It’s Your Call – July 2016

 OSHA: Temporary Employees: Who is responsible for their safety?

It’s summer time and that usually means vacation time, for at least a few lucky employees. Regardless of the season or circumstance, it is common for businesses to hire temporary employees on occasion.  Who is responsible for the safety of temporary employees in your facility? Every worker has a right to a safe work environment, but sometimes there are questions about temporary employees and OSHA.  Does the responsibility for them fall on the staffing agency or the host employer? The answer is, both.

Agencies and practices have specific responsibilities regarding OSHA compliance and temporary employess. The contract provider is responsible for providing general bloodborne pathogen training, appropriate vaccinations, and follow-up evaluations to exposure incidents. The host employer is responsible for providing site-specific training, personal protective equipment (PPE), and control of potential hazards and exposure conditions.  Often these items are outlined in a contractual agreement.  More information can be found in the following link. https://www.osha.gov/Publications/OSHA3735.pdf

HIPAA:  Our office does not have a lot of HIPAA relevant issues. We do file claims electronically, take and send images, but still have paper charts.  Do we really need a HIPAA manual, risk analysis, audits, and compliance training?

Yes. It is important, more now than ever, for medical and dental practices to ensure that they have a robust HIPAA compliance program in place. In 2009, Office of Civil Rights became the agency that enforces HIPAA.  They implemented and conducted a Pilot Audit Program in 2011.  Over 100 covered entities were audited on privacy, security, and breach notification rules.  Fast forward to 2016 and several penalties later, covered entities see the importance of having a good HIPAA compliance program in place.