incorporating an enterprise risk management program that mitigates risks and provides strategies for operational (credentialing, standard of care, and documentation) clinical/patient safety, financial, and legal/regulatory (HIPAA, HITECH, CMS), state-specific regulations, and technology. Write a 750-1,000-word report to the administrative team that: • Describes how the risk management program will address areas of concern over operational, clinical/patient safety, financial, legal/regulatory, and state-specific regulations, as well as technology. • Explains the risk for potential liability and malpractice upon the provider or organization if policies and procedures do not address identified risk concerns. In addition to your textbook, you are required to support your analysis with
Sample Answer
Enterprise Risk Management Program for Synchronous Telemedicine Services
To: The Administrative Leadership Team From: [Your Department/Compliance Office] Date: October 25, 2025 Subject: Implementation of an Enterprise Risk Management (ERM) Program for New Synchronous Telemedicine Services
I. Introduction and Program Goal
The launch of synchronous (real-time, video-based) telemedicine services represents a strategic imperative for expanding access and efficiency. However, this transition introduces complex and interconnected risks across operational, clinical, financial, legal, and technological domains. To ensure the safety of our patients and the financial and legal integrity of the organization, we propose establishing a specialized Enterprise Risk Management (ERM) Program dedicated to telemedicine governance.
The goal of this ERM program is to proactively identify, assess, mitigate, and monitor risks unique to virtual care, aligning all processes with the highest standards of care and regulatory compliance.
II. ERM Program Strategies by Area of Concern
1. Operational Risks (Credentialing, Standard of Care, Documentation)
Operational efficiency and legal compliance hinge on standardized virtual workflows.
Area of Concern
Risk Mitigation Strategy
Credentialing & Licensure
Policy: Implement mandatory pre-service credentialing checks to verify provider licensure in both the originating (provider) and distant (patient) states. The ERM program will enforce continuous monitoring of evolving interstate medical practice regulations (e.g., temporary licenses, reciprocity agreements).
Standard of Care
Policy: Develop Telemedicine Standard Operating Procedures (SOPs) that define when virtual care is appropriate versus when an in-person visit is required. This addresses the limitations of the virtual physical exam by requiring explicit, documented protocols for patient triage and referral.
Documentation
Policy: Mandate the use of specific, time-stamped Electronic Health Record ($\text{EHR}$) templates for all synchronous visits, capturing the patient’s physical location, the provider’s location, the type of technology used, and explicit confirmation of informed consent. This ensures the medical record fully supports the care provided.
2. Clinical/Patient Safety Risks
Patient safety in the virtual environment is paramount, particularly concerning emergency management and technology limitations.
Informed Consent: The ERM program will enforce a comprehensive, written telemedicine-specific informed consent process. This consent must clearly explain the differences from an in-person visit, including potential risks related to technology failure, security, and the inability to perform a hands-on physical exam.
Emergency Protocols: We must establish and annually drill clear Emergency Response Protocols. This includes mandatory verification of the patient's exact location at the start of every visit and immediate, documented procedures for dispatching local emergency medical services ($\text{EMS}$) if a patient experiences a medical crisis during the synchronous session.
Clinical Competency: The program requires mandatory training and competency sign-off for all providers on remote assessment techniques and proper use of peripheral diagnostic devices (if applicable).
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