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How Should HIPAA Compliance Training for Employees be Provided?Ĭovered Entities and Business Associates have several options when it comes to providing HIPAA compliance training for employees. As a guide, this article on the HIPAA Training Requirements includes examples of HIPAA compliance training. This implies the content of HIPAA training will depend on what policies and procedures the Covered Entity has developed, and what policies and procedures are relevant for each employee to carry out their functions in compliance with HIPAA. The HIPAA Privacy Rule requires each Covered Entity to develop policies and procedures designed to comply with the Rule´s standards and implementation specifications and “train all members of its 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”. What HIPAA Training Should be Provided to Employees? Therefore, Business Associates only need to implement a security awareness and training program as required by the Security Rule – ensuring that all members of the workforce receive HIPAA training regardless of their role or function. However, whereas the HIPAA Security Rule applies to Covered Entities and Business Associates, the HIPAA Privacy Rule only applies to Covered Entities. That means not only employees, but also agency staff, consultants, and contractors regardless of the level of interaction with PHI – even if they have no contact with PHI at all. Both the HIPAA Privacy Rule ( 45 CFR § 164.530) and the HIPAA Security Rule ( 45 CFR § 164.308) stipulate training should be provided to all members of the workforce.
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The first issue to resolve is straightforward. This blog aims to clarify the regulations relating to employee training. The degree of flexibility can create misunderstandings about which employees require training, what training should be provided, how training should be provided, and when training should be provided. The regulations relating to HIPAA training for employees are deliberately flexible because of the different functions Covered Entities perform, the different roles of employees, and the different level of access each employee has to Protected Health Information (PHI).
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