A Real-Life Project Experience: Consulting Thielen Student Helath Center (TSCH) Online HIPAA Training Yasemin Demiraslan Farrah Dina Yusop CI 603 Advanced Instructional Systems Design Iowa State University of Science and Technology 05/03/2007 1 Table of Contents 1. Project description 3 2. Situation/context of the project 3 2.1 Problem description 3 2.2 The current HIPAA and ISU policies training 3 3. Problem(s) addressed 4 3.1 Needs analysis 4 3.2 Findings from the interview 5 4. Proposal 8 5. Course of actions 9 6. Reflections 10 7. Future Recommendations 10 Appendixes 11 Project contract 11 Interview questions 13 Final compilation of case studies for TSHC 14 Acknowledgement Letter 15 Closing letter 16 2 1. Project description This project is about developing an online training on Health Insurance Portability and Accountability Act (HIPAA) and ISU Health Information Privacy and Security Policy for the new employees at the Thomas B. Thielen Student Health Center (TSHC), Iowa State University, Ames, IA. The main purpose of the training is to provide the employees, especially the new employees at the Center, with the necessary information to protect patients’ personal health care and financial information according to HIPAA and ISU policies. 2. Situation/context of the project 2.1 Problem description Previously, the Health Insurance Portability and Accountability Act (HIPAA) and ISU Health Information Privacy and Security Policy training were conducted by our primary contact, Ms. PMC on one-to-one and face-to-face basis with the Center’s new employees as part of 3 series of training (The other 2 trainings are Safety Issues in Healthcare Environment and Handling Patients’ Complaints). Each of these training sessions takes between 30 to 50 minutes depending on the employees’ previous background working in healthcare environment, their work needs and positions in the center. The training must be conducted within the first 5 days of employment date and before the employees have direct contact with the patients. 2.2 The current HIPAA and ISU policies training The HIPAA and ISU policies training, which is the main focus of this project, is the most important and most challenging training experienced by the client due to several reasons: 1. frequent changes in HIPAA policies Under the law, every person working in the healthcare environment needs to follow and apply the HIPAA policies in their everyday task. Since the HIPAA requirements changes frequently, it is difficult to keep pace of the current HIPAA policies. In addition, there is no standardized content on HIPAA policies, which made it difficult to be explained for employees who work at different sections in the Center. 3 2. no specialized HIPAA training Since there is no standardized content of the HIPAA policies, the client had difficulties to train each new employee at the Center according to their specific sections. For instance, HIPAA training for clerical tasks will be different from the medical record people. Thus the client ended up with applying general HIPAA policies that will apply to all of the sections in the Center. 3. employees’ prior knowledge on HIPAA Employees’ prior knowledge on HIPAA is another challenge for the client. An employee with prior knowledge on HIPAA and has experience working in healthcare environment will not need to be trained so much on HIPAA policies, thus the client will concentrate more on training him/her in ISU policies compliant with the HIPAA policies. However, for an employee who has no prior knowledge on HIPAA and does not has prior experience working in healthcare environment, the training will take more time as the client needs to explain both HIPAA and ISU policies. 4. no further references Our needs analysis with the new employees on HIPAA and ISU policies also revealed that there are lack opportunities for them to refresh their HIPAA and ISU policies after the training. Even though printed manuals are provided in the Center for references, they seldom use it. Instead, most prefer to update their knowledge on HIPAA based on mouth-to-mouth approach, i.e. asking from someone who has more experienced in the section for guidance if they need help on something related to patients’ privacy issues. 3. Problem(s) addressed 3.1 Needs analysis To better understand the client’s and her employees’ needs, we have conducted 2 types of needs assessment: a. Client’s needs assessment 4 2 meetings were arranged between us and the client. The first meeting was to explore the scope of the project which was also attended by Vanessa Preast, our primary instructor of this project. During the second meeting, we attended and recorded an actual HIPAA and ISU policies training session conducted by our client with one of the Center’s new employees. The second meeting was really helpful to help understand the not only the scope of the project but also the challenges that the client face in her everyday training. b. Employees’ needs assessment Based on our client’s suggestions, we contacted 6 newly employed employees who had gone through the training on HIPAA and ISU policies conducted by our client. 