HIPAA COMPLIANCE PROTECT INFORMATION INCREASE RECYCLING SAVE MONEY

2 HIPAA SWEEPING REQUIREMENTS –AFFECTS SEVERAL MAJOR BUSINESS SECTORS HEALTH CARE –IMPACTS MANY ASPECTS OF OPERATIONS –ASSESSMENT OF RISK FOR RELEASE OF INFORMATION

3 WASTE MANAGEMENT ISSUES VAST MAJORITY OF PAPER GENERATED IN HEALTH CARE CONTAINS CONFIDENTIAL INFORMATION –LEGALLY PROTECTED PATIENT INFORMATION –CONFIDENTIAL ORGANIZATIONAL INFORMATION –PERSONAL/EMPLOYEE INFORMATION

4 HIPAA INTERPRETATIONS NO GUIDANCE FROM HIPAA WIDE VARIATION IN INTERPRETATION –“REASONABLE AND PRUDENT”

5 AVAILABLE OPTIONS DEPARTMENTAL SHREDDING ON SITE CENTRAL SHREDDING DOCUMENT DESTRUCTION/MOBILE SHREDDING CONTRACTORS OFF SITE SHREDDING CONFIDENTIAL RECYCLING PROGRAMS –SECURE CHAIN OF CUSTODY

6 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

7 PROCESS FOR CHANGE ASSESSMENT –REVIEW CURRENT PROCESSES AND PROCEDURES –IDENTIFY VULNERABILITIES INCLUDE APPROPRIATE PERSONS AND DEPARTMENTS IN PLANNING –EMPLOYEE CONFIDENTIALITY STATEMENTS –CONTRACTED SERVICES

8 COLLECTION PROCESSES CONTAINERS –LOCKED VS. UNLOCKED? –FIRE CODE PROVISIONS –COLOR CODE BAGS –IN HOUSE TRANSPORT

9 “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

10 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 PRIVACY OFFICER? INDEMNIFICATION INSURANCE

11 TRAINING NEW EMPLOYEE ORIENTATION ANNUAL TRAINING –HIPAA REQUIREMENTS –EOC HAZARDOUS MATERIALS AND WASTE PROGRAM

12 COST SAVINGS DIVERSION COST AVOIDANCE REBATES

13 OTHER ISSUES RECORDS PURGES CONTAMINATING MATERIALS PATIENT CARDS IV BAGS MEDICINE BOTTLES OTHER MISC CONFIDENTIAL MATERIALS IN THE WASTE STREAM

14 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 –INORMATION SHARING