Why Covered Entities Should Provide HIPAA Training to All Members of the Workforce
The provision of HIPAA training is not only a regulatory requirement. It is also an investment. Effective HIPAA training reduces the risk of costly violations, strengthens patient trust, improves workplace efficiency, and enhances organizational resilience against cyber threats. But what determines effective HIPAA training?
Complying with the Minimum Training Requirements is Not Enough
In most cases, complying with the minimum HIPAA training requirements is not enough to see a return on investment. This is because the HIPAA Privacy Rule requires covered entities to implement policies and procedures with respect to Protected Health Information (PHI) and train members of the workforce on the policies and procedures that apply to their functions.
This approach to HIPAA training has the potential to leave gaps in knowledge for workforce members with incidental access to PHI. It can also result in policies and procedures being misinterpreted or applied inconsistently if training is provided out of context of HIPAA, or compliance shortcuts being taken “to get the job done” when the purpose of policies and procedures is not understood.
Gaps Can Impact the Effectiveness of Security Awareness Training
Gaps in HIPAA knowledge and a lack of understanding can also impact the effectiveness of security awareness training. The HIPAA Security Rule requires security awareness training to be provided in accordance with the General Security Standards. These require covered entities to protect against reasonably anticipated uses and disclosures of PHI not permitted by the HIPAA Privacy Rule.
Without a basic knowledge of HIPAA, the potential exists for workforce members to disengage from HIPAA-focused training. This may not only result in avoidable HIPAA violations and data breaches, but it may also create a false sense of security among team leaders who believe their teams are trained, when in reality they lack the foundational understanding to apply security practices correctly.
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Addressing Issues with the Minimum HIPAA Training Requirements
The way to address the issues with the minimum HIPAA training requirements is to provide a general HIPAA training course to all members of the workforce. A course of this nature can help explain what PHI is, why it needs protecting, and the consequences of disclosing PHI impermissibly in terms of the impact a loss of patient trust can have on the provision of healthcare.
The course should also explain what uses and disclosures of PHI are permitted, when conditions or restrictions apply to permitted uses and disclosures, and the importance of verifying the identities of individuals requesting access to PHI. It may also be beneficial to explain patients’ HIPAA rights to avoid scenarios in which a complaint is escalated to the HHS’ Office for Civil Rights due to a misunderstanding.
A general HIPAA training course can also enhance the effectiveness of security awareness training. With a better understanding of why audit trails are necessary, workforce members will better understand why it is important not to share passwords, use unsecure services for communicating ePHI, or download unsanctioned apps. They will also understand why it is necessary to log out of systems when they have finished using them.
The Benefits of Providing HIPAA Training to All Workforce Members
The provision of general HIPAA compliance training program mitigates the risk that a member of the workforce with incidental access to PHI inadvertently discloses PHI due to a lack of knowledge. For example, if an inexperienced member of the environmental services team identifies a celebrity entering a healthcare facility, they will be less likely to share that information impermissibly on social media when their shift finishes.
If a “behind-the-scenes” employee is asked about the wellbeing of a patient by a hospital visitor, they will know to verify the visitor’s identity, confirm the patient has not objected to directory disclosures, and only disclose the minimum permissible PHI. These processes are not necessarily included in all policy and procedure training or explained to employees who do not have public-facing roles.
If the member of the medical team needs to communicate the condition of a patient to a colleague, they will know not to communicate PHI with the colleague via WhatsApp. While sharing PHI with a colleague for healthcare purposes is a permissible disclosure of PHI, the use of a WhatsApp to share the information is a violation of HIPAA because WhatsApp does not support audit trails.
Why Individual Knowledge Testing is Vital for HIPAA Compliance
Testing individual workforce knowledge is vital for HIPAA compliance because test results verify that workforce members understand the training content or reveal where additional training is required. Individual testing increases the likelihood of policies and procedures being understood and applied consistently and eliminates any false sense of security that team members are HIPAA-aware.
The output from individual testing not only demonstrates the effectiveness of the training but can also be used as documentation for regulators to show that the organization is making a good faith effort to comply with HIPAA. Testing individual workforce knowledge also transforms HIPAA training from a passive exercise into a measurable assurance that workforce members have absorbed the training, and that they are more likely to apply it in their day-to-day functions.
HIPAA Training for Employees Our training provides employees with a clear and practical understanding of what to do and why in real-world HIPAA scenarios. The Gold Standard in HIPAA Training by The HIPAA Journal Team HIPAA Training for Employees Our training provides employees with a clear and practical understanding of what to do and why in real-world HIPAA scenarios. The Gold Standard in HIPAA Training by The HIPAA Journal Team Lessons Cover Emerging Issues Like AI Tools | CEUs & Certificate | Completion Tracking | HIPAA Training for Individuals
HIPAA Training
For Covered Entities
Our HIPAA training for employees provides staff with a clear and practical understanding of what to do and why in real-world HIPAA scenarios.
The Gold Standard in HIPAA Training
by The HIPAA Journal Team
