Traci,
I'm sorry I've taken so long to reply.
You have raised a number of good points and perhaps in my response(s) I lost
sight of the fact that the issue we are discussing has morphed slightly.
We started out by talking about Medicaid audits, or audits by payers, and the
need for BA Agreemen
Had a
question about BAs? If we contract with Therapy Provider company to provide OT,
ST and PT services,
will
that company be our BA? How about the individuals from these companies who come
and render the service?
Do
they need to sign a Confidentiality Agreement?
Regards,
Vikas
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The W
Does it really matter which titled staff member provides the training?
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HIPAA covers every employee who has access to Protected Health Information, whether
temporary or permanent.
Given that civil liabilities could be huge, potential plaintiffs would undoubtedly
name the employee, the agency and the CE as co-defendants.
On the most base level, I can't think of a s
I think you would
have to train a temporary workforce member just as you would a workforce
member that was not temporary. My understanding is you don't train
on the privacy rule itself, you train on what procedures/policies that all
employees need to know about your privacy procedures, tha
Are there any covered entities out there that include a component that
provides for the licensing and certification of facilities and that
addresses long term care program complaints? Our Medicaid agency surveys
hospitals, long-term care, etc. facilities for Medicare/Medicaid
certification and some
We are viewing temp. employees as workforce
members, we will have them sign an Employee Confidentiality Agreement
as well as give them a HIPAA Basic Education Handbook, which they read, take a
test, and sign.
Debbie Kerns
HIPAA Compliance Officer
Steele Memorial Hospital
***
Valerie,
To the extent that the temporary employee
uses and discloses PHI, (s)he would need to be treated as any other workforce
member for the purposes of providing awareness training, mitigation of harm for
breaches, etc.
I hope that this helps.
Your questions are always wel
I have
heard CE's respond both ways. I would like to get an idea of what the majority
of people are doing. And are you treating temp agencies that supply office staff
differently than temp agencies who supply nursing staff?
Thank
you!
Deborah Campbell
Compliance Coordinator
Dominion Dent
Had a question come up today regarding temporary employees. If we have
a temp for a couple of weeks, is that person considered a member of our
workforce and are we required to train that person on HIPAA Privacy? Thanks for your input!
Valerie Hromatka
System
Administrator
Privacy Of
Title: RE: Recording Disclosures (was BA Agreement Questions)
I also agree with Carolyn.
An external Auditor would be a BA if (and only if) YOU hired
the firm to perform audits for YOUR business purposes, and the auditor had to
access to PHI in order to perform the audits.
Government overs
Title: RE: Recording Disclosures (was BA Agreement Questions)
I've
got to agree with Carolyn. These audits are done as required by law, or for
Health Oversight. Not on behalf of the health plan.
Deborah Campbell
Compliance Coordinator
Dominion Dental Services,
Inc. 115 South Union
Stree
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