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Privacy Awareness in Healthcare Training: Dental Practices

Posted on June 15, 2020 by Meghan in Blog, Services

NEW! Privacy Awareness in Healthcare Training – Dental Practices

Privacy Awareness Training for Dental Practices

Is your dental clinic in compliance with the Alberta Dental Association & College, Health Information Act (HIA) and Personal Information Protection Act (PIPA)?

Dentists and dental practices in Alberta are required to have an ongoing privacy program to ensure the protection of private records and patient information. The appropriate collection, use, and disclosure of personal information is critical to maintaining privacy for patients that choose to trust in your practice. Accomplishing this important goal demands an up-to-date training strategy.

Regular privacy awareness training protects patients, employees and your business. The key components of your training strategy must revolve around ensuring HIA compliance to mitigate risk of a privacy breach. Everyone in your clinic – dentists, dental assistants, dental hygienists, office staff, contractors and even practicum students and volunteers must understand how to correctly handle personal information, so it remains confidential and secure. Maintaining high standards that safeguard information privacy and security is an essential aspect of asset management for any health care provider.

Corridor Interactive's training includes a personalized printable certificate of achievement to support compliance and may be used for your continuing education credits, too! Our training delivers industry best practices and is ideal for all levels of staff in any dental organization or clinic that collects, uses or discloses personally identifying information. This includes direct care providers in your practice as well as privacy officers, support staff and any other employees who are not directly involved in patient care.

Corridor’s Privacy Awareness Training for Dental Practices educates dentists, dental assistants, dental hygienists, and all office staff on:

  • Understanding Privacy
  • Privacy Principles
  • Collection, Use & Disclosure
  • Roles & Responsibilities
  • Privacy Breaches
  • Right of Access
  • Safeguards
  • What is “Health Information”
  • Handling Personal Sensitive Health Information
 

If You Are A

  • dentist,
  • dental assistant,
  • dental hygienist,
  • or work in a dental practice

You Need Privacy Awareness in Healthcare Training – Dental Practices

You will 

  • Understand patient and client privacy rights.
  • Respect personal health information and your obligations.
  • Confidently and correctly handle personal health information.
  • Use reasonable safeguards to protect personal health information (PHI).
  • Recognize and respond to a privacy breach
  • Support key policies, procedures and risk management programs in your healthcare practice.

Interactive Online Learning Experience provided by Corridor Interactive

Corridor Interactive’s Buy Now Training Programs give you access to the most current information available, at your convenience. Complete your course all at once, or in multiple sessions from any location – it’s up to you. All you need is an internet connection and an email address to get started…it’s that easy!

  • Fits into your schedule – you can start, pause at anytime, and return to the course exactly where you left off.
  • Easy to use – navigation buttons makes it easy to continue to the next topic or pick and choose the order that you want to see the content.
  • Get started immediately – the entire course is ready for you!
  • Work at your own pace – you have access to the course for three (3) months. Most students complete the course in under 2 hours.
  • You can listen to the narration for each module.
  • Practical examples, too, to make it easier for you to apply what you have learned in the course to your job.
  • Links to extra resource material and websites related to your topic of study, to peruse at your convenience.
  • A printable Certificate of Completion, available as soon as you successfully complete your course.
  • An audit trail and record of your course activity and training history.
  • Self-directed learning features including the ability to pause your course at any time and resume later, right from where you left off.
  • Unlimited access to your course and resources for the duration of your subscription term.
  • Technical support with a one-business day turnaround for end-user support help and questions.
  • Automatic emails when you complete your course, or reminders if you have not completed.

Developed by Corridor’s team of seasoned software specialists and instructional designers, this unique online learning application is the optimum vehicle for delivering learning content.

$30 per subscription

Register Now

 Give your staff the knowledge and tools they need to apply policy in their day-to-day work AND prevent a privacy breach with privacy awareness training.

