Q&A: Are colleges sending students to our facility for rotations business associates?
HIM-HIPAA Insider, September 20, 2011
Want to receive articles like this one in your inbox? Subscribe to HIM-HIPAA Insider!
Q: Should we obtain business associate agreements with colleges that send students to our hospital for clinical rotations? The Privacy Rule includes trainees as a member of the workforce, and other provisions pertain to students in training programs. However, I am not certain whether these provisions apply to all aspects of students’ exposure to PHI and want to request execution of business associate agreements with our affiliated clinical programs.
A: An educational program is not considered a business associate because it does not provide a service on behalf of a covered entity. A business associate agreement is not appropriate, but many organizations execute written affiliation agreements with educational programs whose students they accept.
These agreements usually require clinical programs to provide students who have received HIPAA training and understand their obligation to protect PHI. Many organizations also require students to sign individual confidentiality agreements during orientation.
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, vice president of HIM at Scott & White Healthcare in Temple, TX, answered this question in the September issue of Briefings on HIPAA.
Want to receive articles like this one in your inbox? Subscribe to HIM-HIPAA Insider!
Related Products
Most Popular
- Articles
-
- Don't forget the three checks in medication administration
- Steps for maintaining patient privacy
- The consequences of an incomplete medical record
- Note similarities and differences between HCPCS, CPT® codes
- Tip of the week: Overcoming language barriers with ESL staff members
- Know the medical gas cylinder storage requirements
- Practice the six rights of medication administration
- Prevent dehydration with nursing interventions
- Nursing responsibilities for managing pain
- Q&A: Primary, principal, and secondary diagnoses
- E-mailed
-
- Understand how to report services during the global period for minor surgeries
- Tip: Understand Q status indicator subcategories
- Tip: Report drugs with HCPCS code, revenue code 636
- Tip: Carefully code fracture care
- Elder Abuse and Exploitation
- Documentation challenges for skin and dermatology coding
- Correctly code for new cardiac, pulmonary rehab benefits
- Searched