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Policy 11: Policy on Workforce Sanctions for Violations of HIPAA Policies and <br /> Procedures <br /> North State Medical Transport <br /> Policy on Workforce Sanctions for Violations of HIPAA <br /> Policies and Procedures <br /> Purpose <br /> North State Medical Transport is responsible under the Health Insurance Portability and <br /> Accountabi|ityActof199G ("H|PAA")toadnministeroppropriatesanctionstoitsvvorkforce <br /> members who violate the HIPAA policies and procedures of the organization. This policy <br /> outlines our approach to violations of our HIPAA policies and procedures and emphasizes the <br /> fact that North State Medical Transport takes any breach of our policies and procedures very <br /> seriously. <br /> Scope <br /> This policy applies to all North State Medical Transport staff members, including those <br /> staff members who may learn of patient information indirectly, and even if use of this <br /> /,- <br /> information is not part of the staff member's responsibilities with North State Medical <br /> Transport. <br /> NOTE: Any sanctions under this policy or any other policy will not apply to staff members who <br /> 1) file a complaint with the federal government about potential HIPAA violations, 2)testify <br /> assist, or participate in an investigation or compliance review proceeding or official government <br /> proceeding investigating HIPAA issues, and 3) oppose any actions by North State Medical <br /> Transport that are unlawful under HIPAA, when that opposition is made with the good faith <br /> belief that North State Medical Transport was violating HIPAA (as long as any opposition or <br /> filing of a complaint did not result in improper disclosure of PHI) <br /> Procedure <br /> I. North State Medical Transport will implement sanctions that are to be used when any <br /> staff member fails to comply with or violates our HIPAA policies and procedures. <br /> 2. Sanctions will be administered in a progressive manner, wherever possible. North State <br /> Medical Transport will administer sanctions to the degree necessary to correct improper <br /> behavior and to ensure the protection of patient privacy. The nature of the PHI involved <br /> in the incident will be considered. <br /> (EXAMPLE: A first time violation where an employee revealed PHI to another staff <br /> member without any need to know may receive a verbal counseling or written warning, <br />