Despite nearly a decade of studies and warnings, Medicare cards continue to display participants’ SSNs prominently on the face of the card as their Health Insurance Claim Number (HICN) or patient identification number. This number is also displayed on all claim forms mailed to participants’ homes.

As the studies and warnings clearly point out, this practice leaves participants vulnerable to identity theft when Medicare cards are stolen or claim forms are mailed to the wrong address. This is a common occurrence. It also leaves the Medicare program itself more vulnerable to fraud when identity thieves use stolen Medicare cards to obtain personal medical care and/or to submit fraudulent claims. Using SSNs as a patient identifier is just a bad idea, particularly in light of the fact that other state and federal laws specifically prohibit the use of SSNs in this way.

Both the (CMS) and the U.S. Government Accountability Office (GAO) have studied this issue in some depth. Yet, despite across-the-board agreement that the practice needs to change, no relevant government agency, nor Congress, has taken the necessary action to require the change.

A key reason for this inaction, beyond the studies, is the cost. A 2012 GAO Report examined two options to address the issue:

1. Continue to use SSNs but hide the first five digits.
2. Replace SSNs with a new Medicare Beneficiary Identifier

However, CMS concluded that implementing either option would involve between 40 to 48 government IT systems and would take approximately four years to complete. Early CMS estimates indicated that replacing SSNs with the new MBIs would cost up to $845 million. More recent GAO estimates bring that number down considerably to between $255 million to $317 million. Note that these estimates do not include costs hospitals and providers would incur when making changes to accommodate the new MBIs.

So, things stand pretty much where they have stood since this issue first became a key point of study and discussion years ago. The most recent GAO Report (September 2013) on the matter concluded that despite the many warnings resulting from the studies and the increasing level of Medicare card theft, CMS still had not given the green light to any project that would remove SSNs as the Medicare card patient identifier. CMS has also failed to follow the lead of other existing state and federal laws prohibiting the use of SSNs as patient identifiers.

But hope springs eternal. Maybe CMS will seize the opportunity to make the change during the current modernization project of CMS’s overall IT systems. As proposed in the September 2013 GAO Report, "...one of CMS’s high-level modernization goals is to establish an architecture to support ‘shared services’ - IT functions that can be used by multiple organizations and facilitate data-sharing..." This effort includes a crosswalk function that could translate existing SSNs on claims to the new MBIs and vice-versa. The transition from the SSN to the new MBI would be much more efficient by receiving information on CMS’s modernized system with the new MBI, rather than by processing the information into the modernized system with the SSN and then making the transition.

Is it an impossible dream that the common-sense state and federal regulations already prohibiting SSNs from being used as patient identifiers will also apply to Medicare? It remains to be seen.

With all the talk about HIPAA over the past decade, most people in the U.S. now expect their confidential health care information and records (collectively “PHI”) to be just that…confidential. We expect our providers to assure its privacy and security. But this is not always the case. Read about this incident.

In September 2008, Parkview Hospital in Ohio took custody of approximately 5,000 to 8,000 patient records pertaining to a retiring physician’s medical practice. Parkview was considering purchasing some of the physician’s practice and was assisting the retiring physician to transition her patients to new providers. By taking custody of the PHI, Parkview assumed the responsibility for the private and secure management of the retiring physician’s PHI. However, on June 4, 2009, despite having custody of the records and with knowledge that the retiring physician was not at home at the time of the incident, Parkview employees left 71 cardboard boxes of medical records on the driveway of the physician’s home, within 20 feet of the public road and a short distance away from a heavily trafficked public shopping venue. This action exposed the PHI to unauthorized access and constituted a HIPAA breach.¹

The retiring physician reported the breach to the Department of Health and Human Services (HHS), resulting in an investigation by its Office of Civil Rights (OCR). Parkview cooperated with the OCR investigation. The outcome was an $800,000 civil money sanction and a corrective action plan requiring the revision of Parkview’s policies and procedures, staff training and regular reports to OCR on compliance with the corrective action plan. The extended regulatory oversight and related costs for auditors can be a greater sanction and intrusion into daily operations than any sanction check that has to be written.

