In my last blog article, I discussed the changes that the Omnibus Rule creates. These changes, and future changes for that matter, mean that we need to provide training to our workforce so they know how they and their jobs are affected. Section 164.530 addresses training.
The government mandates that new workforce members be provided training within a reasonable amount of time, but there is no specified definition for what is “reasonable.” At NEMT, we have made the decision that everyone goes through their HIPAA training before they start their actual job duties. Our goal is to have a culture of compliance and awareness for security and privacy.
We also need to provide HIPAA-related information and training when there is a change to a workforce member’s duties. For example, if you have team members who are currently working in the release of information department and it is a new area for them, they will need to be provided training in this particular area of HIPAA. An easy way to accomplish this goal is by classifying each position with what HIPAA training is needed for that position (a topic I spoke about previously). Updated information should also be provided when there is a change to a regulation.
You can sign up on the government website to receive updates and information that can be shared with your team.
All of these actions need to be documented since performing them is required by law. In your policies and procedures you should have a clearly defined plan for your education program(s) and how you will train your staff. I recommend that you have the team members sign a form when they go through training.
You can also make HIPAA fun by adding it to your staff newsletters. Creating quizzes and puzzles that can be turned in for small prizes will spark interest and get your team members engaged in the process.
Additionally, you could create a HIPAA newsletter that you send out quarterly that contains issues you want to remind your workforce of. Including any recent regulation changes is another good way of having both training and documentation of your training.
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