Orange County NC Website
but if a first violation resulted in revealing PHI to someone who was not a staf member <br /> or business associate, a suspension may be warranted.) <br /> 3. Progressive sanctions may include the following: <br /> a. Remedial HIPAA training and education <br /> b. Informal verbal counseling <br /> c. Formal verbal counseling with written documentation of the counseling <br /> d. Written warning <br /> e. Suspension <br /> f. Termination or expulsion from North State Medical Transport <br /> 4. Staff members have an affirmative duty to report to management or the HIPAA <br /> Compliance Officer any suspected violation of our HIPA policies and procedures. <br /> S. Staff members shall be educated about this policy and the serious nature of violating <br /> our HIPAA policies. Staff members will be made aware of the potential sanctions that <br /> may occur, and will be made aware of any changes to this sanction policy. <br /> 6. A record of individual staff member sanctions will be kept in the respective staff <br /> member's file. Adherence to our HIPAA policies may also be considered as part of the <br /> staff member's performance evaluation. <br /> 7. In the event of a suspected or reported violation of our HIPAA policies, the HIPAA <br /> Compliance Officer will initiate an objective and comprehensive investigation that will <br /> include: <br /> a. Interviews of potential witnesses <br /> b. Interviews of the alleged violator <br /> c. Preparation of an investigative report <br /> d. Presentation of the report to management with recommendations for sanctions (if <br /> any) or changes in our policies or practices <br /> 8. At all times, whenever there is a suspected violation of our HIPAA policies or other <br /> breach of privacy, the HIPAA Compliance Officer will recommend immediate action to <br />