HIPAA and HITECH mandate that healthcare providers and managing healthcare entities are responsible for the privacy and security of PHI from the time it is created until the time it is securely destroyed. This includes implementing and monitoring PHI policies and procedures as well as training and monitoring staff compliance with them. Failure to do so can subject healthcare providers or entities to sanctions and regulatory oversight through corrective action plans. HIPAA regulations have been in effect since 2003. HITECH regulations, enacted in 2009, have heightened sanctions for failing to protect PHI, including added sanctions up to $1.5M per year for willful neglect levied against covered entities that can demonstrate no reasonable efforts towards HIPAA/HITECH compliance.

It’s hard to believe that breaches such as the above incident are still taking place. But the OCR confirms that it is quite busy with similar investigations. It is starting up its random audit program again in October 2014 to get the message across that HIPAA/HITECH compliance is mandatory. The message from HHS is that sanctions will increase when non-compliance is identified such as in the case cited above and those noted on its Wall of Shame at www.hhs.gov.

¹See $800,000. HIPAA Fine- Blatant Violations Continue to Occur, www.Medlaw.com, posted June 25, 2014

Data thieves are feasting at the healthcare information and data buffet. The healthcare industry needs to act quickly to manage this problem.

Last year, the healthcare industry experienced more data breaches than any other industry. There were 269 incidents reported with more than 8.8 million healthcare records compromised, equaling 43.8% of breaches reported across relevant industries, according to the Identity Theft Resource Center (ITRC). So far in 2014, ITRC found that healthcare organizations are trending even higher representing 45.8% of breaches industrywide. And these statistics are only for breaches that have been reported.

The vulnerability of healthcare information and data is increasing. The FBI warned healthcare providers that their data security systems lag behind other industry sectors. This warning asserts that the healthcare industry is not as resilient to cyber intrusions compared to the financial and retail sectors. Therefore, the possibility of increased cyber intrusions is likely.

The results of risk analyses performed across the healthcare industry, including the results of the initial Office of Civil Rights (OCR) audit program, point to a lack of investment by healthcare in privacy and data security, a lack of attention to these issues at the executive level, and a tendency to spend only minimal resources to implement HIPAA/HITECH compliance plans. As the above statistics confirm, healthcare remains not only vulnerable but a preferred target for cyber criminals.

Why are cyber criminals focused on healthcare? Quite simply, that’s where the money is. The value of medical data is proving to be far more lucrative than other types of personal data. For example, a single person’s medical identity information can fetch hundreds of dollars compared to just a dollar or two or even less for a Social Security or credit card number, according to experts. Such medical identity information can provide access to prescriptions for drugs that can be re-sold, and can cover expensive medical treatment for the wrong party.

Healthcare data breaches are not only the work of shadowy hackers working out of foreign countries. In as many cases, the breaches are the work of healthcare providers’ own employees. Failure to invest in and implement verifiable privacy and security programs within the organization itself which include meaningful and appropriate workforce training programs is costing healthcare providers millions of dollars in sanctions and corrective action settlement agreements to combat carelessness such as loss of laptop computers and other devices with unencrypted data and unauthorized snooping into or copying patient records and data. Breach reports and complaints are patient and consumer driven and can be made directly to the Department of Health and Human Services (HHS) by disgruntled individuals. Breaches can also result from criminality by an employee acting on his or her own to steal healthcare data outright for personal gain.

Also, as electronic health records systems (EHRs) become more prevalent and sophisticated, the risk of medical identity theft continues to grow. Providers are accountable for data security efforts to remain on top of current threats, identify emerging problem areas and stay ahead of the myriad of new threats. Further, HITECH has pulled Business Associates and Business Associate sub-contractors into the HIPAA/HITECH regulatory realm.

Healthcare, as an industry, has a long way to go to match their counterparts in the financial and banking sectors, which have invested heavily in data privacy and security. These industries experienced only 3.7% of data breaches and less than 1% of compromised records. Excuses are no longer being tolerated by HHS, willful neglect (failure to demonstrate any effort at HIPAA/HITECH compliance) is being sanctioned at a rate of $1.5 M per year on top of corrective action settlements, and random audits by OCR are beginning again in October of 2014. Now is the time to act.

For assistance with your HIPAA/HITECH compliance efforts, contact Jim Wynne at jwynne@meritcd.com or by phone at 610-225-0193.

The difference in project plan outcomes with and without a good communication plan is a real eye-opener for managers. When well-executed, the workflow of a project can advance seamlessly among stakeholders and break down departmental communication silos. Managing project stakeholders is critical to the success of every project. The first step to developing an efficient and effective communications plan is to assess the individuals on the team to determine who are the most essential team members for the project.