 

Privacy Awareness in Healthcare Training – Dental Practices

Protect your organization and your patients. Equip your staff with the information they need to confidently and correctly handle personal health information. Learn basic healthcare privacy principles and how to handle personal health information, use safeguards, and recognize and report a privacy breach.

Sounds great! Sign me up!

This self-paced on-line education includes:

  • 9 Modules
  • 6 Quizzes
  • 2 Case Studies
  • Final Exam

Certificate of Completion

“When we know better, we can we do better.”

As an employer and health care provider, you are responsible to provide training to all of your employees about privacy awareness. Protect your organization and your patients. Equip your staff with the information they need to confidently and correctly handle personal health information.

I am constructively obsessive about privacy and confidentiality in the healthcare sector–and I think you should be, too! I designed this course to assist healthcare providers, clinic managers, practice managers, privacy officers and independent healthcare practice owners provide practical privacy awareness training that was easy to implement, consistent content, cost-effective and meaningful to your day-to-day business.

When each member of your independent healthcare practice completes this privacy awareness course, you will have clearer expectations and confidence that your team will maintain the privacy, confidentiality and security of your patient’s health information. Give your patients the gift of privacy. Improve your healthcare practice with privacy awareness education.

Jean L. Eaton, Your Practical Privacy Coach Information Managers Ltd.

Frequently Asked Questions

How can I access the course?

The course, Privacy Awareness in Healthcare Training – Dental Practices  is available on-line from any internet enabled device. You can use your desktop computer, smart phone or tablet to view the slides and even hear the narration.

How long is the course?

Most students complete the course in under 3 hours. You can start and stop the course at any time. Let's say you decide to take 20 minutes each day to work on the course. You can login and start the course right away. When you come back to the course the next day, you can start right from where you left off. You will have all the modules and the post-test done within 6 days. Don't worry about missing a few days – you have access to the course for a full 3-months!

This is my first job in a dental practice. Do I know enough to start the course?

You bet! The course is easy to read and I explain all the terms that you need to know. There are a lot of practical examples, too, to make it easier for you to apply what you have learned to your job.

I've worked in healthcare for a long time. Do I still need to take this course?

You bet! Seasoned professionals like yourself have an extra obligation to share your knowledge with new workers. This course will help you to refresh key principles and suggest wording, examples, and key messages that you can use to train new employees to their specific tasks in the workplace. The course will help you to advocate for the privacy rights of your patients. Unfortunately, we have many examples where trained professionals who “should have known better” make errors in judgement causing privacy breaches that affect our patients, our business, and the reputation of healthcare. Healthcare practitioners and owners have a responsibility to ensure that everyone in the practice receive comprehensive privacy awareness training regularly.

Will I get a certificate of completion that I can give my employer?

Yes –  at the end of the course, you will have the opportunity to complete a short on-line quiz to confirm that you understand the key concepts. Then you will have access to a Certificate of Completion that you can download and share with whomever you choose.

Can I get continuing education credits with my professional association?

Maybe! If you are a member of a professional association and you would like to seek credits from for taking this course, please let us know so we can take steps to request pre-approval. Often, professional association and colleges will grant continuing education (CE) credits based on your certificate of completion.

How much is the course?

The course is $30 per individual 3 month subscription. Click here to buy it right away.

I think everyone in my healthcare practice should take this course! Can I buy in a group package?

Yes – Privacy Awareness in Healthcare Training – Dental Practices is available in group packages, or it can be customized to incorporate your organization’s privacy policy and practices. Employers can monitor the employee’s training progress and receive a report of employee’s satisfactory completion of on-line quizzes. Track annual privacy awareness training through our online platform to demonstrate your compliance with legislation. Contact Corridor Interactive for more information.

I agree that privacy awareness training is important - but I don't work in healthcare. Do you have a corporate privacy awareness program?

While these programs have been developed with health care providers in mind, the privacy principles and fundamentals of protecting personal information are appropriate for any organization that collects, uses, and discloses personally identifying information. Contact us for information about our Corporate Privacy Awareness Program!

Interested in Group Training?

