If not, you need to know what protected health information (PHI) they are looking at and make sure they have a legitimate need.
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Failure to make sure your employees know not to access PHI without a legitimate business need can be costly.
Michigan Medicine notified 269 patients that a new employee accessed patient records without a legitimate need.
The investigation showed the employee looked at demographic and clinical information, out of curiosity. The information was not used or disclosed for any other reason.
While this might seem like a ‘smaller’ breach than many in the headlines, it still managed to make the headlines.
This type of internal PHI breach can impact a healthcare facility, because they can lose patients, their public trust is damaged, and they may open themselves up to further government audits, reporting requirements, or even fines.
How can you protect your practice from snooping employees?
Make sure your employees are trained on minimal use in regards to PHI. Also, make sure your employees know what constitutes PHI. PHI is very broad and can encompass a lot more than employees may think.
Have open and frequent discussions and trainings regarding PHI, HIPAA, and their obligations. Let them know that personal sanctions can be in place for their improper actions.
Next, make sure you know where employees are accessing PHI from. Do you have an inventory of devices? Is it up to date? Can employees access PHI remotely?
Finally, make sure your employees have a way to anonymously report any of their concerns. Often, staff knows about ongoing issues well before the doctors in the practice do. If they have a way to report, and know that they will be heard, they are often more inclined to report suspicious behavior.
We help our clients train their employees and let employees know their concerns will be taken seriously. If you need help training your employees, contact Rickard & Associates today.
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Do you need help with updating your Business Associate Agreement or negotiating contracts with third-party vendors? We can help. To contact us about your Business Associate Agreement, your vendor contracts or your other legal needs, contact Rickard & Associates today.