Building the Grid

Throughout their training and certification, project managers learn about the communication plan process and the role it plays in effective project management. Without a plan, communications can be disjointed and fractured, creating the potential for conflict and miscommunication. Because stakeholders often consist of contributors from different disciplines and functions, managers should conduct a thorough analysis of their team to determine the right talent for each aspect of the communication plan.

One technique is to build a plotted grid that conveys each stakeholder’s relationship to the project. Doing so facilitates the categorization of individual employees, determining where his or her efforts will be most effective for the project. In the grid, the X axis identifies the level of interest, or how much the stakeholder will be affected by the outcome, and the Y axis signifies influence, or how much he or she can impact the finished project. Each quadrant, measured from low to high, would help measure the specific value of each project team member and develop the framework for the communication plan. Using the grid, leaders measure how much members of a team will contribute to the success of the project. Employees with high levels of interest and power would be more effective than members with lower levels of these attributes, while those with mixed levels can still positively influence the assignment. From there, managers must decide who will be included in the project.

Managing Stakeholder Expectations

Stakeholders can vary in terms of influence and interests. While the team assignment itself could drive completion, many factors can impact the project's success. Several warning signs can point to project management trouble, such as missed deadlines and conflicts among stakeholders. To combat these challenges and break down communication silos, project managers must actively follow their communication plans to the end. It is the only way to keep stakeholders in check and ensure that the project's needs are met in an efficient manner. Regular meetings - both virtual and in-person - can keep everyone up to speed on progress and serve to better manage stakeholders' expectations.

Learning from Experienced Professionals

At Merit Career Development, courses are customized to provide flexibility and meet an organization’s needs. In its experience running effective project management training, Merit has found that many managers were not creating a communication plan, endangering the success of their projects. To illustrate the impact ineffective communication plans can make, Merit had managers run a simulation of a stakeholders meeting without a communication strategy in place. The inefficiencies of this non-strategy were apparent from the start. Merit then had the managers run through the same scenario with a communication plan in place. The differences were dramatic. There was a marked improvement in performance as managers realized the indispensable benefits of effectual planning and were able to better coordinate efforts among the team. Teaching project managers the essentials of developing effective communications plans has become an important component of Merit’s project management training. Merit actively looks to turn on the light bulb for project managers so that the value of efficient communication is crystal clear for them. The solution lies in getting the participants to struggle in the first hour of training in order to understand the benefits of the second hour and the importance of a plan. This can help save time and reduce errors, repetition and confusion among stakeholders and lead to better financial gains for the business. To learn more, review Merit’s course list or contact Merit today.

Although the wrong frame in the wrong situation can lead to bad decisions, using the right frame can be beneficial in closing sales with prospective customers.

In her seminal 1996 book, “The Power of Framing: Creating the Language of Leadership,” Gail Fairhurst, Ph.D., explains that when we communicate through framing, we shape the reality of a situation. Our past experiences and perspective create a frame through which we perceive the world and which guide our decision-making. However, the wrong frame in the wrong situation can lead to bad decisions. As Fairhurst explains, through effective framing and use of language, we can become better leaders because we are relating to our followers better and, therefore, being more persuasive.

When it comes to selling products and services to prospective customers, frames can interfere with making the sale. But they can also have a positive effect when used appropriately.

Framing for Positive Outcomes

During the sales process, associates need to be cognizant of the potential buyer’s own frame and how it affects how he or she makes purchases. Many buyers may be hesitant to commit, and these objections can result in failures and frustrations. To navigate the buyer’s hesitations, salespeople need to frame their interactions—drawing on the customer’s wants and needs—to make the customer care about what they’re selling.

Appealing to emotions is essential to the sales process, the buyer should feel good about his or her decision to purchase the product. The salesperson should focus on putting positive twists on perceived negatives, as they can affect how customers react to a sales pitch.

“The Framing of Decisions and the Psychology of Choice,” written by Daniel Kahneman and Amos Tversky and published by the American Association for the Advancement of Science, touched upon the psychological principles of framing. The authors’ posit that people are more influenced by the pain of loss rather than the rewards of gain and will take greater risks to avoid loss than to see potential gain. By framing a pitch around eliminating the threat of loss, salespeople have a greater chance at success.

