Message from the Compliance Officer


As you are now providing service from home, I am sure you have encountered new and unique challenges, especially around dealing with privacy and protected health information (PHI). Over the last two weeks, the Office of Civil Rights (as part of the U.S. Department of Health & Human Services) empowered essential health workers to serve patients during this public health emergency by providing new tools for service delivery and publishing clear instructions around management of PHI.

At this point you have already received guidance from your supervisor on how to conduct telehealth services, as well as how to best protect privacy while working from home. If you have not received this guidance, or you do not understand the guidance you did receive, please reach out to your supervisor, Division Director, or an Operations Committee member for additional information.

I want to remind you of a few important privacy rules during this period:

  • Staff should not be storing any member information on their personal devices (phones, laptops, desktop computers). This is why you are being required to handwrite documentation. I truly do understand the inconvenience, and appreciate your cooperation with this important procedure.
  • Telehealth is to be completed in private settings. HIPAA laws have always directed us to “do the best we can”, and that is no different now. You and your members can protect privacy by moving to an area away from others, lowering your voices, and/or not using speakerphone.
  • Although the methods by which you handle member information has changed to allow for remote work, the expectation of responsibility and ethical management of this information has not changed.
    • You are expected to protect member information from accidental disclosure.
    • You may not use member information for purposes other than providing service.
    • Member information is not to be used for invasions of privacy or any other criminal act.
    • You are not permitted to use any “public facing” communication systems for telehealth (e.g. Facebook Live, TikTok, Slack). The methods by which you have been instructed to provide telehealth (individual call or group conference call using Wedge lines) is permitted.

This is a new and challenging time for us all. We are all figuring this out together, and each one of us are doing the best we can. I appreciate your hard work, and your dedication to the service of others. On the other side of this pandemic, we will all be stronger as a result of the challenges that we are facing now – and that is a beautiful thing to look forward to.

If you have any questions, you are welcome to contact me directly:

Take care and be well,

Jessica Griffith, MSS, LCSW, CPRP

Vice President, Compliance & CQI