ShelterCare complies with federal regulations as defined in the Health Insurance Portability and Accountability Act (HIPAA) and all State of Oregon rules and regulations regarding the use and disclosure of Protected Health Information (PHI) of the clients/consumers served by ShelterCare. Upon accepting employment with ShelterCare, all employees receive copies of ShelterCare’s Policies and Procedures for Use and Disclosure of Clients/Consumers’ Protected Health Information and sign a confidentiality agreement. An employee is not to disclose or use any ShelterCare confidential client information, either during or after his/her employment unless he/she is authorized to do so. All staff will receive training on privacy policies, procedures and forms within 30 days of hire. It will be the responsibility of the program manager to ensure that new employees are provided with this training.
Confidential information shall be shared with fellow employees when it is relevant to the well-being of the individual or the integrity of the program. Please refer to the confidentiality section in the Statement of Ethical Standards (see below). A key principle related to sharing confidential information is that only the minimum necessary information will be disclosed to fulfill the purpose of the disclosure. Employees who are unsure about the confidential nature of specific information must ask their supervisor for clarification. This Handbook, the client rights and consumer participation statements, the HIPAA policy manual, and the guidelines and protocols particular to each program will provide a comprehensive understanding to the regulations regarding confidentiality and privacy rights for clients/consumers.
Complying with confidentiality requirements and HIPAA rules is critical. Employees must adhere to all rules and regulations at all times. Within ShelterCare, a breach of confidentiality if confirmed, would be a disciplinary matter and depending on the severity of the breach, could result in termination of the employee’s employment, as well as other possible legal actions.
SHELTERCARE CONFIDENTIALITY POLICY
Confidentiality. The agency has written policies to ensure records containing protected identifying information of any individual/family receiving assistance will be kept confidential. ShelterCare has an electronic client record system in place and maintains compliance with federal patient confidentiality law. All passwords and signature passwords are strictly regulated and are not shared with anyone other than the person intended for its use. Employees do not to share their passwords with anyone else or to allow their passwords to be used by anyone else. In addition, for paper files, client confidentiality is protected through a “double lock” system. Files are stored in a locked file cabinet that is within a locked room.
The location of any family violence project will not be made public. ShelterCare does not operate a family violence project.
The location of any housing of any program participant will not be made public except as provided in a preexisting privacy and as provided by law. ShelterCare does have signage at Shankle and Family Housing that identifies the property as an agency property. There is no indication of who lives in residence or what services they receive. ShelterCare publications may list the names and locations of the Shankle and Family Housing programs. None of the scattered site units are identified as program units.