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. 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 regulations addressing hipaa at harvard university tina s sheldon harvard university

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

HIPAA Summit West II

San Francisco, California

March 13-15, 2002


Agenda

Agenda

  • Inside Harvard Yard

  • HIPAA’s Impact on Harvard

  • Harvard’s Approach to HIPAA

  • HIPAA Issues & Operational Concerns


Inside harvard yard

Inside Harvard Yard

  • Understanding Harvard

  • Designating a HIPAA Team

  • Communicating with the Governing Body

  • Building University-wide Partnerships


Hipaa risk assessment

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


Protected health information on campus

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

Covered Entities on Campus

  • Health Care Providers

    • University Health Services

    • Dental School Dental Clinics

  • Health Plan

    • University Group Health Plan

  • Health Care Clearinghouse

    • None


Non covered entities hipaa analysis

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

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

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

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 concerns1

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

Closing Comments

  • Numerous Challenges Ahead

  • Many Unanswered Questions

  • Look to Associations & Industry Groups

  • Document HIPAA Expenses


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