HIPAA ~ HIPAA Sanctions: From Warnings To Termination, You Must Show Determination

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Note:  The following article synopsis was NOT provided by AAPC. It was created by Find-A-Code/innoviHealth.

Article Overview

This article discusses how covered entities can structure and apply HIPAA sanctions policies for workforce members who fail to follow privacy policies and procedures. It focuses on the need for a formal policy, the role of privacy officers and management, and broad approaches to categorizing non-compliance and disciplinary responses. The piece is aimed at privacy, compliance, legal, and healthcare operations staff who need to understand how sanctions policies fit within HIPAA privacy program requirements.

Why This Topic Matters

A sanctions policy is a required part of HIPAA privacy compliance, and organizations need a workable approach for addressing employee non-compliance. This article helps readers understand the operational and governance issues involved in making discipline consistent, defensible, and visible to staff.

What You Will Learn

  • Why covered entities need a sanctions policy for HIPAA privacy compliance
  • How organizations may organize workforce non-compliance into broad severity levels
  • What roles privacy officers, counsel, and management may play in reviewing incidents
  • How organizations think about responding to improper disclosures and other privacy violations
  • Why staff awareness of consequences is considered important in a compliance program

Who Should Read This

  • HIPAA privacy officers
  • Compliance officers
  • Healthcare administrators
  • In-house counsel
  • Health information management professionals

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