Employers can also purchase training for groups of employees; employees can access the internet based training at a time and location convenient to them. Employers can monitor the employee’s training progress and receive a report of employee’s satisfactory completion of on-line quizzes. Track annual privacy awareness training through our online platform to demonstrate your compliance with legislation.

Email Corridor Interactive to Order Group Training

Corridor Interactive, dentists, health care, Health Information Act Training, healthcare, healthcare provider, primary healthcare, privacy, privacy awareness, privacy breach, training

How To Correctly Identify Patients And Use Photo ID

Posted on December 10, 2019 by Jean Eaton in Blog

Patients should be asked to show their Alberta Health Care Insurance Plan (AHCIP) card and photo identification when visiting a practitioner office.

The Importance Of Correct Patient Identification

Failure to correctly identify patients can lead to serious problems such as medication errors, as well as privacy breaches.

Positive patient identification is critical to ensure patient safety and protect patient data. According to industry research cited by RAND, 7-10% of registering patients are misidentified upon entry.

Patient mis-identification contributes to:

  • 27% of radiation errors
  • 29% of medication errors
  • 5% of wrong-patient/wrong-site surgeries
  • 850 medical errors and 20 deaths related to blood transfusions

And, of course, we must deal with the administrative headache of privacy breaches and medical identity theft and duplicate patient records!

In Canada, health ministries have underscored the importance of correct patient identification when they issue Patient Safety Alerts. Correct patient identification criteria is also included in Accreditation Canada standards.

Verifying patient information improves patient care and efficient business practices. Click to Tweet

Verifying patient information improves patient care and efficient business practices.

  • Care – Good patient care starts with correct patient identification. Incorrectly identifying patients contributes to medication, transfusion, procedure and testing, errors.
  • Good Documentation – Avoid incomplete, inaccurate, and duplicate patient records!
  • Gatekeeper –Each caregiver has the responsibility to identify the patient before providing a health service. I think that the family physician has an added role and responsibility of the patients’ gatekeeper to additional health services to ensure that the documentation of patient identification is correct at the time of registration.
  • Billing – Avoid rejected billing and re-work when you correctly identify the patient and record the data correctly the first time. Patient demographic information is best corrected while the patient is present at the clinic instead of trying to contact the patient after they leave the clinic.
  • Uninsured Services – The practitioner will submit a claim to the Alberta Health Care Insurance Plan directly for all insured services provided. If a provincial health care card is not shown or the individual is not eligible for coverage, they may be asked to pay for health services before receiving them.

How To Correctly Identify Patients

Ask The Patient Questions – When a patient presents to register for a new or repeat visit, ask for at least two sources of patient identification. You may also request new patients to complete a new patient registration form.

Ask for Photo Identification – Photo identification will validate that the information and the image of the patient in front of you corresponds to the information from the patient and AHCIP. If there is a discrepancy, the best time to sort it out is when the patient is still at the clinic.

New Patient Registration Form (optional) – A paper form allows for discretion when asking for demographic information including date of birth, address, medications, Alberta Health Care Insurance Plan, allergies, etc. This reduces overhearing the conversation from other patients and staff and can often improve workflow and reduce congestion at the reception desk.

Document – Record on the new patient registration form or the clinic note that the photo identification was reviewed and that the image matches the individual. Use a clinic note or other location in patient record that is used consistently in your healthcare practice. (Bonus Tip: You might be able to create a template clinic note in your EMR for this. Or, create a check list template of this and related tasks to be completed for each (new) patient registration.)

Enter the information into the patient demographic or EMR system. Use registration document standards to ensure consistent data entry.

Validate – the AHCIP # and the patient information is valid by using the Netcare parameter launch browser between the EMR and Netcare. This will also help to ensure that there are no data entry errors in the EMR. If necessary, assist the patient to complete a change of information form for AHCIP, or make an update entry in Patient Registry if you have appropriate access. If you don’t have access to the Netcare via browser or web sign-on, use the phone number to AHCIP for this purpose.

