Confidentiality, Privacy and Security

COVID VACCINATION LISTS - HIPAA

  • 1.  COVID VACCINATION LISTS - HIPAA

    Posted 16 days ago
    So there is a lot of discussion regarding whether or not employees receiving a covid vaccine is covered under HIPAA.  Are we the care provider or an employer?

    We are not documenting the administration in our EMR.
    We are not submitting a claim to the insurance company
    We are not sharing this information with other covered entities or business associates
    We have employed staff administering the vaccine to their peers.

    The discussion at our facility is -  can we share lists of vaccinated staff with their managers so that we can organize administration dates and understand how many staff are left to receive the vaccine.

    Input welcome. Thank you.

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    Stacey Goodenough
    Manager of Medical Records / Privacy Officer
    Wayne Memorial Hospital
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  • 2.  RE: COVID VACCINATION LISTS - HIPAA

    Posted 16 days ago
    This is a good discussion topic.  In my opinion, the managers should receive information related to optional dates and a list of patients who have not been vaccinated.  They should only receive this as they would the flu shot clinics or TB tests.  This would be managed or maintained by the occupational health department.

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    Patricia Medrano
    Manager of Release of Information
    UCI Medical Center
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  • 3.  RE: COVID VACCINATION LISTS - HIPAA

    Posted 16 days ago
    I would think that this would be considered a public health activity.  The law is written so that information can be shared with public health, I'm not sure about a person's manager.  Would be interested in hearing others thoughts.

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    Ta-Tanisha Ingram, MSM, RHIA, CHPS





  • 4.  RE: COVID VACCINATION LISTS - HIPAA

    Posted 16 days ago
    One other curious point regarding: 'like the flu or TB shot', those are usually conditions for employment. are you considering the Covid vaccine (which hasn't been fda approved) to be mandatory? Not a breaker, but a point to consider.

    Other points to consider in my 2c: I don't think it would be protected by HIPAA itself, as not documenting in the EMR (though I'd ask why not, if the coworker is also a patient as this is also a relatively new treatment that can have other health impacts) or electronically transmitting but state and other laws may interfere. I do still think the general philosophy of min necessary is applicable. In which case does a manager need to know? Are you prepared for the results of that knowledge to be shared? Is there an option for deidentified data to be just as useful?

    Honestly, I think I'm leaning toward 'yes to should share', though, that is more gut feeling, that I can't really back up, as I don't think anything should change as of now if they did know. Actually, thinking this through more deeply, I'm more inclined to share with employee health, and EMR, but not the manager in most cases (possibly patient facing ones, that aren't remote being an exception). There isn't really a benefit to sharing from an orgazational level (and is a record if things come up which makes the honor system more worthwhile i think). De-identified info (like x of x in your dept, or section) if large enough maybe should suffice. A positive test result for covid I think is different as that does have a potential effect on other coworkers.

    You also asked 'can', and for that, I think the answer may be more 'yes', but not strong enough to back it.

    Sorry for the bit of rambling, but I also am always hoping my thought process will help others in some way. Just my 2c

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    Cody Todd , RHIT
    Health Info Svc Specialist
    Mercy Hospital
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  • 5.  RE: COVID VACCINATION LISTS - HIPAA

    Posted 11 days ago
    In my opinion, if the COVID vaccine isn't required for employment then there is no reason to share that information with anyone.  TB tests and flu vaccines are required.

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    DeAnn Tucker MHA, RHIA, CHPS, CCS
    Senior Manager | Coker Group
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