tci Medicare Compliance & Reimbursement - 2021 Issue Q1

Reader Question: Keep Staff and Patient COVID-19 Vaccination Records Separate

Question: At our rural practice, most staff are also patients as we are the only healthcare provider in the area. Is it OK to store employees’ COVID-19 vaccination records with patients’ EHRs in our system, so we can track who’s been vaccinated? Iowa Subscriber Answer: Both the Occupational Safety and Health Administration (OSHA) and the Centers for Disease Control and Prevention (CDC) recommend strongly against storing staff files — both paper and electronic — with patient data. Here’s why: Though EHR technology can greatly help with the maintenance of staff records, you should avoid mixing patients’ protected...

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