1. Privacy & Confidentiality
Protecting those we serve & securing the contract we operate under

2. Training Objectives
Explain SKILS’KIN’s policy located in the Employee Handbook.
Outline contract requirement regarding privacy & confidentiality.
Explain employee’s responsibility.
Discuss preventative measures.
Define HIPAA & how it relates to service provisions.

3. SKILS’KIN’s Internal Policy & Requirements

4. All employees must read & sign SKILS’KIN’s Employee Handbook and confidentiality agreement prior to working with participants or having access to their confidential information.
These forms must be signed annually thereafter.
All employees must complete the DDA background check prior to the first day on the job.
All DVR contract employees who serve and have unsupervised access to DVR participants must complete a DVR authorization form
When the employee is hired.
Every two years at contract renewal.

5. Access to files is on a professional “need-to-know” basis.
Access is limited to employees providing rehabilitation and direct services to the Employment Services participants.
Employees are required to keep all information contained in participant files confidential.

6. DSHS Requirements
DVR & DDA Contracts

7. SKILS’KIN shall . . .
not use, publish, transfer, sell or otherwise disclose any confidential information gained by reason of DVR contract for any purpose that is not directly connected with performance of services (with the exception of law or personal consent).

8. SKILS’KIN shall….
protect & maintain all confidential information gained against unauthorized use, access, disclosure, modifications or loss.
Employ reasonable security measures, which include restricting access to confidential information.
Employ a DSHS approved method to destroy information.

9. SKILS’KIN shall…. SKILS’KIN shall….
Allow access only to staff that have authorized business requirement to view confidential information.
Physically securing any computers, documents, or other media containing the confidential information.
Ensure the security of confidential information transmitted via fax.
Encrypting and attachments that contain confidential information.

10. Your Responsibility As An Employee

11. Employee Responsibility
Hold confidential information in the strictest of confidence.
You should NEVER share confidential information with unauthorized individuals. This includes family and trusted friends.
Be clear on who has authorization to information. If you are unclear, check the Release form in the file prior to giving out ANY details!
If you are not clear, coordinate with your supervisor before moving forward in your progress.

12. Employee Responsibility
Take utmost care to guard individual privacy.
Do not leave confidential files or paperwork unattended. This includes on the printer!
Secure your electronic devices that may have names of participants and/or any other confidential information.
Be aware of your surroundings. Do not discuss case- related information in public areas. An unauthorized person may overhear your conversation. Confidential information may inadvertently be disclosed.

13. Employee Responsibility
Protect participant anonymity
Honor an individual’s request to keep their personal or service-related information confidential.
Do not disclose information to an employer (or other 3rd party) if it is against the individual’s wishes.
Do not acknowledge a participant in public if you are unsure of how they will feel about it. If you are not certain, do not approach!
You may inadvertently disclose their affiliation or involvement in a program through your actions.

14. Employee Responsibility
And Remember You have a legal obligation to protect confidential information, even after the employment relationship ends.

15. Strictly Prohibited
Unauthorized release of private and confidential information is not allowed under any circumstance with one exception . . .
If it is required by law.
If you are unsure, coordinate with your supervisor or manager prior to moving forward in any form of documentation.

16. What is HIPAA?
Health Insurance Portability & Accountability Act of 1996

17. HIPAA Privacy Rule
National standards established to protect an individual’s medical records & other personal health information.
Sets limits & conditions on requests for participant information without authorization.

18. Purpose of Privacy Rule
Define & limit the circumstances in which an individual’s protected health information may be used or disclosed.
Requires the individual who is subject of the information (or their legal guardian) to provide authorization for disclosure in writing.

19. Protected Health Information
All individually identifiable information held or transmitted by SKILS’KIN (by any means) is protected.
Includes but is not limited to an individual’s past, present or future physical or mental health condition, healthcare provisions.
Includes payment for those provisions that identifies the individual or has the potential to identify the individual (for example, name, address, birthday, SSN, etc.).

20. Why does HIPAA Apply to SKILS’KIN ?
Each day SKILS’KIN employees receive, send, and discuss confidential participant information/records that directly relate to their physical and mental health.
This information, and the participant it belongs to, is specifically protected by HIPAA.
The law requires that all SKILS’KIN employees abide by HIPAA rules & regulations.
The law requires that we inform all participants of their rights under HIPAA prior to or at start of services.

21. Preventative Measures

22. Preventative Measures
Secured area for Confidential Files
Confidential files are kept in a locked room.
Only authorized program employees who have completed and cleared a background check and signed the confidentiality agreement are allowed access.

23. Preventative Measures
File Check-out Process
Employees must check out a participant file by initialing and noting the date and time of check out and return.

24. Preventative Measures
Signed Release Forms
A Release of Information must be signed by the participant (and guardian when applicable) prior to services or upon start of services.
This release shall list all organizations that are authorized to request/receive confidential information.
This form shall be updated annually and any time there is a new person/organization who becomes authorized to request/receive information.

25. Preventative Measures
When a participant (and/or guardian) requests information from there file, a written & signed release must be completed each time.
The request must state specifically the information being requested along with the date and time of the request.

26. What We Have Learned
Privacy & Confidentiality

27. A participant’s information (and their file) is confidential.
SKILS’KIN employees are responsible to uphold confidentiality & secure confidential information. SKILS’KIN policy support this requirement.
DSHS contracts and HIPAA have rules/laws in place to protect a participant’s right to confidential information during service provision.
SKILS’KIN has protective measures in place to secure confidential information and ensure contract requirements & the law is upheld.