4 of the interviewees are in the administrative positions at various sections of the Center, 1 is a clerk working with the Center’s Directors and 1 is a 10-hour working student who is assigned to work at the Medical Records section. All of them have prior knowledge on HIPAA policies and had previous experience working in healthcare environment. 2 focus group and 1 individual interview sessions were conducted with the center’s new employees on Feb. 23rd, 26th and 27th at the Center. The purpose of these interviews was to understand the effectiveness of the training conducted by our client from the employees’ perspectives and to solicit feedback on how we can better address their needs. The interview questions are attached. Focus group methods was selected to conduct the interviews with the employees due to the fact that this method triggers opinions of each participant as we saw in our interview sessions, thus lead more effective and valuable information regarding with the needs and interests of different people in the sessions. In addition, the way of interviewing 2 or 3 people together helped both us and the employees save time. 3.2 Findings from the interview The initial findings revealed valuable information and suggestions that are critical in helping us to develop the online training as stated in the Proposal section. Table 1 shows some key points acquired from the analysis of interview sessions with the employees. 5 Table 1: Interview sessions Current job and roles Session 1 Date Marlene Previous training on HIPAA &ISU privacy policy Learning preferences : Marlene, Pat and Mary : Friday Feb 23, 2007 at TSHC Started to work one month ago Medical records supervisor Applying HIPAA guidelines for medical records Transcribing health history and immunization information of the patients Interviewing, hiring the team of medical records Enforcing safety and HIPAA guidelines in medical records Do not have a direct contact with the patients Pat Suggestions to improve online training Started to work 9 months ago Administrative assistant Worked 3 years in a physician office Worked with HIPAA regulations and ISU privacy policy (student ID, Social security number etc.) Remembered more things about the training because of taking the training a few weeks ago Training was appropriate her work needs Learned most of the things about HIPAA and ISU policy by experience Training expectations were met (the training was very through) Worked 3 years as a clerk in an emergency Questionsanswers (FAQ) Brief quiz at the end of the training to show what and how you understand Bring additional questions to the current trainer can be helpful (blended approach) Not linear but provide a flexible navigation Comfortable with using computer Have internet access at home Checking out CD takes more time, online is preferable Online tour on the web site can be interesting Comfortable with using computer Have internet 6 Being the front desk for the administer, taking care of his calendar Hiring a new employee (human resources functions) Doing paper work for the advertising press Do not have a direct contact with patients (do not handle students’ records) Mary Started to work 6 weeks ago (early January) hospital Well know about HIPAA because of her experience in ISU for ten years Did not get a comprehensi ve training due to her position in the center (training was specific to the position of the people in the center) Could not recall anything specific about the previous training Different policies and procedures should be available online in case you forget the information Found current training very clear, got a good understandin g Can ask another person if she does not remember a policy or procedure Online checklist showing what you done Printing the sign form access at home Do not know the benefits of using which system The online training should be towards employees (temporary passwords to access the training) Audio+visual can be really helpful 10 question post test Printing the certification at the end of the training 7 Session 2 Date Ray : Ray Rodriguez & Lori : Monday Feb 26, 2007 at TSHC Started: 7 month ago Health cocoordinator (administrative) Conduct workshops and training (education) eg. Stress management, drug, fitness etc Lori Session 3 Date : Megan : Tuesday Feb 27, 2007 at TSHC Megan 4. Proposal To help overcome the problems presented above, we proposed the development of an online training module specifically for the Health Insurance Portability and Accountability Act (HIPAA) and ISU Health Information Privacy and Security Policy for the new employees. The proposed online training will have specific features that will eliminate, or at least to minimize, the current problems that the client is experiencing. The suggested features are: c. Online-based training – our needs analysis revealed that