It’s Your Call November 2017

OSHA:  Your local news has just reported an increase in active TB cases. What employee documents should be in place in light of this information?

The CDC recommends an initial baseline TB testing upon hire for employees at risk of exposure which are typically clinical workers. This can be done using one of 2 methods: a two-step skin test or a blood assay. Baseline testing for new hires should be done prior to beginning work at the practice. If an employee is exposed to a patient with active TB, the practice must provide new testing which would then be compared to earlier tests to help determine if the TB transmission occurred in the facility. More information about testing healthcare workers for TB can be found on the CDC website, https://www.cdc.gov/tb/topic/testing/healthcareworkers.htm or by contacting your state TB Control Program.

HIPAA:  A provider has inquired about the safest way to transport a few paper records with protected health information (PHI) between sites. What suggestions would you offer?

Theft is typically the reason for breach of paper records, so physical safeguards are a must when PHI is transported offsite. The provider should not leave the paper charts in plain sight in an unattended vehicle. It is better to leave them locked in the trunk of a car and/or a locked briefcase.  Once the records have reached the final storage location, they should be stored in a locked file cabinet or secured using reasonable safeguards.  Ultimately, the practice is liable if the charts are stolen; it would be a breach of unsecured PHI.