HIPAA Training for Physical Therapists

HIPAA training for physical therapists - HIPAA Guide.net

HIPAA training for physical therapists and physical therapy assistants is much the same as HIPAA training for any healthcare professional who works for a HIPAA covered entity or business associate inasmuch as they must receive training on the organizationโ€™s privacy policies and procedures, and participate in a security awareness and training program.

Not all physical therapists and physical therapy assistants are required to receive HIPAA training. Many do not qualify as members of a HIPAA covered entityโ€™s workforce because they work in a private clinic that does not qualify as a HIPAA covered entity, work in a school, or work in a non-healthcare setting (i.e., sports therapy) in which HIPAA training is not required.

For those that do work for a HIPAA covered entity, qualify as a HIPAA covered entity in their own right, or provide services to or behalf of a HIPAA covered entity as a business associate, HIPAA training for physical therapists and physical therapy assistants consists of privacy policy and procedure training, security awareness training, and any other necessary HIPAA training.

Privacy Policy and Procedure Training

The Administrative Requirements of the HIPAA Privacy Rule (ยง164.530) require HIPAA covered entities (and business associates โ€œwhere providedโ€ by ยง164.102) to develop and implement policies and procedures with respect to Protected Health Information (PHI) that are designed to comply with the requirements of the HIPAA Privacy Rule and Breach Notification Rule.

All members of a covered entityโ€™s workforce must be trained on the policies and procedures โ€œas necessary and appropriate for the members of the workforce to carry out their functions within the covered entityโ€. Further privacy training must be provided if there is a material change to a policy or procedure that affects a workforce memberโ€™s functions.

In addition to the required HIPAA training for physical therapists and physical therapy assistants, it is advisable to provide HIPAA refresher training at least annually. The provision of HIPAA refresher training demonstrates a โ€œgood faithโ€ effort by an organization to be HIPAA compliant and supports compliance with privacy policies and procedures by workforce members.

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HIPAA Security Awareness Training

Because HIPAA security awareness training has to be provided in accordance with the General Requirements of the HIPAA Security Rule (ยง164.306), this type of HIPAA training for physical therapists must take into account reasonably anticipated threats to the security and integrity of electronic PHI, and reasonably anticipated disclosures of PHI not permitted by the HIPAA Privacy Rule.

For this reason, HIPAA security awareness training must be developed on the results of a risk analysis that identifies reasonably anticipated threats and impermissible disclosures relevant to the nature of work being performed. It is not possible to provide โ€œgenericโ€ security awareness training in order to comply with HIPAA as this type of training does not account for the nature of work being performed.

In addition, it is important to remember the HIPAA Security Rule training standard requires HIPAA covered entities and business associates to implement a security awareness training program. HIPAA security awareness training should not be regarded as a one-off or periodic exercise, and should be updated as necessary to mitigate new threats or other events that risk the confidentiality, integrity, and availability of electronic PHI.

Other HIPAA Training for Physical Therapists

In addition to material changes to policies and procedures, there are several types of events that can trigger HIPAA training for physical therapists. These include when training is imposed as a workforce sanction for a violation of HIPAA, when the organization receives a privacy complaint from a client, and when a new technology is implemented to better safeguard electronic PHI from reasonably anticipated threats or impermissible disclosures.

HIPAA training for physical therapists can also be integrated with other non-HIPAA training. For example, the privacy of PHI could be a factor in CMSโ€™ emergency planning training, OSHA safety training, or state mandated training to counter sexual harassment and/or violence in the workplace. In some circumstances, HIPAA training for physical therapists can also award CEUs to help meet licensing bodiesโ€™ continuing education requirements.

Individuals and organizations that would like to know more about integrating HIPAA training for physical therapists into non-HIPAA training are advised to seek independent compliance advice. It is recommended you seek advice from a compliance professional familiar with the licensing and training requirements in each jurisdiction, as many states have unique regulations relating to workplace safety that affect the content and frequency of training.

About Liam Johnson

Liam Johnson has produced articles about HIPAA for several years. He has extensive experience in healthcare privacy and security. With a deep understanding of the complex legal and regulatory landscape surrounding patient data protection, Liam has dedicated his career to helping organizations navigate the intricacies of HIPAA compliance. Liam focusses on the challenges faced by healthcare providers, insurance companies, and business associates in complying with HIPAA regulations. Liam has been published in leading healthcare publications, including The HIPAA Journal. Liam was appointed Editor-in-Chief of The HIPAA Guide in 2023. Contact Liam via LinkedIn: https://www.linkedin.com/in/liamhipaa/