An effective framing sales pitch puts an emphasis on the outcome, showing prospective clients that they will experience a positive change from purchasing the salesperson’s product or service. While framing can be problematic when used inappropriately, with professional coaching it can be leveraged during the sales call. Creating context for the potential buyer can be the difference between losing or closing the deal.

May 2014

The Department of Health and Human Services (HHS) entered into settlements totaling $4.8 million with New York-Presbyterian Hospital (NYP) and Columbia University Medical Center (CU) for failing to implement appropriate administrative and technical safeguards to secure the ePHI of approximately 6,800 patients^[i]. This is HHS’ highest financial sanction issued to date as a part of breach settlement agreements, confirming its commitment to enforce HIPAA compliance.

Breach Report, Investigation and Findings

NYP and CU received a complaint from an individual who found confidential health information (ePHI) including status, vital signs, medications, and laboratory results of a deceased relative, a former NYP patient, on the Internet. The HIPAA regulations require such ePHI be maintained in secure systems and kept confidential. In accordance with HIPAA requirements, they submitted a joint report of the complaint to HHS dated September 27, 2010 resulting in an investigation by HHS’ Office of Civil Rights (OCR).

OCR’s investigation found that NYP and CU have a joint healthcare services arrangement wherein CU faculty members work as attending physicians at NYP. To support the services, NYP and CU operate a shared data network including firewalls administered by employees of both entities with shared links to NYP patient information systems.

OCR identified the breach to have occurred when a CU physician employed to develop applications for both entities attempted to de-activate a networked server containing NYP patient ePHI. Due to a lack of technical safeguards in place on the network, the de-activation attempt resulted in NYP ePHI becoming accessible to internet search engines.

OCR found that neither NYP nor CU could demonstrate that its servers were secure or contained software protections prior to the breach. OCR found an additional lack of administrative safeguards, specifically that neither entity had conducted a risk analysis to identify all systems with access to NYP’s ePHI or had a risk management plan in place to address potential hazards or threats to the security of its ePHI.

Finally, OCR found that NYP failed to implement its own technical safeguards including procedures for authorizing access to its databases and information access management processes. In addition to the financial sanctions, NYP and CU agreed to a corrective action plan requiring implementation of the administrative and technical safeguards and to monitor compliance with regular reports back to HHS.

Increased HHS Enforcement of HIPAA Compliance

This action gives notice to Covered Entities and Business Associates that HHS has heightened its enforcement efforts since the enactment of HITECH and the HIPAA Omnibus Rule.

It is imperative that a healthcare organization ensure that its workforce understands the privacy and security regulations, not just completes rote training programs, and recognizes the impact that non-compliance - from even one employee - can have on an organization.

The mandated HIPAA safeguards must be in place to identify risks and threats to ePHI and patient information systems, including insider threats from its own workforce. The safeguards must be regularly monitored through risk analysis as a part of a comprehensive risk management program.

[i] See http://www.hhs.gov/news/press/2014pres/05/20140507b.html

In this era of HIPAA enforcement, it is important to understand the fundamental role of the privacy regulations. Privacy outlines the big picture for compliance. Failing to understand and implement privacy's administrative, technical and physcial safeguards can be a costly miscalculation.

Privacy regulations have been in effect since 2003 and are updated regularly on the Department of Health and Human Services’ (HHS) website.

These regulations list compliance requirements for protected health information (PHI) in all formats (oral, paper or electronic). Security regulations are a subset of privacy limited to PHI in electronic format (ePHI). Privacy encompasses the big picture for compliant access, use, and disclosure of all PHI, including ePHI. Investing the staff, resources and time necessary to meaningfully implement privacy regulations is the entrée to compliance and a prudent business decision.

Prior to 2009, regulated organizations were primarily self-monitoring. The lack of outside accountability precipitated the major investment of staff and resources allocated for HIPAA compliance being directed towards building and supporting electronic health records systems. Fewer resources were dedicated to the less concrete, yet more comprehensive, role of privacy. Responsibility for patients’ and clients’ rights; uses and disclosures of PHI; role-based access issues; business associates; and other privacy issues were disbursed over many departments. This resulted in insufficient compliance, lax oversight and a high occurrence of violations.

HITECH’s enactment in 2009 refocused HIPAA enforcement on the privacy regulations.

HITECH mandates the implementation of complaint and breach report procedures, requires accountability for management of PHI, establishes higher sanctions for violations including a new category for willful neglect, and initiated a random audit program for an expanded list of regulated organizations by HHS’ Office of Civil Rights (OCR).