online module is more preferable than any other types of training, for instance, print-based materials and CD. The interviewees stressed that online module will enable them to access the training at anytime at anywhere at their own convenient. It will also provide the employees with an effective way to recall the information they forget or need later. d. Interactive elements – Our needs analysis also suggested that the online training to include interactive elements such as videos, audios and animations to be included, not only to motivate the employees to take the training but also to help 8 them better understand how HIPAA and ISU policies looks like in real life situations. For instance, the employee needs to they can not leave the patients’ files on their desks at anytime during the working hours to avoid other patients and staff looking at it, even accidentally. e. Online quizzes – Since learning about policies and regulations could be long and tiresome, we decided to include short quizzes in the online training. This element is needed not only to test the employees’ understanding on the content, but also to ‘wake them up’. f. Breaking down the modules – Based on the needs analysis, we plan to break down the training modules into sub-modules. Each sub-module will take only 20 to 30 minutes time for motivational and easiness purposes, especially for employees who would like to take the training during their lunch break. 5. Course of actions We plan to conduct the needs assessment, design and development works, and usability testing within this timeline: Activity Start Date End Date 1. identify client’s needs (Needs assessment) 29 Jan 2007 5 Feb 2007 2. conduct needs analysis (Needs assessment) 5 Feb 2007 26 Feb 2007 3. design content and online module 26 Feb 2007 19 March 2007 19 March 2007 9 April 2007 5. pilot test and revise the module (usability testing) 9 April 2007 23 April 2007 6. disseminate the online module 23 April 2007 3 May 2007 (Design and development) 4. develop the prototype of the online module (Design and development) 9 6. Reflections Based on our experience working with the client in specific and with the Center in general, we found out that they are cooperative and attended to our needs as much as they can. Thus, our relationship with the client was smooth. The client was helpful and cooperative, shared materials and eager to help. - there was a time when we did not get response from the client.. it turned out that she was sick at the time - we learned that we need to employ other methods of communication other than e-mails including phone calls In addition, it is clear to see that many employees in the center has positive thoughts about online training and find it effective in learning. They also mentioned a special need and interest to take the training online in order to get necessary information and skills to combat such an important issue in their workplaces. 7. Future Recommendations Accompanying these findings is a set of recommendations to improve the effectiveness of the online training. 1. An online quiz can be added not only to test the employees’ understanding on the content, but also to ‘wake them up’. 2. The development of “Test” and “FAQs” sections can be another mini-project by itself. 3. Site navigation: I. An presentation to orient the employees (can also be put on TSHC website) II. A help button can be added with some text explaining the structure of the website with suggestions about navigation through the website. 10 APPENDIXES 1. Contract with the client PROJECT CONTRACT Overview The Thomas B. Thielen Student Health Center (TSHC) wants to implement online training on Health Insurance Portability and Accountability Act (HIPAA) and ISU Health Information Privacy and Security Policy for the new employees. This training is intended to educate the employees on their responsibilities to protect patients’ personal health care and financial information according to HIPAA and ISU policies and will be carried out within five working days of their first day of employment. This contract constitutes an agreement between Ms Penni McKinley and Ms Yasemin Demiraslan and Farrah Yusop regarding the development of the ‘Handling Patients’ Privacy and Security Issues’ module of this training program. This document will serve as a reference point for discussion about the project and will set forth the expectations of both the client and the consultant. The contract is meant to be a continuously negotiated document that sets the groundwork for the project, and not a rigid set of guidelines that cannot be modified. Personnel The client for the project is Penni McKinley, the Quality Improvement Coordinator for the Thomas B. Thielen Student Health Center. She is currently the trainer of the face-to-face orientation for the ‘Handling Patients’ Privacy and Security’ training program. The consultanst are Yasemin Demiraslan and Farrah Yusop, PhD students from Curriculum and Instructional Technology Department of Iowa State University. This project is undertaken by the consultants to fulfill the requirements of the CI 603 – Advanced Instructional Systems Design course. Yasemin and Farrah will work with Penni during the course duration spanning 29 January 2007 to April 26. Goal To develop an online training module on the ‘Handling Patients’ Privacy and Security Issues’ for the TSHC new employees. Objectives 1. 