Team 27CCentral Columbia Hospital, Scenario D: Technology/Social Media/HIPAA

IntroductionCentral Columbia Hospital (CCH) must address: Human Resource Department structural issues, ineffective communication channels, an undefined social media policy, and potential HIPAA violations. Major Problems Lack of a Comprehensive Social Media Policy

Social media is an emerging trend that is not fully understood. CCH does not have a current social media policy, thus exposing the hospital to potential online issues. Without a set policy in place, CCH employees are unaware of what constitutes inappropriate behavior on social media.

Current Structure of Human Resource DepartmentThe current structure of CCH’s HR dept. is understaffed, reactionary and ill-suited to meet employee needs. Due to the current employee to HR personnel ratio, the HR dept. struggles to manage various employee issues. A positive correlation may exist between employee dissatisfaction and CCH’s current low patient satisfaction scores.

Communication ChannelsIneffective employee communication channels exist at CCH. The Board Chair plays too significant of a role in day-to-day operations, which negatively effects communication channels, and undermines managers’ ability to directly address subordinates’ issues.

HIPAA Violation Upon analyzing the comments made on social media, it is clear, a HIPAA violation has occurred. A HIPAA violation is a serious infraction CCH must address immediately.

Minor Problems Protection of CCH’s Public Image

Negative effects on CCH’s public image may stem from the employee comments made via social media. The comments can be attributed to the absence of a social media policy and overall employee dissatisfaction.

Employee’s Overall Lack of HIPAA Knowledge Considering the careless comments made on social media, it appears CCH employees do not fully understand HIPAA regulations and may require additional training. Even members of the HR dept. have displayed an inability to recognize HIPAA violations.

AlternativesCCH has a variety of alternatives to choose from when addressing the aforementioned problems. The hospital has the option to revise the organizational framework or maintain the current structure. When addressing employee dissatisfaction, CCH may continue using the current meeting structure or encourage more employee discussion during meetings, while also reiterating HIPAA guidelines. In order to improve communication channels, the hospital could empower managers to better handle employees by eliminating improper interactions. In regards to the social media problem, CCH has the option to create a new social media policy, create an umbrella electronic policy within the Code of Conduct, or continue to operate under the current policy. CCH must also decide whether or not to report or ignore the HIPAA violation.Solutions/Implementation CCH should create a new social media policy to provide a clear and consistent message to employees concerning all social media activity. This policy will restrict staff members from accessing any form of social media on site (unless work related), restrict discussion of any CCH

patients/residents, visitors, or employees, and clearly state what constitutes protected health information. Various challenges are associated with implementing a social media policy:

Social media is an emerging trend not fully understood in the workplace. Numerous Federal Acts, State Laws and Regulations protect employees. Social Media activity can occur inside and outside the workplace. Employers may be exposed to public scrutiny via social media.

The implementation of CCH’s new social media policy should be engineered by a newly appointed Vice President of HR. This VP of HR will take some of the current HR manager’s responsibilities and oversee CCH’s entire HR dept., shifting responsibility away from the CFO. Currently, CCH’s HR to employee ratio sits at 1:241. As stated in Schwind (2007), "The basic rule-of-thumb, which says the average ratio is one HR professional for every 100 employees, still holds up for the most part" (Pg.17). It would be beneficial for CCH to hire at least one more HR Assistant to help manage the hospital’s workforce.

CCH should hold individual meetings with the employees who made the comments on social media, inform them a code of conduct violation may have occurred, and express no form of discipline will be pursued. The HR dept. needs to foster an environment of inclusion, where employees can voice concerns, with the assurance positive changes will be made. In addition to encouraging better attendance and participation in employee discussion meetings, the hospital should lay out a comprehensive series of meetings that ensure all employees completely understand what HIPAA regulations require. According to Smith (2013), the HHS states, “We emphasize the importance of ensuring that all workforce members are appropriately trained and knowledgeable about what constitutes a breach and on the policies and procedures for reporting, analyzing and documenting a possible breach of unsecured protected health information” (Pg. 1). Comprehensive meetings will help CCH’s HR dept. become more proactive risk managers and reduce the number of future HIPAA violations.

The disciplinary emphasis regarding the social media comments will focus on the HIPAA violation. Within McBride (2013), Daniel Shay, J.D., draws attention to HIPAA protected health guidelines, stating, “…any information that identifies patients whether it’s a name, a photograph, a description of unique symptoms perhaps accompanied by other bits of patient information…” is considered PHI and is protected by HIPAA (Pg. 56). Based on this information, a violation has occurred, thus the hospital administration must take immediate corrective action.

Irregularities surrounding the communication channels at CCH exist. While Dr. Stiller's interaction and hands on approach with employees is beneficial, his services would be better utilized through focusing on OB-GYN and Board Chair duties. It appears employees are apt to reach out to Dr. Stiller with issues and concerns, instead of using the proper communication channels. Whether intentional or not, his behavior, in part, diminishes the ability of managers to work out issues with subordinates. Dr. Stiller has been an invaluable tool to the hospital for multiple years and should continue to play an important role going forward. In order for the recommendations to gain traction, Dr. Stiller must be on board, particularly during the hiring process of the HR VP. It will benefit CCH if Dr. Stiller encourages employees to voice concerns through proper communication channels.

References

McBride, M. (2013). Social Media Musts. Dermatology Times, 34(1), 52-53,56. Retrieved from

ProQuest.

Schwind, H. (2007). HR Staff Ratio Changing. Canadian HR Reporter, 20(9), 17,20. Retrieved

from ProQuest.

Smith, A. (2013). HIPAA Rule Alters Definition of ‘Breach’. Society for Human Resource

Management. Retrieved from

http://www.shrm.org/legalissues/federalresources/pages/hipaa-rule-breach.aspx