Is Your Immunization Tracking Program HIPAA Compliant?

Students participating in clinical rotation or residency programs in hospitals and health systems must provide immunization histories to meet student screening requirements. As a college or university, you help students fulfill their requirements so they can have a positive experience and continue their medical training.

According to the National Resident Matching Program (NRMP), in 2020 alone, there were over 37,000 residency positions filled by medical students, with many more participating in rotation programs. When you’re tracking numerous immunization records for large numbers of students moving into various clinical departments and hospital systems, an immunization tracking system can maintain important health and immunization information in a secure and HIPAA-compliant manner.

HIPAA Requirements for Immunization Tracking

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 was established to regulate the exchange of private health information, including student immunization data. HIPAA prompted the development of national standards to address the use and disclosure of individual health information, including the establishment of standards for individual privacy rights. 

To stay in compliance with HIPAA requirements, healthcare organizations and educational institutions must keep student health and immunization records confidential and secure at all times. HIPAA-compliant safeguards prevent the improper disclosure of student health information and include the following actions:

• Keeping patient authorization forms current and providing proper disclosures to students
• Giving students the option to restrict disclosure of private health information to certain entities
• Providing students with the option of receiving an electronic copy of their healthcare records, when requested
   

The Risks of Non-Compliance

The risks of failing to keep student health information private can result in hefty HIPAA fines. As of May 2020, the Department of Health and Human Services (HHS) Office for Civil Rights (OCR), which enforces HIPAA, has received over 237,000 HIPAA complaints and imposed civil monetary penalties totaling over $116 million. Even in instances where you’re unaware of an action resulting in a HIPAA violation, you can be subject to civil penalties reaching into the thousands of dollars. Individual offenders can face criminal penalties and jail time.

Other organizations and individuals can also be sued for HIPAA violations. In addition to healthcare organizations and universities, all entities and individuals involved in the non-compliant exchange of information can be subject to penalties and lawsuits, including related vendors, insurance companies, and testing labs.

A non-compliant immunization tracking program poses other risks to colleges and universities who help to collect student health information. University actions leading to a health information data breach can result in warnings during an audit, and it can put contracts between universities and health systems at risk. Severe instances of poor compliance can also lead to loss of credentialing for a clinical program or university.

Students can become the victim of poor HIPAA-compliance. Data breaches or improper communication of personal health information results in a violation of privacy rights. In addition, any delays caused by HIPAA non-compliance, for example, improperly communicating or accessing immunization data, can result in a student potentially missing clinical participation deadlines.

The Benefits of a HIPAA-Compliant Immunization Tracking Program

The importance of a compliant immunization tracking program extends beyond avoiding the risks of non-compliance. The benefits of compliance help you manage your immunization program more efficiently and improve communication between all involved parties.

A key benefit of a compliant tracking program is faster turnaround times. Instead of spending time on back and forth with students to obtain health records, a compliance partner working on your behalf, such as ImmuniTrax by VerifyStudents , can send and track messages to students through a HIPAA-compliant messaging center. You’ll no longer need to work with Excel spreadsheets or legacy systems, which can both become quickly outdated. With the click of a button, and you can track student immunization status in real-time. 

No one wants the personal information entrusted to them to end up in the hands of an unauthorized person or circulating in the public domain. Achieving HIPAA compliance in immunization tracking means that all health and immunization reports are conveyed in accordance with HIPAA data security rules. Compliance also gives administrators and program managers a guide for managing student health data. It reduces the opportunity for program activities to go off-course due to a lack of regulatory guidance.

Identifying Compliance Gaps in Your Immunization Tracking Program

Though you may not have faced penalties, fines, or lawsuits, there may be compliance gaps in your current program you need to address. In fact, your program doesn’t need to be falling apart for there to be sizable opportunities for improvement. 

To determine if your immunization tracking program has compliance gaps, take the following steps:

1. Determine if all staff members with access to student health information are HIPAA-trained. It’s essential to make sure you understand the HIPAA requirements, as well as others who handle student health information on your behalf.
2. Review the technology you use to track immunization data. Your immunization tracking system requires controls to restrict access to authorized individuals. You could have gaps in your tracking technology if it lacks secure, cloud-based tools to help you properly collect and store student health information.
3. Look for instances of sharing student health information through unsecured channels. Without compliance controls in place, it’s easy to send a seemingly benign piece of health information over email, fax, or telephone. However, transmitting private health information using those methods can pull your program out of compliance. 
    

Building a HIPAA-Compliant Immunization Tracking System

Missed deadlines, manual processes, and compliance gaps aren’t the necessary evils of busy immunization program management. Achieving compliance in immunization tracking is possible with the help of available resources and an experienced immunization compliance partner. 

To build a compliant tracking program, seek a partner with the following characteristics:

• Utilizes an integrated immunization tracking system to help you collect and organize student health data
• Successfully completed an external audit of its compliance programs and activities
• Has been certified in meaningful use standards for electronic health records
• Provides monthly HIPAA training for all employees
• Adheres to strict data security standards 
• Offers compliance services to educate and train individuals in your organization on proper actions to secure private health information
• Helps you conduct periodic reviews of your immunization tracking program for ongoing compliance
   

An Integrated Immunization Tracking Solution for Your Needs

Immunization tracking compliance saves time for students, universities, and healthcare organizations. With the help of an integrated immunization tracking system, you can cut down on manual tracking of health records and keep student health information safe at the same time. 

When you incorporate HIPAA-compliant immunization tracking into a total compliance and student screening solution, you have the tools to meet the screening requirements of a broad range of clinical and residency programs. With your student immunization management partner to guide you, you get the benefit of cutting-edge technology and a team dedicated to helping you achieve full program compliance.