Don’t Photocopy The Photo Identification

You should record that you viewed the photo ID and verified, but do not record the unique number associated with the photo identification (for example, driver’s license number). Do not photocopy the photo identification.

Remember, we have a responsibility to collect the least amount of information necessary. Viewing photo id to verify the identity of the patient, is a reasonable step to ensure the safety of the patient and to prevent an error. Recording the drivers license number or photocopying the drivers license is not necessary to provide a health service and an unnecessary (and probably illegal) privacy and security breach.

Listen To The Podcast Here

Members of Practice Management Success

If you are a member of Practice Management Success, login and access the webinar replay, patient registration procedure template, collection notice template, and the new patient registration form template.

Not a member of Practice Management Success, yet? What are you waiting for?

Get Your Practice Management Success Membership Now!
#PracticeManagementNugget, AHCIP, Alberta Health Care, dentists, drivers license, healthcare, medical errors, Netcare, Patient identification, photo ID, podcast, registration, risk

Ransomware – 6 Mistakes Made By Dentists (And Their IT)

Posted on November 14, 2019 by Jean Eaton in Blog

Anne Genge of Alexio tells us that 96% of healthcare providers are concerned about how their staff are using personally identifying health information.

But, many healthcare providers and business owners don’t know what to do about it!

Can your staff protect you from a ransomware attack?

Yes, they can!

And it doesn’t have to be hard or expensive to do that.

Anne will help us to understand the cyber security risks that every healthcare practice in Canada is facing now and what you can do now to reduce your risk on Practice Management Nuggets For Your Healthcare Practice. Anne Genge, CEO of Alexio Corporation is my guest expert.

 

Anne Genge's #1 Tip to healthcare providers and practice managers

Invest in a professional cyber security risk assessment for your practice. Click to Tweet

My Favorite Takeaways From The Podcast

  • Ransomware is the biggest threat to any digital environment
  • Healthcare data is urgent – we need it to treat our patients.
  • Cyber security awareness is very low among healthcare providers.
  • Data loss often happens even when you can de-encrypt the data often resulting in 15% loss.
  • Without proper remediation, repeat ransomware attacks can happen.
  • Good backup insulate yourself from data loss, remediation costs, mandatory privacy breach reporting, loss of reputation, fines, and penalties.
  • Intrusion detection and prevention software can alert users to potential problems, but sometimes, individual users’ behaviour continues to put the practice at risk.
  • 90% -92% of successful breaches are facilitated by human error.
  • IT focus on efficient workflow and communications between systems. Security professionals monitor access to ensure it is authorized and appropriate. Both roles is necessary in our digital practices.

6 Mistakes Made By Dentists (And Their IT)

  1. Think that IT has them covered and that ransomware won't happen to me!
  2. Not updating and monitoring computer systems with intrusion prevention/detection.
  3. Don't have a comprehensive backup of all of your data in at least 3 locations.
  4. Don't run backup restore tests regularly.
  5. Don't have a written mandatory cyber security awareness training plan.
  6. Don't have an independent cyber security risk assessment and management plan annually.

Instead,

Take steps to prevent a ransomware attack – including cyber security education for your team, implement good IT systems, complete and comprehensive backup, and an annual cyber security risk assessment preventative digital IT health assessment.

Let Alexio help assess your risk, protect your practice, ensure data recovery, and train your staff.

Protect your investment today.

Get started with a quick on-line self assessment

Book a 30 minute consultation with Anne!

Follow Anne and Alexio on social media for more training and tips

InformationManagers.ca/Likes-Alexio

Anne GengeFeatured Guest: Anne Genge

Alexio Corporation

Anne Genge is a pioneer in protecting health data and those who use it. She is a Certified Information Privacy Professional with a specialization in dentistry. Anne also holds certifications for HIPAA, Credit Card Security, Internet, and Network Security. Ransomware and data theft have changed the face of dentistry in the past decade meaning dentists need a new toolkit for protecting their practices.

