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Executive Summary of February 2019 Board of Directors Meeting

Partnership at Starling is a privilege that comes with the responsibility of citizenship.  Some Board discussion topics are important for all partners to be aware of.  For the February 2019 meeting, these topics included an update to HIPAA policy violations, Board certification for partners, and $15 minimum salary.

HIPAA Violations

In the past, Starling compliance policy stated that any time an employee looks at his/her own medical record, whether intentional or not, it is considered a terminable offense.  The board asked the compliance committee to review the policy a year ago and changes were made such that unintentional violations did not result in immediate termination. At the time, this was processed through the compliance committee and voted on by the Board. We were given legal counsel that not terminating for such an intentional HIPAA violation would put the organization at significant legal and regulatory risk.   Recently, another situation arose concerning an intentional violation with similarly mitigating circumstances, and an updated legal opinion was obtained, this time with a change in recommendation.  Based on updated legal precedents over the last 1 to 2 years, it is now felt that termination is not automatically necessary for all intentional HIPAA violations.  The policy will be returned to the compliance committee for further revision. 

Board certification

Most partners and employed providers at Starling are board-certified or board-eligible. The Starling employment contract requires either board certification or board eligibility as criteria for partnership. Additionally, most hospitals require this status for privileges and many private insurers require it for inclusion in provider panels. Both hospitals and insurers have actively enforced this policy. Situations may arise, however, when a partner is unable to maintain board eligibility.  There has also been controversy over the last few years as to the utility/meaningfulness of board certification. In light of this, the board discussed whether to maintain or change current policy.  After much discussion, the board felt maintaining current policy is in the best interest of the organization. 

Minimum starting salary $15/hr

A number of the medical employers both locally and nationally have increased minimum employee salary to $15 per hour. The macroeconomic success of these policies is the subject of much discussion.  Nonetheless, it can make it difficult to successfully recruit lower wage employees including MAs and some patient service representatives. The Starling board discussed and, in order to encourage competitive balance, voted to create a minimum salary of $15 per hour for all new hires.  

If you would like to discuss or make your opinion known on any of these topics please email me directly.

Sarit Patel, MD, MBA
Chair, Starling Board