HIPAA COMPLIANCE
PROTECT INFORMATION
INCREASE RECYCLING
SAVE MONEY
HIPAA
• SWEEPING REQUIREMENTS
– AFFECTS SEVERAL MAJOR BUSINESS
SECTORS
• HEALTH CARE
– IMPACTS MANY ASPECTS OF
OPERATIONS
– ASSESSMENT OF RISK FOR RELEASE OF
INFORMATION
2
WASTE MANAGEMENT
ISSUES
• VAST MAJORITY OF PAPER
GENERATED IN HEALTH CARE
CONTAINS CONFIDENTIAL
INFORMATION
– LEGALLY PROTECTED PATIENT
INFORMATION
– CONFIDENTIAL ORGANIZATIONAL
INFORMATION
– PERSONAL/EMPLOYEE INFORMATION
3
HIPAA INTERPRETATIONS
• NO GUIDANCE FROM HIPAA
• WIDE VARIATION IN
INTERPRETATION
– “REASONABLE AND PRUDENT”
4
AVAILABLE OPTIONS
• DEPARTMENTAL SHREDDING
• ON SITE CENTRAL SHREDDING
• DOCUMENT DESTRUCTION/MOBILE
SHREDDING CONTRACTORS
• OFF SITE SHREDDING
• CONFIDENTIAL RECYCLING
PROGRAMS
– SECURE CHAIN OF CUSTODY
5
DRIVER FOR POSITIVE
CHANGE
• REGULATORY REASON TO COLLECT
OFFICE PAPER
• USE EXISTING STRUCTURES AND
PROCESSES
– BUILD ON EXISTING PAPER RECYCLING
PROGRAM
• DEVELOP POLICY AND PROCEDURES
6
PROCESS FOR CHANGE
• ASSESSMENT
– REVIEW CURRENT PROCESSES AND
PROCEDURES
– IDENTIFY VULNERABILITIES
• INCLUDE APPROPRIATE PERSONS
AND DEPARTMENTS IN PLANNING
– EMPLOYEE CONFIDENTIALITY
STATEMENTS
– CONTRACTED SERVICES
7
COLLECTION PROCESSES
• CONTAINERS
–
–
–
–
LOCKED VS. UNLOCKED?
FIRE CODE PROVISIONS
COLOR CODE BAGS
IN HOUSE TRANSPORT
8
“TO SHRED OR NOT TO
SHRED… THAT IS THE
QUESTION!”
• ULTRA SECURE DOCUMENTS
– DOCUMENT SHREDDING CONTRACTOR
• ITEMS ANOTHER EMPLOYEE
SHOULD NEVER SEE
– SHRED IN THE DEPARTMENT
– BASKET TOP SHREDDERS
9
SECURE CHAIN OF
CUSTODY
• KNOW YOUR VENDOR
– FACILITY AUDIT/TOUR
– PROCESSES AND PROCEDURES
– VENDOR EQUIPMENT
• CONTAINERS
• OFFSITE OPTIONS
• CONFIDENTAILITY AGREEMENTS
AND CONTRACTS LANGUAGE
• LEGAL REVIEW
10
TRAINING
• NEW EMPLOYEE ORIENTATION
• ANNUAL TRAINING
– HIPAA REQUIREMENTS
– EOC HAZARDOUS MATERIALS AND
WASTE PROGRAM
11
COST SAVINGS
• DIVERSION
• COST AVOIDANCE
• REBATES
12
OTHER ISSUES
•
•
•
•
•
•
RECORDS PURGES
CONTAMINATING MATERIALS
PATIENT CARDS
IV BAGS
MEDICINE BOTTLES
OTHER MISC CONFIDENTIAL
MATERIALS IN THE WASTE STREAM
13
NEXT STEPS
– CONTINUE DEVELOPMENT OF POLICY
AND PROCEDURE
– CONTINUE CONNECTING COMPLIANCE
TO OPPORTUNITY FOR MATERIAL
RECOVERY
– IDENTIFY PROBLEMS AND CORRECTIVE
MEASURES
– WASTE STREAM
AUDITS/RECORDKEEPING
14
– INORMATION SHARING