With over 20 years of experience, Anne knows the challenges healthcare providers face with technology. She and her team at Alexio Corporation work with dental and medical professionals to minimize data risk and maximize patient care. As healthcare grows increasingly dependent on the digital environment, cyber-security becomes increasingly more difficult. Protection of patient data is not only law, it’s imperative for business success and reputation. Anne simplifies cyber-security for dentists and other healthcare providers and gives ‘real world’ strategies to protect patient information and the practice business.

Be sure to tune in to my interview with Anne Genge,

Ransomware – 6 Deadly Mistakes Made By Dentists (And Their IT) | Episode #082

Listen To The Podcast Here
#PracticeManagementNugget, Alexio, Anne Genge, dentists, healthcare, podcast, ransomware, security risk assessment

The Top 3 Agreements Your Healthcare Practice MUST Have (and Why)

Posted on November 29, 2018 by Jean Eaton in Blog

In order to provide services, healthcare practices must collect pertinent information from patients. This data gathering often includes many sources of information, across different types of technology, among multiple vendors. Good business practices and health records management is supported by three agreements your healthcare must have: information manager agreement (IMA), information sharing agreement (ISA), and successor custodian agreement.

For instance, when a patient attends a clinic, their details are nearly always entered into a computer software program to maintain demographic information, manage patient appointments, and to process payments. Often, health service providers (including physicians, pharmacists, chiropractors, dentists, psychiatrists and more) record their patients’ notes into an electronic medical record (EMR).

Patient information is shared between providers where required. For example, when the patient visits a diagnostic lab for testing, results are often transmitted electronically to the ordering physician’s fax machine or to the EMR.

Custodians including physicians, pharmacists, chiropractors, dentists, and psychiatrists, as defined by the Alberta’s Health Information Act (HIA), must follow HIA legislation when they collect, use, and disclose health information.

Often, custodians are also the owners of independent healthcare practices. However, an owner of a healthcare practice is not the custodian if they are not also an active member of a regulated health profession named as custodians in the HIA.  

1. Information Manager Agreement

The HIA allows custodians to contract with other health service providers and vendors for the purposes of providing information management or information technology services, so patients can receive health services, and make payments. This often requires the custodian to share patient information with a vendor (or give them access to) so the vendor can process, store, or provide information as needed.

The custodian selects one or more business to provide the services, equipment, or software to assist in the management of health information. For example: EMR provider, contracted transcriptionist, billing agent, remote backup service, etc. These businesses are known in the HIA as information managers.

Before sharing health information with someone else, the custodian must ensure that the partners and vendors have reasonable safeguards in place to protect sensitive health information. The custodians must ensure that there is a written agreement between the custodian and the information manager. These agreements are known as “Information Manager Agreements.” This requirement is stated in the HIA section 66(2).

The Information Manager Agreement (IMA) is one of three crucial agreements a healthcare practice must have in place.

If You Don’t Have an IMA

If you are a custodian who uses vendors as part of your business and you do not have an IMA with that vendor…

  • You are in breach of the HIA.
  • You may incur fines under the HIA.
  • You may face sanctions and disciplinary actions from your professional regulatory college.
  • Almost certainly, you will encounter conflicts, poor communication, between yourself and the vendor(s) and the other participating custodians in your practice.
  • You may lose control of the health information as reported in the Investigation Report H2013-IR-01from the Alberta Office of the Information and Privacy Commissioner (OIPC).

In a press release from the Alberta OIPC in 2013, Information and Privacy Commissioner Jill Clayton noted that:

“The HIA allows custodians to disclose health information to IT service providers, such as EMR vendors, under an appropriate Information Manager Agreement. When custodians do not sign these agreements, they may find themselves in the unfortunate position of losing control over the health information they need to provide health services.”

Investigation Report H2013-IR-01 (https://www.oipc.ab.ca/news-and-events/news-releases/2013/investigation-report-h2013-ir-01.aspx)

Who Must Create the Information Manager Agreement?

The custodian is responsible to ensure that there is an appropriate IMA created and signed.

