Recent Staff Departures
I wanted to make sure you were all aware of the causes of the recent personnel changes to help mitigate the gossip and assumptions surrounding the departures.
Our HIPAA/Privacy policy is on HERDTHAT and Traci will be pushing it out on Relias for everyone to review. We take HIPAA/patient privacy policies very seriously at the GSCC because our patients trust us to do so, it is a federal requirement, and the GSCC can be fined heavily for instances of HIPAA/privacy breeches.
Please remember that you should NEVER be in a family member’s chart if it doesn’t pertain to your assigned responsibilities and your specific role within your team. It is best practice that if you must interact with a family member while performing your duties, either from a clinical standpoint or billing/payments standpoint, that you ask someone else to perform the function when possible, so as to best protect the patient’s privacy.
If the you are listed on the patient’s PHI, that DOES NOT give you permission to access a family member’s records. You must follow proper procedures as would any other patient/family member who would need to find out about test results, etc.; ideally calling the patient’s care team to discuss. As a reminder, please do not use email or TEAMS to share patient information.
To get us all on the same page and reduce the potential fear of termination due to a possible violation, please self-disclose any actions that you may have taken before 01.20.23 with regard to patient records to your supervisor so that we can clear the slate and move forward. If you will come clean immediately on any situations where you have accessed a family member’s chart, there will be no termination for self-disclosing the instances. Following your disclosure to your supervisor, they will share these with Kim Spandle, RN Chief Compliance Officer, so that she can compare them to future HIPAA audits so that they not be counted against you as cause for termination.
Moving forward, please make sure you are super clear regarding potential consequences for intentional HIPAA/privacy breeches. We understand that accidents can and do happen within the EHR and although these are not good, they are not cause for termination. However, willful disregard for GSCC policy, including HIPAA/privacy policies and/or failure to self-disclose are serious and can be cause for immediate termination so, take the time to ensure you fully understand the consequences of your actions moving forward.
If there is a justifiable need to be in a family member’s chart (and sometimes there is depending on the situation) or if there is an accidental exposure to a family member’s chart, you need to let your supervisor know immediately. These are allowable as long as they are well-intentioned and self-disclosed. Upon notification, your supervisor will share the information with the Compliance Department so that they can keep record that it was a access performed within the bounds of your position and responsibilities and clear it from future audit findings.
In summary, please take care to not unnecessarily access patient health information or areas within the EHR that are not critical to your specific role within the GSCC. It is best practice to ask someone else to perform the duties needed if the patient is a family member. Finally, immediately self-disclose to your supervisor any times that you have to access a family member’s chart within the responsibilities of your position so that it doesn’t negatively affect you moving forward.
Additionally, Amber’s departure was due to the decision to combine the Care Team Director and Care Manager Roles into one to improve continuity of care and better coordination of treatment within the provider pods in preparation for the Pilot Program to roll out to all centers and all pods. Each Care Team Director will be responsible for their assigned provider’s Care Management including Medicare’s Annual Wellness Visits (which is what Amber was assigned to do).