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UW-Madison School of Nursing
Health Insurance Portability And Accountability Act
(HIPAA)
Privacy Rule Training For Students

School of Nursing Policy on Disciplinary Action For Violations of HIPAA By Students

As a student in a clinical training program of the University of Wisconsin-Madison, you are required to learn about and abide by the health information privacy requirements of a federal law called HIPAA. Students will be informed of the requirements of HIPAA through required training they will undergo when admitted to the nursing program. Reminders of these requirements occur at the course level and include a Statement on the Privacy of Patient Information, developed in the School, which is printed in each course syllabus.

Violations of the privacy requirements of HIPAA will be handled recognizing the categories of violations below.

Type of Violation

Process

Corrective Action

Notificaiton

I. Inadvertent or accidental breaches of confidentiality that may or may not result in the actual disclosure of patient information. For example, sending/faxing information to an incorrect address.

Discussion between instructor and student.

Re-education and/orprocess improvement.

Verbal or written communication between instructor and student only.

II. Failure to follow existing policies/procedures governing patient confidentiality. For example, talking about patients in areas where others might hear, failure to obtain appropriate consent to release information, or failure to fulfill training requirements.

Discussion between instructor and student.

Re-education and/or process improvement.

Verbal or written communication between instructor and student only.

III. Repeat Offense of Type I or II Violation.

Discussion between instructor and student.

May range from: a) Re-education and process improvement; to disciplinary sanctions such as: b) Repri-mand; c) Removal from clinical site; or d) Probation or other disciplinary action.

Verbal or written communication between instructor and student may be included in student record and sent to Dean of Students Office.

IV. Inappropriately accessing a patient's record without a need to know. For example, accessing the record of a friend or family member out of curiosity without a legitimate need to know the information.

May range from discussion between instructor and student to Associate Dean convening a committee to address corrective action.

May range from: a) Re-education and process improvement; to disciplinary sanctions such as: b) Repri-mand; c) Removal from clinical site; or d) Probation or other disciplinary action.

1) SON Student Record
2) UW Madison Privacy Officer
3) Dean of Student's Office

V. Accessing and using patient information for personal use or gain or to harm another individual.

Notification to Associate Dean. Associate Dean convenes committee to address action.

May range from: a) Removal of student from course; to disciplinary sanctions such as: b) Probation; c) Suspension; or d) Expulsion.

1) SON Student Record
2) UW Madison Privacy Officer
3) Dean of Student's Office

NOTE: The School of Nursing Grievance Procedure is available to students who believe they have been treated inequitably.
  Updated November 3, 2006 . For feedback, questions, or accessibilty issues contact dbhopke@wisc.edu.
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