Question Employee vaccine records

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Pendleton, OR
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I have a compliance related question, our site is going through some system updates and recently or Clinical Applications Coordinator attended a systems training that covered a section regarding employee vaccine records and confidentiality.

During this training, it was relayed that staff receiving services including vaccines could not be in the same database that is used in the clinic; and services could not be billed out to insurance. In addition, that the clinic should adopt paper documentation for all staff. Our facility is a 638 tribal facility and provides vaccinations to staff that would otherwise be ineligible for care in our setting.

Our Clinical Applications Coordinator stated this was an OSHA Regulation that services rendered to an employee in our clinic could not be documented in our Electronic Heath Records even though all staff signs a consent and new patient paperwork to have charts created upon hire.

I cannot find any supporting OSHA regulation to confirm this information, only supporting information I found was related to injury or exposure, which this topic is unrelated to.

Thank you,
Heather Dominguez CPCO, CFPC
 
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I couldn't find any specific OSHA information related to your question either, but I did find some related information under the CDC's "Management of Healthcare Personnel Health Records." Under the section, "Confidentiality and security of HCP health information," the CDC explains why its best to avoid keeping HCPs info with patient info. OSHA and records retention are referenced by the CDC as well as HIPAA.

You may also want to check your local and state requirements on separating patient and HCP records. I hope this answers your question.

Here's the link for more information: https://www.cdc.gov/infectioncontrol/guidelines/healthcare-personnel/health-records.html#ref9.

Best,

Kristin J. Webb-Hollering
Development Editor
Medicare Compliance & Reimbursement
Health Information Compliance Alert
Part B Insider

AAPC
 
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