The question we are always asked is: “Why is HIPAA Group Training important today in health care?” The Health Insurance Portability and Accountability Act (HIPAA) has been in effect since 2003. Among many of its many roles it mandated the adoption of Federal privacy protections for individually identifiable health information. This requirement was aimed at covered entities that conduct standard health transactions electronically that are one of the following groups: Providers, Health Plans and Health Care Clearinghouses. Portions of the rule since then has also applied to Business Associates who perform activities requiring the use of protected health information on behalf of the covered entities. The regulation also required training of the workforce of these organizations on the Privacy Rule.
If your organization fits into one of these groups, then you must consider some type of HIPAA Group Training to satisfy the requirements of HIPAA.
You must also consider what the training requirements are to make an informed decision for your organization.
Covered Entities are required to comply with the Privacy Rule training requirement. Both Covered Entities and Business Associates are required to comply with the Security Rule training requirement, which applies to all members of the workforce regardless of whether they have access to PHI or not.
Privacy Rule Training Requirement
The following is a statement addressing the Privacy Rule requirement:
“A covered entity must train all members of its workforce on the policies and procedures with respect to protected health information required by this subpart and subpart D of this part, as necessary and appropriate for the members of the workforce to carry out their functions within the covered entity.”
“Workforce means employees, volunteers, trainees, and other persons whose conduct, in the performance of work for a covered entity or business associate, is under the direct control of such covered entity or business associate, whether or not they are paid by the covered entity or business associate.” (45 CFR § 160.103)
Based on this information it is important that all members who are accessing protected health information would require HIPAA training to carry out their functions
Security Rule Training Requirement
The following is a statement addressing the Security Rule requirement.
“Implement a security awareness and training program for all members of its workforce (including management).”
This would require an ongoing training program addressing the Security Rule for all workforce members.
How Often Should You Train?
HIPAA training is required for “each new member of the workforce within a reasonable period of time after the person joins the Covered Entity’s workforce” and when “functions are affected by a material change in policies or procedures” – again within a reasonable period of time.
The Security Rule training standard implies that security and awareness training programs should be ongoing. HIPAA training should also be provided whenever there is a change in working practices or technology, whenever a risk assessment identifies a need for further training, or whenever new rules or guidelines are issued by the Department for Health and Human Services (HHS).
Based on these conditions and best practices an organization should offer training at least every other year if not more often.
HIPAA Group Training Programs
An acceptable HIPAA Group Training program should provide a basic understanding of HIPAA to every member of the workforce and offer specific training on the policies and procedures of the organization as necessary and appropriate. Not only will this ensure every member of the workforce understands HIPAA, but they can also apply it to their work functions.
By providing a group training approach an organization will lessen the administrative overhead and more efficiently complete the training necessary to satisfy their HIPAA Compliance requirements. This training today can be easily provided through a virtual platform, all at once, or through an online educational platform where every member of the group can proceed with training at their own pace. A good educational partner will help the organization arrange training and keep them informed of progress.
In this circumstance it is best to train your staff using a well-crafted group training program. Look for an organization that has substantial experience in the field and for one that has known credentials and advanced training in the HIPAA Privacy Rule. Many organizations today offer HIPAA training with little or no experience in the field. Beware of these.
HIPAA Associates has been in the HIPAA business prior to the implementation of HIPAA. Their professionals are well respected in the field and have the advanced knowledge, experience, and credentials to service your educational needs.
Al Lopez is the Vice President of Operations for HIPAA Associates for the last ten years. Dr. Lopez has passed board certification in internal medicine, pulmonary, and anesthesia and holds a degree as a medical coding specialist. He has served as a Compliance Director and Privacy Officer for over ten years. In addition, Dr. Lopez is certified in Healthcare Compliance and has held various leadership roles within the hospital staff and private practice. His main interest is in HIPAA training.