2. 3. 4. 5. To identify learners’ needs To identify learning objectives of the training To analyze and scope the content of the training To develop the online training To pilot test the online training Expectations and tasks The client expects the consultants to: 11 a. b. c. d. Provide expert advice regarding the use of instructional methods and strategies Manage the instructional product development process Share problems and concerns about the project with the client Adhere to agreed project deadlines, unless negotiated otherwise The consultants expect the client to: a. Work collaboratively with the consultants for the project b. Share problems and concerns about the project with the consultants c. Provide content expertise and appropriate learning materials for the project d. Locate resources (inclusive of human, financial, material) necessary for the project e. Adhere to agreed project deadlines, unless negotiated otherwise Resources The client will provide: materials for the online training resources for data collection and disseminating the online training The consultants will provide: data on the requirements of the online training expertise in the instructional design of the online training Work Schedule Activity Start Date End Date 7. identify client’s needs 29 Jan 2007 5 Feb 2007 8. conduct needs analysis 5 Feb 2007 26 Feb 2007 9. design content and online module 26 Feb 2007 19 March 2007 10. develop the prototype of the online module 19 March 2007 9 April 2007 11. pilot test and revise the module 9 April 2007 23 April 2007 12. disseminate the online module 23 April 2007 3 May 2007 Renegotiation Any part of this agreement may be revised at any time by mutual consent. 12 2. Interview questions 1. Demographic background a. Can you briefly describe your current job and roles in this center? b. previous knowledge on HIPAA & ISU privacy policy Did you ever heard about Health Insurance Portability and Accountability Act (HIPAA)? What do you know about it? How does it relate to your job? 2. Training a. previous training on HIPAA & ISU privacy policy have you taken the training? Where and when? b. Training expectations What were your expectations? Did the training meet your expectations? What do you know now about protecting privacy of health information that you wish you knew at the time of training? What was particularly helpful about the training you received? 3. Suggestion to improve training We are developing new online training about protecting privacy of health information. What advice would you give us to make this training more effective and enjoyable for trainees? 4. Learning preferences Are you comfortable using computers? Do you have access to computer and internet? If you were given options to take the training online, print-based, CD which one would you prefer? Why? 5. Could you write one or two questions about protecting privacy of health information that you really want to learn the answers? 13 3. Final Compilation of case studies for TSHC Module 2.2 PHI basics Case I work in the TSHC Medical Record section. A friend of mine who works in the Yellow Pod section told me that she just saw her ISU Teaching Assistant get on to the TSHC. My friend is curious about this person. She read in the Iowa State Daily paper that the TA has cancer. My friend asked me if I could find out the TA’s medical records and show it to her. (Adapted from University of California, San Diego’s Department of Psychiatry at http://psychiatry.ucsd.edu/forms/HIPAA%20Mandatory%20Train ing.pdf) 2.3 PHI use and disclosure Passing through a check-in area, Nurse Betty overhears Adam, the clinic check-in clerk telling a patient on the phone that he needs a follow-up appointment because his HIV test just came back positive. She notices waiting patients are listening intently to the phone conversation. (Adapted from UNC School of Medicine at http://www.med.unc.edu/ois/hipaa/training/genprivacy_mod1/sli de15.html ) 2.2.c Disclosing PHI to family & friends Joe McCleod, who is a junior, was seen by a doctor at the TSHC for treatment of a broken leg. He is 19 years old. Unable to learn what is happening with their son, Mr. & Mrs. McCleod ask their friend, Betty, who works in the Business Office, to review Joe's records. Betty reviews the records and informs Joe's parents that Joe broke his leg in two places after he fell over the curb coming out of the bars. What we need from TSHC 2 people from the Medical record section: Talking to each other 1 person will act thinking of something 1 person will looking at the camera and puzzle 1 person from the front desk (talking on the phone) 1 nurse (passing by the desk) 2-3 people waiting in the waiting areas 1 woman (as the mom) 1 man (as the dad) 1 doctor (reading the patient’s record to the couple) (Adapted from UNC School of Medicine at http://www.med.unc.edu/ois/hipaa/training/genprivacy_mod1/sli de12.html) 3.2 Securing PHI on your computer workstatio n A physician leaves his tablet which is open to a patient’s visit notes, on the counter of the back lobby. The laptop did not have a automatic screen saver set. As the physician is on the phone, looking away the patient intentionally looks at the information on the laptop. 