To: All Principal Investigators
Effective June 16, 2014, we have implemented an Addendum to Policy 3.210 Hiring Options Through RCUH that requires all RCUH employees that handle protected health information (PHI) protected by the Health Insurance Portability and Accountability Act (HIPAA), to be in compliance with HIPAA requirements and the HIPAA policies and procedures of the agency/unit in which they work.
All Principal Investigators (PI) with RCUH employees that handle information protected under HIPAA are responsible for the following:
- Ensure employees are required to receive and do receive training on the handling of PHI in accordance with HIPAA
- Address and disclose the agency/unit’s HIPAA/PHI policies, required regulatory compliance, and any Business Associate or related agency/unit’s policy to the RCUH Human Resources Department
- Provide written assurance to the RCUH Human Resources Department that the PI’s agency/unit has a HIPAA/PHI policy, training, and internal controls that meet all regulatory requirements prior to any RCUH employees being hired into a position exposing them to HIPAA/PHI
- Disclose the contact information of the agency/unit’s Security Officer to the RCUH Human Resources Department
Work with the RCUH Human Resources Department to ensure all employees who work with HIPAA/PHI have the standard verbiage for HIPAA/PHI compliance in their job descriptions:
Policy and/or Regulatory Requirements: As a condition of employment, employee will be subject to all applicable RCUH policies and procedures and, as applicable, subject to University of Hawaii’s and/or business entity’s policies and procedures. Violation of RCUH’s, UH’s, or business entity’s policies and/or procedures or applicable State or Federal laws and/or regulations may lead to disciplinary action (including, but not limited to possible termination of employment, personal fines, civil and/or criminal penalties, etc.).
Must complete University of Hawaii’s and business entity’s training relating to HIPAA/PHI privacy and security relating training as soon as possible but not later than the first six (6) months of the new hire probation period. Must maintain a current status on University and/or business entity’s training requirements.
A post offer criminal background check.
All RCUH employees that handle information protected under HIPAA are responsible for the following:
- Required to follow the HIPAA policies, procedures and training requirements of the agency/unit for which they are employed
NOTE: The RCUH will not employ staff in projects that do not have a policy, training or internal controls for compliance with HIPAA/PHI regulations.
Please see Policy 3.210C RCUH Employee Positions Affected by HIPAA Rules for Medical Records, Addendum to the RCUH 3.210 Hiring Options Through RCUH, effective June 16, 2014, for more details. If you have any questions regarding this policy or need to have your current employee’s job description updated, please contact the RCUH Human Resources Employment Department via email at firstname.lastname@example.org.
RCUH Human Resources