Health Information Management

HIPAA Q&A: Summer help

HIM-HIPAA Insider, December 21, 2009

Q. A covered entity is hiring summer temporary help and has also implemented a job shadowing program. Temporaries’ job duties include entering data and downloading films that include PHI. Do temporaries and those involved in the job shadowing program need to sign a confidentiality agreement and/or acknowledgement of HIPAA?

A.
Covered entities should require workers such as temporaries, summer help, and individuals who are job shadowing to sign a confidentiality agreement. All such workers are considered part of a covered entity’s work force for HIPAA purposes. Develop a brief training flyer that covers high-level privacy and security requirements and require temporary workers to read and sign it. This will satisfy the HIPAA privacy and security rule training requirements.

All work force members must be trained, but unless the temporary workers will be employed at the organization for an extended period of time, it is not practical to run them through the full new employee HIPAA training.

Editor’s note: Chris Apgar, CISSP, answered this question. This is not legal advice. Consult your attorney regarding legal matters.

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