1 person (using his/her laptop at TSHC) Back lobby counter (Adapted from UNC School of Medicine at http://www.med.unc.edu/ois/hipaa/training/gensecurity_mod2/sli de21.html ) 14 4. Acknowledgement Letter May 4, 2007 Farrah Dina Yusop Yasemin Demiraslan Center for Technology in Learning and Teaching N031 Lagomarcino Hall Iowa State University Ames, Iowa 50010 Re: Online training on the Health Insurance Portability and Accountability Act (HIPAA) and Iowa State University (ISU) Privacy Policy for Thielen Student Health Center (TSHC) On behalf of Thielen Student Health Center (TSHC) at Iowa State University (ISU) I would like to thank both of you for designing and developing an online training on Health Insurance Portability and Accountability Act (HIPAA) and ISU Privacy Policy for our new and current employees. The online training you designed and developed is very helpful to introduce our new employees to the HIPAA Privacy Policy, a federal law that requires every healthcare personnel to protect patients’ personal health information and how TSHC acts in accordance with the law. At the same time it also functions as a refreshing reference for our current employees. This is the first time that an online training on HIPAA and ISU Privacy Policy has ever been developed specifically for TSHC employees. The online training was very well done and we compliment you on its professional presentation. I appreciate the time and effort you spent assisting our organization. I also appreciated the opportunity to get to know both of you. We look forward to future collaborations. Sincerely, Penni McKinley, RN, BA Quality Improvement Coordinator Iowa State University 2260 Thielen Student Health Center Ames, IA 50011-2260 515.294.1059 (Work) 515.294.5457 (Fax) 15 5. Closing Letter 04/03/2007 Yasemin Demiraslan Farrah Dina Yusop Center for Technology in Learning and Teaching N031 Lagomarcino Hall Iowa State University Ames, Iowa 50010 Penni McKinley, RN, BA Quality Improvement Coordinator Iowa State University 2260 Thielen Student Health Center Ames, IA 50011-2260 Phone:15152941059 (work) Fax:15152945457 pmckinle@iastate.edu Dear Ms. McKinley, You have requested developing an online training on Health Insurance Portability and Accountability Act (HIPAA) and ISU Health Information Privacy and Security Policy for the new employees at the Thomas B. Thielen Student Health Center (TSHC). The main purpose of the training was to provide the employees, especially the new employees at the Center, with the necessary information to protect patients’ personal health care and financial information according to HIPAA and ISU policies. The enclosed materials were designed and developed to meet the objectives of the project such as identifying learners’ needs, identifying learning objectives of the training, analyzing the scope and the content of the training, developing and pilot testing the online training. The results of the interviews conducted with 6 newly employed employees revealed that online module is more preferable than any other types of training, for instance, print-based materials and CD. The interviewees stressed that online module will enable them to access the training at anytime at anywhere at their own convenient. Our needs analysis also suggested that the online training including interactive elements such as videos, audios and animations, not only to motivate the employees to take the training but also to help them better understand how HIPAA and ISU policies looks like in real life situations. In addition, based on the needs analysis, we planed to break down the training modules into sub-modules for motivational and easiness purposes. 16 These findings informed us in developing the online training which will eliminate, or at least to minimize, the current problems in HIPAA training that you are experiencing. Accompanying these findings is a set of recommendations to improve the effectiveness of the online training. Please feel free to send us e-mail if you have any questions about these materials or if we can provide any additional information to assist you in the implementation process. You may reach us via e-mail. Our e-mail addresses are: yasemind@iastate.edu, fdyusop@iastate.edu Thank you for this opportunity and we will be looking forward to future collaborations. Sincerely, Yasemin Demiraslan Farrah Dina Yusop 17