Policy Manual sample
MDT Home Health Care Agency, Inc. ACCESS TO ELECTRONIC HEALTH RECORDS (EHS) POLICY (Electronic Medical Record) PURPOSE: The purpose of the Access to Electronic Health Records Policy (“EHR Policy”) is to establish processes and procedures for permitting agency staff (office/field) members access to and sharing of the Agency’s Electronic Health Records in order to enhance the continuum of health care/data entry to our patients (Agency Computer System). DEFINITIONS: 1. Agency Staff means a Registered Nurse, Licensed Practical Nurse, Registered Therapists (Physical, Occupational, Speech, Respiratory), Therapists Assistant (Physical, Occupational, Speech), Home Health Aide/Certified Nursing Assistant or office staff (all clerical, officials of the Agency). 2. Disclose and Disclosure mean, with respect to Protected Health Information, the release, transfer, provision of, access to, or divulging in any other manner of Protected Health Information outside Agency internal operations. 3. Electronic Health Record (“EHR”) means a repository of consumer health status information in computer processable form used for clinical diagnosis and treatment for a broad array of clinical conditions. EHRs contain Protected Health Information. 4. Information Technology (“IT”) for purposes of obtaining access to Agency EHR includes by way of example: rights, licenses, and intellectual property related to the EHR software; connectivity services, including broadband and wireless internet services; portals; secure messaging capabilities and related services that are used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, or transmission or reception of data or information in any electronic medium to any source. IT for purposes of EHR does not include hardware, including routers or modems necessary to access or enhance connectivity, and operating software that makes the hardware function; storage devices; software with core functionality other than EHR (such as human resources or payroll software or software packages for practicemanagement or billing); or items used to conduct personal business or business unrelated to Agency practice. 5. Protected Health Information (“PHI”) means information, including demographic information, that (i) relates to the past, present, or future physical or mental health or condition of an individual, the provision of health care/data entry to an individual, or the past, present, or future payment for the provision of health care/data entry to an individual; (ii) identifies the individual (or for which there is a reasonable basis for believing that the information can be used to identify the individual); and (iii) is received by Agency from or on behalf of Agency, or is created by Agency. PHI may be contained in other mediums including without limitation, electronic PHI, EHR, paper records, audio, and video recording. 6. Use or Uses means, with respect to PHI, the sharing, employment, application, utilization, examination or analysis of such PHI within Agency’s internal operations. 7. User means individual who will be accessing the electronic systems requested through a unique login and password. 8. Terms used, but not otherwise defined, in this Policy shall have the same meaning as those terms in the Privacy and Security Regulations. POLICY: It is the policy of the Agency to provide access to and share with each field staff and/or office staff who is a member of the Agency’s Staff the Agency’s EHR subject to the provisions and procedures outlined in this Policy. 1. Access 1.1 Each User shall sign and submit a Agency Access Request Form (Exhibit A). Home Health Agency Policies A-172
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