The information manager can assist the custodian by preparing templates of the IMA including specific details of the services that they will provide and the safeguards that the vendor will implement to protect personal health information.

Key Points About IMAs

A few important notes about IMAs.

  • IMA must be signed by the custodian.
  • Agreements signed by individuals who are not custodians are not valid under the HIA.
  • Custodians are required under the HIA to have an IMA with the vendor before disclosing health information. If there is no agreement in place, the custodian is in breach of the HIA.
  • Custodians are responsible for the health information that they collect, use, and disclose. Therefore, the custodian is responsible for the IMA and to ensure that the health information will be handled confidently and securely.

Key Points IMA

The custodian can select the best vendor and information manager for the job. The vendor who understands the requirements of the HIA and who can demonstrate that they have implemented the appropriate reasonable safeguards and can assist the custodian to develop an appropriate IMA is, in my opinion, demonstrating a significant competitive advantage.

All healthcare providers in a community practice should spend time when creating their business to establish good business practices, including developing written contracts and agreements to improve the efficiency of the business and to make things happen in the way that they are planned.

Here is a common example

Dr. Alice and Dr. Mark created a welcoming family medical practice in a new sub-division of their city. They each worked hard to attract new patients, hire and train staff, and develop a profitable business.

In the last few years, Alice and Mark had differences of opinion on how to grow their business. In the end, Alice decided that this type of practice wasn’t for her. She decided to leave and join a larger practice in a neighbouring subdivision. Alice wanted to take her patient’s records with her to her new practice and continue to see her patients at the new location.

Mark, who had signed the IMA with the EMR vendor, did not agree to Alice’s request to transfer her patient records to her new group practice.

Alice and Mark argued and eventually involved a professional mediator to help them resolve their business conflict. Hurt feelings between the providers and staff, costly delays in their business and expenses could have been avoided if Alice and Mark had established clear expectations in the event of the termination of their business partnership when they started their group practice. An IMA between custodians in a group practice is a recommended best practice.

When You Have Multiple Custodians in Your Healthcare Practice

When the practice has multiple providers, the owner and custodian frequently assumes responsibility for maintaining the contracts and IMAs with the vendors. Each of the participating healthcare providers may delegate the responsibility of maintaining the vendor arrangements to the custodian owner. This can be achieved with an IMA between the owner / custodian and each participating custodian.

Custodian Owner IMA

Each healthcare provider custodian is considered the custodian of the health information that they collect. The custodians can jointly agree to all use the same EMR. This provides continuity of care for the patients and economy of scale for the participants of the practice.

When the owner/custodian signs the agreement with the EMR, they become the signatory custodian. The EMR vendor takes their instructions from the signatory custodian.

The owner / custodian is now an information manager for all the participating custodians.  but does not become a custodian of the health information provided to them in their roles as an information manager.

For example,

Dr. Bill opened his medical practice, ABC Clinic. Later, additional physicians were recruited to work at ABC Clinic. The physicians are each custodians as defined by the HIA.

Dr. Bill assumes the responsibility for the operations of the clinic including the computer network and the contract with the EMR vendor. Dr. Bill is the information manager for the patient records at the clinic.

Each physician signs an IMA with Dr. Bill and agree that he will continue to manage the patient records on their behalf. Dr. Bill is operating as an information manager.

In his role of the information manager, Dr. Bill must follow the instructions from each physician, the custodian, as it relates to the management of their patients’ records.

2. Information Sharing Agreement (ISA)

When you have more than one physician in your practice, you need an agreement about how you will decide to manage the personal health information in your practice.

An Information Sharing Agreement (ISA) focuses on the internal decision making about all things related to personal health information whereas, an IMA is an agreement with a single vendor about the services that the vendor provides.

ISA IMA

An ISA may include things related to the services that a vendor provides but is not limited to just vendor services.

