Confidentiality, Privacy and Security

Employees COVID positive

  • 1.  Employees COVID positive

    Posted 04-01-2020 18:08
    Interested in the process you are following to alert staff of other staff members that test positive for covid (due to being exposed to a patient at your facility).

    Are you seeking permission to use the staff member's name or are you just stating that there has been exposure to someone?

    Is your privacy officer involved in that notification?

    Are you concerned if someone other than the privacy officer is handling the alert that they are not adhering to the minimum necessary?

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    Deanna Heinrich
    Director of HIM/Privacy Officer
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  • 2.  RE: Employees COVID positive

    Posted 04-02-2020 09:46
    We had a similar discussion earlier in the week.  Our infection control nurses have handled exposure notification internally for years.   They have this experience and really it is not a different process other than this is a much more high profile condition.   We decided that they were best able to manage this both from experience and having the clinical background to address questions.  We asked them, however, to please advise the employee that this exposure and the patient information is covered by HIPAA and our privacy policies and there should be no further discussion of the notification.

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    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
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  • 3.  RE: Employees COVID positive

    Posted 04-10-2020 13:31
    Have you used a specific education tool to remind staff that COVID-19 is protected?  As the numbers have increased, I'd like to remind staff of not sharing these results or exposures.  If you have a message, please share.

    thank you,
    Pat

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    Patricia Medrano
    Privacy & Compliance Coordinator
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  • 4.  RE: Employees COVID positive

    Posted 04-13-2020 10:14
    We sent this out to all staff:


    Privacy Reminder – Safeguarding the Privacy of DCMC Patient Information During the Covid19/ Coronavirus Pandemic

     

    Attention All XXXX Staff Members:

     

    XXXX is committed to keeping our patients first in everything we do – including safeguarding the privacy and security of their confidential health information.  With the current situation of managing Covid 19 (Coronavirus), DCMC is actively testing and will be caring for patients with this disease.  As we treat these individuals, we want to take this opportunity to remind staff of their responsibility to only access that patient health information that is required for carrying out assigned job duties.  As we prepare to care for patients with this disease, please remember the following basic privacy and security guidelines for safeguarding patient information – whether on-site or working from home:

     

     

    • Access only the patient health information/health information you need to meet your assigned job responsibilities.

     

    • Be aware that routine EHR access audits will be carried out to identify any unauthorized access, use, or disclosure of patient health information; follow up action will be taken for violation of policy (and HIPAA).

     

    • Remember that verbal patient information is confidential too. Do not discuss the status of patients unless the discussions are necessary to carry out patient care.

     

    • Determine if the patient has elected to be listed as part of the XXXX public facility directory which allows for basic information to be shared about the patient's condition. If the patient has chosen to opt-out of the facility directory, then no information will be shared with callers, visitors, family members, etc. Note:  This is usually determined during the registration process.

     

    • Determine if the patient wants his or her health information shared with family members or friends involved in his or her care.

     

    • Refer all external patient information inquiries from the media, law enforcement, or other external agencies to Administration or their designees: Media – XXXXX; Law Enforcement – XXXXX; Public Health – XXXXX

     

    • As always, DO NOT access personal, family, or friends' health information through XXXX or any other application. This is a HIPAA a XXXXX Policy Violation!   Failure to follow this directive WILL result in corrective action.   Curiosity can kill more than the cat – it can kill the career.

     

    • Utilize the XXXX patient portal for your access to personal health information.

     

    Thank you for your commitment to putting our patients first in everything we do and ensuring that their confidential health information remains secure.



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    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
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  • 5.  RE: Employees COVID positive

    Posted 04-13-2020 10:51
    Thank you!  With so much information, I forgot this tool shared earlier.


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    Patricia Medrano
    Privacy & Compliance Coordinator
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  • 6.  RE: Employees COVID positive

    Posted 04-13-2020 11:37
    This is what we sent to staff...used Nancy's as a template.  Tried to make is short and to the point so staff would read.

    REMINDERS FOR PROTECTED HEALTH INFORMATION
    Gundersen is committed to protecting our patients first, in everything we do, including safeguarding the privacy and security of their confidential health information. As we test and care for patients with COVID-19, we want to remind all staff of their responsibility to only access protected health information (PHI) that is required for job-related reasons. 

    • Access and disclose only the PHI necessary to meet your assigned job responsibilities.
    • If you are no longer providing care to a patient, you may not go back and check their lab test results or access their medical record. Employee Health Services will be notified by Infection Control if there is a patient who tests positive. At that time, Employee Health Services will follow-up with employees involved in the patient's care.
    • If you are aware of an employee/colleague that comes in for COVID testing, remember they are now patients and we need to respect their privacy. It is not our role to disclose this information to Employee Health Services, but instead we should be encouraging all patients to notify their employer of their symptoms and that they have been tested.

    Thank you for your commitment to putting our patients first in everything we do and ensuring that their confidential health information remains private and secured.



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    REBECCA KILEN, MS, RHIA, CHPS
    Privacy Officer
    Gundersen Health System
    rakilen@gundersenhealth.org
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  • 7.  RE: Employees COVID positive

    Posted 04-13-2020 11:45
    Thank you for sharing your condensed version as well as Nancy's original version. I am looking for little blurbs to share with staff to help them keep privacy on their minds during these scary times. I don't want anyone to panic and get themselves in trouble because they weren't thinking. There have been lots of rumors around our organization about the "relaxing" of HIPAA so I have been trying to counter balance the misinformation.

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    Kathryn Wood, RHIA
    Assist Dir of Information Systems/Privacy Officer
    War Memorial Hospital
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  • 8.  RE: Employees COVID positive

    Posted 04-13-2020 12:01
    Thank you for this brief information.  I think this would be great to add in our newsletter!

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    Patricia Medrano
    Privacy & Compliance Coordinator
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  • 9.  RE: Employees COVID positive

    Posted 04-15-2020 21:15
    Edited by Regina Cantrell 04-16-2020 12:49
    I've had this same question come up at my place of employment. If an employee was tested for the COVID-19 whether it came back positive or negative would co-workers be told? Due to it being a HIPAA issue, I don't think they would tell the rest of the staff until it was positive?   Is there some state status or federal regulations stating they have to disclose a clear answer. Yes, its positive or No it is negative? Isn't it an infection control issue they have to disclose. Would the federal regulation 164.512 (b)(1) (i -v ) cover it?

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    Regina Cantrell, RHIT
    Health Information Manager
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  • 10.  RE: Employees COVID positive

    Posted 29 days ago
    Managing disclosures of COVID-19 is not any different than HIV status either workforce members or patients. Just my .02.

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    Carlyn Doyle
    Compliance Engineer
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