Team 6C
Central Columbia Hospital, Scenario D: Technology/Social Media/HIPAA
Problems
Central Columbia Hospital is a close-knit community hospital. When they hired a new
president and CEO from outside of their community after a long 125 years, the employees had
trouble adapting to the change. Since Anita Green was hired she set many lofty goals for the
hospital to reach. She set a goal to reach 90% in patient satisfaction, she wants to hire a corporate
compliance officer, improve numerous service lines in addition to the ones she has already
turned into revenue-producing lines, as well as improve the staffing in those areas. All of the
changes and high goals have caused an increase in stress and decrease in morale among the
employees. They are no longer engaged, they are not trusting Green, and they are not sure if they
want to continue working at the hospital. As a result, employees are not living up to the
hospital’s mission. We can see this by looking at the employees that started expressing their
concerns on social media that were not compassionate, caring, or professional. In addition, the
posts have caused other employees to become concerned, worried about the security of their
positions. It also raised an important legal issue: a HIPAA violation that could end with
disciplinary action for these employees.
An individual’s health and demographic information is protected under HIPAA and even
without the use of a name, any descriptors that could reasonably identify someone in relation to
that information is in violation. Both Renee and Charles gave away specific details that could
lead to the identification of a patient. Renee specified the patient’s location inside the hospital
along with speaking poorly of his character. Charles specified the medical condition the patient
was being seen for along with speaking poorly of the patient. Being in direct violation of HIPAA
warrants discipline. While Holly and Christopher were not in direct violation of HIPAA, they
both spoke negatively about the patient and confirmed his location indirectly. Based on the
hospital’s mission, these actions could warrant discipline. Amy, Tammy, and Stephanie were not
in violation of HIPAA. As a whole, the group is protected against discipline for criticizing their
employer and working conditions in a concerted activity since they were discussing these things
with other coworkers. Had the other employees not joined in on the conversation, Christopher
would receive harsher discipline. Amy, Tammy, and Stephanie did not violate HIPAA, are
protected under Section VII of the National Labor Relations Act (NLRA) for their concerted
activity, and therefore warrant no discipline.
Alternatives
The employees’ behavior in the situation needs to be addressed. We recommend a
disciplinary action of termination for Renee and Charles, written reprimands for Christopher and
Holly, and Amy, Tammy and Stephanie would receive no discipline. If deemed appropriate, a
verbal counseling could be given to them so that they understand the nature of the situation they
were in and leave with a better understanding for the future.
CCH needs to address the situation on a larger scale so that future violations of any
policies and legal risks can be avoided. A clearly defined Code of Conduct needs to be
implemented and relayed to all the employees. The code would not only clearly define and
clarify policies, but also specify the consequences of such actions that violate it. Implementing
training on HIPAA, social media policies, and other legal risks the hospital needs to avoid would
also be beneficial in providing the employees with a better understanding of what they can and
cannot say in different situations. It is important for all employees to be trained on these
important issues annually as laws and technology can change over time. A way to address the
stress and morale issues would be to provide resources for stress management the employees can
utilize. Lastly, CCH needs to work on receiving more feedback from employees by having
individual department meetings run by each department head. These steps will help the
employees become more comfortable with changes being made at the hospital and create a better
environment for them to voice their concerns. Their compliance and understanding would
increase Green’s goals and it will help the hospital work on their results from the cultural
assessment survey since the scores have continually decreased.
Recommendation
We recommend establishing a position for a corporate compliance officer. Hiring this
employee will enable them to focus on “addressing HIPAA, Medicare issues, and regulations
associated with the Department of Health and the Joint Commission's criteria” (Riccio, Steve).
This employee will be able to work strategically with other executives in planning ahead to avoid
all other possible compliance challenges. Moreover, this employee will have the ability to
conduct annual HIPAA training for all employees. The corporate compliance officer will have
the necessary knowledge and information to clarify the Code of Conduct and will be able to
develop a formal social media policy.
The formal social media policy will provide enough guidance for employees about the
use of social media, since the current Code of Conduct does not. The policy will detail how CCH
respects the right of employees using social media during nonworking hours, however social
media may “cause certain risks and carries with it certain responsibilities” (Social Media Policy).
These guidelines will include sections detailing what is considered social media, knowing and
following the rules, being respectful, being honest and accurate, posting only appropriate and
respectful content, using social media at work, how retaliation is prohibited, and media contacts.
In addition, the social media policy will clearly state possible consequences that may result in
disciplinary action up to and including termination. Lastly, the policy will mention that nothing
in this policy is intended to interfere with the employees’ Section VII rights of the NLRA to
communicate with each other regarding the terms or conditions of their employment (NLRB).
This position needs to be approved and once that is done, Green can meet with Toth and
Scott to discuss the hiring process for this employee and develop a job description. Since this
employee could end up working with Human Resources and Risk Management, all three of them
need to work together to start the search for these candidates, interview them, and come to a
consensus on hiring the right person for the job.
Hiring the corporate compliance officer is the first step CCH must complete to ensure the
hospital is moving in a positive direction. Once this individual is hired and training for the social
media policy and HIPAA issues are addressed, the hospital will be able to focus on improving
their facility. This includes goals such as increasing employee satisfaction, wages, minimizing
stress, and promoting a healthy work-life balance. Additionally, it will make CCH more
proactive rather than reactive when dealing with company problems. Finally, making these
necessary changes will aid CCH in executing their strategic goals and preserving and upholding
the company’s mission to deliver health care services in a compassionate, caring, and cost
effective manner while maintaining professional excellence.
Works Cited
1. "Social Media Policy." SHRM Online - Society for Human Resource Management. N.p.,
n.d. Web. 09 Apr. 2015.
2. "Department of HealthJohn J. Dreyzehner, MD, MPH, Commissioner." HIPAA: Health
Insurance Portability and Accountability Act. Web. 7 Apr. 2015.
3. "NLRB.gov." Protected Concerted Activity. N.p., n.d. Web. 09 Apr. 2015.
4. Riccio, Steve. Central Columbia Hospital. N.p.: Society for Human Resource
Management, 2015. PDF.
"Symptoms of Anxiety / Stress & Burnout Statistics." Symptoms of Anxiety / Stress & Burnout
Statistics. Web. 7 Apr. 2015.