It also includes decisions about the process to ensure appropriate role based access to personal health information in the EMR, computer network, and paper formats; the regular review of health information privacy and security policies and procedures, ensuring privacy and security awareness training, the regular review of administrative, technical, and physical safeguards in the practice, and so on.

In larger organizations or when several smaller organizations participate in an information sharing initiative, a Data Management Committee may provide oversight and facilitate this process.

An ISA is a requirement of the College of Physicians and Surgeons of Alberta.

Identifying a successor custodian is also a requirement of the College of Physicians and Surgeons (CPSA).

3. Successor Custodianship Agreement

As a business owner, you need to plan a successor to the business. This might be an interim or short-term decision to ensure continuity during an absence or future retirement planning or unexpected illness or death.

In healthcare, physicians and custodians have the added responsibility as the ‘gatekeeper’ for patient records. In the event of a sudden inability to meet these responsibilities, physicians need to identify a successor custodian to ensure appropriate and continued access by patients to their health information for their continuing care and treatment and to ensure that the continuing confidentiality, security, and access to patient records continue to be fulfilled.

Have you identified a successor custodian? Each of the physicians in your group practice should also identify their own successor custodian.

This is a CPSA requirement and should also be included in the Privacy Impact Assessment if you have this information available. See CPSA, Patient Record Retention, s.5:

A regulated member acting as a custodian must designate a successor custodian to ensure the retention and accessibility of patient records in the event the regulated member is unable to continue as custodian. (Reference: Health Information Act Section 35(1)(q)

If you are a chiropractor, the Alberta College and Association of Chiropractors (ACAC) further requires its members to name a chiropractor as the successor custodian to maintain the status of ‘chiropractic’ records. (See the ACAC’s Standards of Practice s5.3 Custodianship of Health Records.)

A chiropractor, as a custodian of health records, is responsible for the care and control of the health records in their practices as required by the Health Information Act of Alberta. A custodian of active chiropractic files must be under the custody or control of an active, registered member of the ACAC.

Note that under the Health Information Act, a chiropractor may disclose files to another custodian who is not a chiropractor, and only a chiropractor may have custody or control of chiropractic files. Chiropractic files disclosed to a non-chiropractor should no longer be considered chiropractic files.

A custodian must implement technical and physical safeguards to protect the confidentiality of the information and privacy of individuals as well as protections against reasonably anticipated threats to the security or integrity of the information. A custodian must also defend against unauthorized uses, disclosures or modifications of the information. Safeguards must be periodically assessed and documented in policies and procedures.

If you are working in an owner/custodian scenario discussed above, clearly identifying a successor custodian becomes imperative. An unplanned absence of the owner / custodian can seriously jeopardize the business and the continuing care and treatment of patients.

The custodian can, but is not required to, name another custodian in the same practice to be their successor. Whatever your decision, ensure that this is well documented and easily accessible to the other custodians and key decision makers in your organization in the event of an emergency.

The best time to create IMA, ISA, and Successor Custodianship Agreements is when you start your healthcare business.

The second best time in now.

What are you waiting for?

If you need assistance, contact Jean L. Eaton, Your Practical Privacy Coach and Practice Management Mentor with Information Managers. I’m here to help you with your Practice Management Success.

Download the FREE Report - Top 3 Agreements Your Healthcare Practice MUST Have

If you are a member of Practice Management Success, login here to access the Top 3 Agreements.

When we know better, we can do better…

Jean L. Eaton is constructively obsessive about privacy, confidentiality, and security especially when it comes to the handling of personal health information. If you would like to discuss how I can help your practice, just send me an email. I am here to help you.

Jean L. Eaton
Your Practical Privacy Coach
INFORMATION MANAGERS 

chiropractors, dentists, health care, Health Information Act, healthcare, HIA, IMA, information management agreement, information manager agreement, information sharing agreement, ISA, medical, physicians, Practice Management Success, successor custodian

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I have used Corridor's Privacy Awareness in Healthcare: Essentials online training program. The course has helped satisfy the training requirements of the Health Information Act. Staff go through the course at their own pace while we monitor to ensure completion.

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