STAY HOME COMPANIONS HIPAA POLICY

These are the HIPAA compliance policies and procedures followed by Stay Home Companions. All staff at Stay Home Companions are required to read and adhere to all the Stay Home Companions Personal Protection Policies.

HIPAA Definition: HIPAA stands for Health Insurance Portability and Accountability Act.

PHI Definition: PHI stands for Protected Health Information.

NOTICE OF PRIVACY PRACTICES

Policy:

The Notice of Privacy Practices (NPP) is a statement from Stay Home Companions to our clients about how we handle and protect their PHI and their personal information or Personal Identifiers.

Procedure:

We provide the NPP to our clients on or before we provide Stay Home Companions’ services. We receive a signed acknowledgement that they have received a copy of our NPP. We then place the signed acknowledgement into the client’s file.

BUSINESS ASSOCIATES

Policy:

We obtain Business Associates (BAA) from all companies whom we hire for support services that may come into contact with PHI or PI on our behalf.

Procedure:

We obtain a BAA or contract from all companies that may have access to PHI or PI, such as computer software and support services. A business associate is not a member of our workforce.

RETENTION OF RECORDS

Policy:

We retain all HIPAA related documents for 6 years

Procedure:

We have retained all HIPAA related documents for 6 years. This applies to:

Policies & Procedures

Notice of Privacy Practices

Business Associate Agreements

Authorizations

Audit Records

We destroy records by burning or shredding to ensure that there is no allowance for disclosure of PHI or PI. We do not provide medical care and do not obtain or retain any medical records.

USES AND DISCLOSURE OF PHI OR PI

Policy:

SHC uses and does disclose PHI or PI without the client’s authorization for client care purposes or as required by law. Other disclosures require the authorization of the clients unless required by law, such as instances of:

Domestic Violence

Abuse or Neglect

Court Order or Subpoena

Threat to Public Health

AUTHORIZATION

Policy:

SHC requires signed client authorization for non-insurance, billing related or required by law disclosures.

Procedure:

We require signed authorization by clients before disclosure of PHI or PI that in non-insurance, billing or required by law related. The authorization will specify: Purpose of Disclosure, Expiration Date, Specific Purpose

ACCOUNTING FOR USES AND DISCLOSUURE

Policy:

SHC clients have the right to request an accounting of all PHI and PI disclosures that are non-insurance, billing or required by law.

Procedure:

Our clients have the right to request an accounting of all disclosures that are non-insurance, billing or required by law.

MITIGATION

Policy:

If SHC accidentally discloses PHI or PI for a reason that is not allowed or required under the Privacy Rule and that disclosure is apt to cause harm to the client, the HIPAA Compliance Officer must inform the client of the disclosure.

Procedure:

If we accidentally disclose PHI or PI for a reason that is not allowed or required under the Privacy Act and that disclosure is apt to cause harm to our clients, the HIPAA Compliance Officer must inform the client of the disclosure. The HIPAA Compliance Officer must act necessary to repair the harm done by the disclosure and change any office or staff procedures that allowed the disclosure.

FAXES AND EMAILS

Policy:

It is the responsibility of SHC to make sure faxes and emails from SHC include an adequate privacy warning.

Procedure:

All faxes and emails from our office will include the following privacy warning:

PRIVELEGED AND CONFIDENTIAL: This document and the information contained herein are confidential and protected information. This message is intended only for the use of the Addressee(s). If you are not the intended recipient, you are hereby notified that dissemination or copying of this information is prohibited. If you received this communication in error, please erase all copies of the message and its attachments and notify the sender immediately.

MARKETING

Policy:

SHC will obtain the client’s authorization for the use of their photo, PHI or PI for marketing purposes.

Procedure:

If we intend to use photos or any PHI or PI for commercial purposes, we will get signed authorization from our clients.

OFFICE SAFEGUARDS

Policy:

SHC protects their client PHI or PI with reasonable safeguards.

Procedure:

We protect our clients PHI or PI by:

Keeping PHI or PI from unauthorized view in our office

Keeping doors locked after hours

Using passwords on computers

Keeping fax machines from an unauthorized view

COMMUNICATION SAFEGUARDS

Policy:

SHC is cautious when speaking about our clients. Our staff are encouraged to be cognoscente of PHI and PI in their conversations and communications.

Procedure:

We are cautious when speaking about our clients in conversations and communications with anyone in and outside of work. We strive to protect PHI and PI in all forms of communication verbally and electronically. All staff are aware of HIPAA guidelines and protecting client information.

LEGAL ISSUES

Policy:

Cases of abuse and neglect are serious issues. We are permitted by law to report suspected cases of abuse and neglect.

Procedures:

SHC will report suspected cases of abuse and neglect as allowed by HIPAA regulations. Staff will report suspected abuse and neglect to management and the HIPAA Compliance Officer will report the issue appropriately.

SUPOENAS & LAW ENFORCEMENT

Policy:

We disclose PHI or PI in response to subpoenas and law enforcement warrants as established by the Privacy Rule.

Procedure:

If we receive a subpoena or warrant request, the HIPAA Compliance Officer will respond after receiving satisfactory assurances the subpoenas or warrants are appropriate.

WORKFORCE TRAINING

Policy:

SHC acknowledges that both ongoing and annual training is required in order to maintain ongoing HIPAA compliance.

Procedure:

We train our workforce upon hiring and on an annual basis to maintain HIPAA compliance. The HIPAA Compliance Officer is responsible for ensuring all members of the SHC staff participate in training and maintain a training log in the SHC HIPAA Compliance Manual.

TRANSACTIONS AND CODE SETS

Policy:

SHC obtains assurance from their software vendor that they are HIPAA compliant.

Procedure:

We assigned BAA from our software vendor as an assurance they comply with HIPAA standards.

CODE/BILLING

Policy:

SHC bills all companions’ services accurately and appropriately.

Procedure:

We strive to bill all companion services we always render accurately and document appropriately.

STAY HOME COMPANIONS

POLICY & PROCEDURE ACKNOWLEDGEMENT

The Stay Home Companions Policies and Procedures (P&P’s) are important to understand and follow. They are intended to provide you with our company HIPAA guidelines and what procedures to follow to be in compliance.

Because HIPAA compliance guidelines may change from time to time, the SHC P&P’s may be changed at any time. SHC will provide you with ongoing updates and annual HIPAA training to keep you informed.

Please read the following statements and sign below to indicate your receipt and acknowledgement of these P&P’s.

I have received and read a copy of SHC’s Policies and Procedures. I understand that the policies and procedures described in it are subject to change as the HIPAA guidelines change.

I further understand that I am required to follow the P&P’s and agree to protect our client’s information in all forms of communication.

Employee’s Printed Name: ______________________________________________Position: ______________________

Employee's Signature: __________________________________________________ Date: ________________________

The signed original copy of this acknowledgement should be given to your manager. It will be filed in our HIPAA Compliance Manual.