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Employees Working Remotely / Recommendation on discarding Controlled Substances

April 10, 2014

 
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Question:

Jennifer, 

With HIPAA and all the other things I have to worry about, how concerned do I have to be about my employees working remotely?

Please let me know.  
Thanks, 
P

Answer:

Very.  But, lets limit this discussion to the concerns you should have with employees working remotely related to HIPAA.  If you own/operate/manage a company similar to most governed by HIPAA you may not have all the policies and procedures in place required by law, or recommended by your counsel.  Here is where you may run into an extreme problem.  HIPAA imposes a burden on any responsible party for maintaining confidentiality of PHI, and if you do not have proper policies and procedures in place covering who may or may not work remotely, with what authority and under what circumstances and what protections, you may be opening yourself to exposure based on an unsupervised employee's conduct. Exposure, including but not limited to a government investigation and fines (possibly substantial).   

For any employee authorized to work remotely, I recommend adopting policies that govern everything mentioned above - address what technology is acceptable and the required administrative, technical and physical safeguards required to be in place for access, use or storage of PHI. Each practice should have a breach notification policy dictating procedure dictating reporting requirements for stolen hardware or unauthorized disclosures of PHI, and train on that policy.   Also, make sure you have the employee indemnifying you for any exposure resulting from their failure to comply with company policy. 

Need help?  Contact Jennifer or Erica to discuss.  

HBMA Members - remember, your discount on all compliance documents expires on April 18, 2014!!!!

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Recommendation on discarding Controlled Substances - (Thank you to Cheryl Malone, always an incredible resource! #supportoursocieties!)

Hi, Jennifer:
 
Hope all is well with you.  I wanted to share this resource with your  after reading today’s Healthcare Newsletter on controlled substance storage.  Dispensary of Hope is an organization that  doctors can use to help with  medication samples disposal. 
 
 Dispensary of Hope is a nonprofit organization that helps doctors donate sample or shortly expiring medications so they can be used by clinics serving the needy.  (They will take expired medication as well for disposal.)    Not only do they  put medications in the hands of a patient in need, they also reduce their staff time, reduce medical waste, and help the community.   Pledge to donate sample medications and the Dispensary of Hope will provide the practice with a donation bin and prepaid shipping. Participation is free.  The New York County Medical Society’s Clifford L. Spingarn, MD Memorial  Education Fund (aka MEDCOFUND) is a supporter of  Dispensary of Hope.    New York County Medical Society members have donated over $400,000 worth of medication in the past two years.  The practice will receive an itemized receipt of the samples donated for  its records.  No more worry about disposal or waste, and itemized list of what was donated.  Doctors can pledge today  at www.dispensaryofhope.org/give-meds  
 
Cheryl
 
Cheryl M. Malone, CAE
Executive Director
New York County Medical Society
12 East 41 Street, 15th Floor
New York, NY 10017
(212) 684-4670, ext. 210
Fax: (212) 684-4741
www.nycms.org

     
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