More federal and state regulatory agencies, including FTC and states’ attorney generals, now coordinate with HHS’ enforcement actions. Their websites regularly post results of enforcement actions as notice and guidance for regulated organizations. Most violations settle with corrective action plans (CAPs); some include fines tipping millions of dollars.

Many CAPs require hiring auditors to monitor and report to HHS on CAP compliance, particularly revising policies and procedures and workforce training programs (basic privacy administrative safeguards) over a period of years. As the following three cases from HHS’ website confirm, HHS is serious about privacy compliance.

Continue reading "HIPAA Privacy and Security, Perfect Together"

Managing risk to confidential patient health information (PHI) is not only a critical component of healthcare today; it is also a mandate of the HIPAA Omnibus Rule (HIPAA).

HIPAA mandates that organizations conduct a regular risk analysis to identify and mitigate risks to patient records and the PHI they manage in their electronic health records systems (EHRs). Failure to secure PHI and mitigate the threats and vulnerabilities identified in a risk analysis can result in investigations by the Department of Health and Human Services (HHS) and other federal and state regulatory agencies. These agencies have authority to impose millions of dollars in penalties and fines as well as extended regulatory oversight, and can do so simultaneously for the same offense.

The Situation

According to the HIPAA Omnibus Rule (HIPAA Omnibus Rule)¹, Failing to protect patient records and prevent disclosure of PHI can damage patients’ financial status, job prospects, and reputation, far exceeding the impact of their medical conditions.

The HIPAA Omnibus Rule requires Covered Entities and Business Associates to conduct regular risk analyses² to identify and address threats and vulnerabilities to the confidentiality, integrity and availability of patient records and the PHI they manage and maintain in electronic health information systems.

Millions of dollars in penalties and fines as well as extended regulatory oversight can result from these failures, levied after investigations by the Department of Health and Human Services (HHS) and other federal and state regulatory agencies.

Nearly 30 million patient records have been reported to HHS as compromised in breaches since 2009, according to surveys conducted by healthcare IT security consultants as recently as February 2014[3]. The report states that “(i)n 2013 alone, 199 incidents of breaches of PHI were reported to HHS impacting over 7 million patient records, a 138% increase over 2012.” These statistics do not include breaches that have not been reported to HHS.

Furthermore, HIPAA requires notification of HHS and the patients whose PHI has been breached. Such notification can negatively impact patients’ confidence in as well as the reputation of the service provider. The flip side is that patients build trust in and strengthen their loyalty for their healthcare providers when their PHI is securely managed. A reputation for private and secure management of health information can also serve as a marketing tool for the provider.

In the early roll-out of HIPAA, HHS’ history of lax oversight and few consequences for non-compliance resulted in minimal implementation of the privacy and security standards. Covered Entities lacked comprehensive compliance planning, allocating responsibility over multiple departments to provide workforce training and accountability programs and taking the position that electronic health records systems (EHRs) successfully producing electronic records and bills was sufficient to demonstrate HIPAA and HITECH compliance.

Meanwhile, reports of patient complaints and breaches poured into HHS by the millions. Eighty-three per cent of all large HIPAA privacy and security breaches are the result of theft, according to surveys from HHS sources reported by Healthcare IT News. More specifically, the surveys report that approximately 22% of breaches since 2009 were due to unauthorized access to PHI, 35% were attributed to theft or loss of unencrypted devices containing PHI, and 6% were due to hacking¹.

The results of HITECH’s pilot audit program demonstrated that covered entities lacked understanding of the actual privacy and security standards as well as grounding in the specific implementation requirements the standards impose on internal systems, operations and resources necessary to meet HIPAA compliance requirements.

The HIPAA Omnibus Rule amendments confirm that anything short of a comprehensive, documented and implemented risk management process will not meet HIPAA compliance requirements today. It also requires that risk management program incorporate the results of a comprehensive complaint and breach investigation procedure focused on identifying and addressing workforce errors and patient complaints within the organization. Finally, the HIPAA Omnibus Rule extends these compliance requirements to Business Associates performing services or functions for or on behalf of covered entities.

The Solution

Risk management begins with an organization-wide risk analysis- i.e. an accurate and thorough assessment and mapping out of actual use and disclosure procedures in place for PHI in all formats throughout the whole organization. This includes satellite and multi-state offices, subsidiaries, patient portals, remote access to its PHI/ePHI, and PHI/ePHI disclosed to its Business Associates.

