Hipaa privacy regulations addressing hipaa at harvard university tina s sheldon harvard university
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HIPAA: Privacy Regulations Addressing HIPAA at Harvard University Tina S. Sheldon Harvard University PowerPoint PPT Presentation


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HIPAA: Privacy Regulations Addressing HIPAA at Harvard University Tina S. Sheldon Harvard University. HIPAA Summit West II San Francisco, California March 13-15, 2002. Agenda. Inside Harvard Yard HIPAA’s Impact on Harvard Harvard’s Approach to HIPAA HIPAA Issues & Operational Concerns.

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HIPAA: Privacy Regulations Addressing HIPAA at Harvard University Tina S. Sheldon Harvard University

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HIPAA: Privacy RegulationsAddressing HIPAA at Harvard UniversityTina S. SheldonHarvard University

HIPAA Summit West II

San Francisco, California

March 13-15, 2002


Agenda

  • Inside Harvard Yard

  • HIPAA’s Impact on Harvard

  • Harvard’s Approach to HIPAA

  • HIPAA Issues & Operational Concerns


Inside Harvard Yard

  • Understanding Harvard

  • Designating a HIPAA Team

  • Communicating with the Governing Body

  • Building University-wide Partnerships


HIPAA Risk Assessment

  • Inventoried Protected Health Information on Campus

  • Identified Covered Entities on Campus

  • Reviewed Non-Covered Entities’ Use of Protected Health Information

  • Examined Statutory Exceptions


University Health Services

Dental School Dental Clinics

Mental Health Services (Schools)

Student Athletics

Faculty & Staff Assistance Program

University Group Health Plan

Flexible Spending Account

Workers’ Compensation

Disability Plan

Research with Human Subjects

Protected Health Information On Campus


Covered Entities on Campus

  • Health Care Providers

    • University Health Services

    • Dental School Dental Clinics

  • Health Plan

    • University Group Health Plan

  • Health Care Clearinghouse

    • None


Mental Health Services

Student Services: Records Protected by FERPA

Student Athletics

Student Services: Records Protected by FERPA

Faculty & Staff Assistance

Referral Service, No Records

Flexible Medical Spending Account

Grievance Board: ERISA

Workers’ Compensation & Disability Programs

Self-Insured, Self-Managed Programs: State Preemption

Researchwith Human Subjects

IRB Approval Process

Non-Covered Entities & HIPAA Analysis


Bifurcated Approach: Health Care

  • Constituents

    • University Health Services

    • Dental School Dental Clinics

    • University Group Health Plan

    • Human Resources: Benefits Group

  • Sponsored Training

    • HIPAA Tutorial: McDermott, Will & Emery

  • Convened HIPAA Work Group

    • Members: Multi-Disciplinary (Clinical & Administrative)

    • Assess Practices & Inventory Vendor Relations

    • Develop HIPAA Work Plan

    • Create Forms & Policies

    • Conduct Staff Training


Bifurcated Approach: Research

  • Constituents

    • Institutional Review Boards

    • Office of Sponsored Research

    • Principal Investigators

  • Sponsored Training

    • HIPAA Workshop: McDermott, Will & Emery

    • Case Study Discussion

  • Created HIPAA Research Brochure

  • Charged IRB Operations Group

    • IRB Administrators

    • Office of Sponsored Research

    • Office of General Counsel

    • Risk Management & Audit Services


HIPAA Issues & Operational Concerns

  • Hybrid Organization

    • Primary Function: Education & Research

    • Designate Health Care Components

    • Document Designation: Corporate Vote

  • Privacy Officer

    • Each Covered Entity will Designate Privacy Officer

    • Each Privacy Officer will have Access to Governing Body

  • Student Services

    • FERPA vs. HIPAA

    • Transfer Issue: EMTALA

    • Consent Issue: Freshman Physicals


HIPAA Issues & Operational Concerns

  • Dental School Dental Clinics

    • Faculty Practice & Teaching Practice

    • Dental School Students: HIPAA Training? Medical Records?

    • Volunteer Teaching Faculty: How HIPAA Wise?

  • Research with Human Subjects:

    • 3 IRBs: Different Types of Studies & Data Points

    • Longitudinal Studies: Study Drop-outs & Aggregated Database?

    • PI Status: Covered Entity?

    • PI Request: Further Analysis of Data?

    • Colleague Request: Comparative Use of Data?

    • Cooperative Agreements: Whose IRB Reviews?


Closing Comments

  • Numerous Challenges Ahead

  • Many Unanswered Questions

  • Look to Associations & Industry Groups

  • Document HIPAA Expenses


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