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HIPAA training for dental offices can be more complex than “mainstream” HIPAA training programs due to the need to cover multi-tasking employees, state licensing requirements, and the disposition of clients attending dental offices. Nonetheless, it is important that the basics of HIPAA are still included in HIPAA training programs for dental office employees.
As most dental offices are required to comply with state and federal e-prescribing regulations, most dental offices automatically qualify as HIPAA Covered Entities because they process HIPAA-covered transactions electronically. Consequently, all members of a dental office´s workforce are required to comply with applicable provisions of the Privacy, Security, and Breach Notification Rules.
In order for all members of the workforce to comply with the HIPAA Rules, it is important for employees to know what the Rules are and how they apply in day-to-day duties. Therefore, dental offices should provide training on the policies, procedures, and mechanisms put in place to ensure the privacy, confidentiality, integrity, and availability of Protected Health Information (PHI).
What are the Training Requirements for Dental Offices?
The basic HIPAA training requirements for dental offices are the same as for any HIPAA Covered Entity. Dental offices must train members of the workforce on the policies and procedures as “necessary and appropriate for the members of the workforce to carry out their functions within the Covered Entity”. Dental offices should also implement a security and awareness training program for all members of the workforce regardless of their roles within the organization.
However, the way in which dental offices are staffed – especially smaller practices – can complicate HIPAA training dental office programs. This is because – for example – it may be the case that a receptionist also has the roles of dental assistant and payment processor, meaning that an individual employee may have to understand HIPAA compliance from multiple perspectives. Even in larger dental practices it is not unusual to find employees multi-tasking – i.e. receptionists processing payments.
Not only is multi-tasking more common in dental offices than in other HIPAA-covered organizations, but the nature of the roles may mean the focus of HIPAA training dental office programs needs to be adjusted to account for:
- The increased number of scenarios in which incidental disclosures can occur – for example when appointment reminders are left or when calling patients from a waiting room.
- The increased number of times in which treatments are paid for privately – for example when a parent pays for their child´s treatment rather than claim the cost via insurance.
- The increased use of Business Associates unfamiliar with HIPAA Rules – for example finance companies that fund a course of treatment over an extended repayment period.
It is important to remember that HIPAA preempts state laws unless a state offers better protection for healthcare data or improves HIPAA´s patients´ rights provisions. It is also important to remember when complying with the HIPAA training requirements for dental offices that clients often only attend a dental office when they are in extreme discomfort. Therefore, employees need to know about exceptions to HIPAA and how to compliantly manage patients who are in too much pain to give consent or care about NPPs.
How to Organize a HIPAA Training Dental Office Program
Naturally it is important for dental offices to comply with the HIPAA training requirements, but it can be useful to provide all members of the workforce with a basic understanding of HIPAA before overloading them with policies and procedures that apply in certain circumstances – and security mechanisms that apply in others. The basic understanding of HIPAA will help employees put policy and procedure training in context, help with retention, and mitigate the risk of HIPAA violations.
There are many different types of “off-the-shelf” courses suitable for providing employees with a basic understanding of HIPAA. By completing a HIPAA training course, employees will be in a better position to absorb training on the dental office´s HIPAA policies and procedures, understand why security mechanisms are in place, relate to state licensing requirements that may preempt HIPAA, and address the dispositions of clients attending the dental office in a HIPAA-compliant manner.