A key component of the assessment involves identifying and planning for mitigation of reasonably anticipated human, natural and environmental threats and vulnerabilities to the organization’s internal and external processes and systems. To be most effective, a risk analysis should be conducted regularly and at key intervals when changes, upgrades and/or mergers take place. The findings from the risk analysis should be incorporated into a document comprehensive and regularly updated risk management strategy for the organization. This documentation is what the OCR will likely request during investigations or audits to evaluate the organization’s compliance efforts.

The next round of OCR audits is scheduled to begin in October 2014. Covered Entities’ and Business Associates’ compliance with the HIPAA security standard’s risk analysis and risk management standard is in the OCR’s cross hairs. Failure to take affirmative steps towards compliance before the OCR comes a’knocking can add additional sanctions for willful neglect to corrective action plans and/or settlement agreements.

Whether the OCR is knocking on your door or not, the private and secure management of the Covered Entity’s or Business Associate’s health information is a critical aspect of quality healthcare services today. Leaders in the industry have this as a critical core value for their organizations, making compliance with the HIPAA Omnibus Rule just par for the course. The availability of secure and reliable healthcare information and data to support quality treatment and services requires the practice of good IT governance and due diligence². Continue reading "Risk Analysis: Prepare Now or Pay Later"

The HITECH law puts a cap on fines that the Department of Health and Human Services (HHS) can assess for HIPAA violations at $1.5 million per incident per year. However, other federal, state and regional regulatory agencies have authority to impose fines for violations of the HIPAA privacy and security standards, and can do so simultaneously for the same offense.

Health insurer, Triple-S Management Corporation (Triple S) of San Juan, was recently fined $6.8 million by the Puerto Rico Health Insurance Administration (PRHIA) for improperly handling protected health information (PHI) of 13,336 of its beneficiaries who were dual-eligible for Medicare and Medicaid. Accreditation requirements to sell insurance in Puerto Rico required Triple S to sign a contract agreeing to maintain compliance with HIPAA or face fines and additional sanctions for violations.

The breach resulted from a September 20, 2013 incident where Triple S mailed out pamphlets to its beneficiaries with their Medicare numbers visible from the outside. Medicare numbers are unique client identifiers deemed PHI when held by or on behalf of a HIPAA covered entity. As a result of the HIPAA violations, the PRHIA assessed a $6.8 million fine and called for Triple-S to suspend dual-eligibility enrollment, notify affected individuals of their right to end their enrollment, and implement a corrective action plan to prevent future breaches.

Cooperation is Key

In this case, the fine was assessed at $500 for each of Triple S’ 13,336 affected beneficiaries in accordance with the contract Triple S signed with PRHIA. An additional $100,000 was assessed for its failure to cooperate with PRHIA’s investigation into the incident, providing misleading information, and, in response to some requests, not supplying any information to PRHIA at all, as reported by 4Medapproved HIT Security in HIPAA Enforcement Blind Spots (March 3, 2014).

The fines levied against Triple-S put Covered Entities and Business Associates on notice about their absolute obligation of full compliance with HIPAA and implementing proper procedures for reporting and investigating breaches. This is an essential part of HIPAA compliance planning. Further, Covered Entities and Business Associates need to be aware of the concurrent authority of the Federal Trade Commission (FTC) to address HIPAA violations. The FTC can exercise regulatory oversight through corrective action plans for up to 20 years for HIPAA violations. Complying with HIPAA privacy and security standards is the right thing to do for your healthcare practice and/or business—but most important, for your patients and clients.

Current, practical business ideas

At Merit, we read a lot. From current thought leaders, to the latest research on critical management skills and adult learning theory. The concepts in these books inform our professional education programs and have often helped drive our own business growth. How we'd like to share them with you by giving a book away each month.

For this month's book, Merit recommends Decisive: How to Make Better Decisions in Life and Work.

Following their best sellers, Switch: How to Change Things When Change Is Hard and Made to Stick: Why Some Ideas Survive and Others Die, authors Chip Heath and Dan Heath explore why so many of us make poor quality decisions. This very readable book shares the latest research on decision-making, and examines both corporate and personal case studies on how we can improve our decision-making by following the authors' four step WRAP model.

The deadline for entries is March 14, 2014.