[MCOH-EH] Employee occupational health clinic medical record confidentiality in an EMR

[Timothy Herrick]

It seems to me that if this thinking was carried to its 'logical extinction'  you would not be able to order PEP meds for an exposed worker, under their name;  which would necessitate a potentially damaging situation where their pCp or other providers did not know about the meds they were taking, and could prescribe a non-compatible medication.

We order labs under a computer generated alias, so it resides in the general EMR but only occ health is breaking the code.

From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Davis, Sue
Sent: Tuesday, November 20, 2018 7:56 AM
To: 'MCOH/EH' <mcoh-eh at mylist.net>
Subject: Re: [MCOH-EH] Employee occupational health clinic medical record confidentiality in an EMR

Have you thought about obtaining an annual consent from the employees which specifies which sections are viewable by non-EH (ex: lab, radiology).

Thank you,
Sue Davis MS, BSN, RN, CVRN - BC, NE-BC, CCRN-K
Director, Learning Center & Employee Health
Methodist Health System
825 S 169th St, 175E, Omaha NE 68118
Phone:  (402) 354-5694
Learning Center Fax: (402) 354-5466
Employee Health Fax: (402) 354-8819
sue.davis at nmhs.org<mailto:sue.davis at nmhs.org>
Making life easier, one day at a time :)

From: MCOH-EH [mailto:mcoh-eh-bounces+sue.davis=nmhs.org at mylist.net] On Behalf Of Denece O Kesler
Sent: Monday, November 19, 2018 3:54 PM
To: MCOH/EH
Subject: [EXTERNAL] Re: [MCOH-EH] Employee occupational health clinic medical record confidentiality in an EMR

CAUTION:This email originated from outside of the organization.  Do not click links or open attachments unless you recognize the sender and know the content is safe.


Hi, Pat,
That is what our legal counsel is suggesting-although not for concern regarding us entering the non-employee side, but for other employee's seeing the occupational health side. The only work around identified currently would be essentially what you recommend-that we would have to order tests as if we were a different clinic.
Thanks,
Denece

From: MCOH-EH <mcoh-eh-bounces at mylist.net<mailto:mcoh-eh-bounces at mylist.net>> On Behalf Of Hartley, Patrick
Sent: Monday, November 19, 2018 1:52 PM
To: MCOH/EH <mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>>
Subject: Re: [MCOH-EH] Employee occupational health clinic medical record confidentiality in an EMR


[[-- External - this message has been sent from outside the University --]]
Denece:

Is your legal counsel proposing that you not enter the non-employee health side of the firewall within your EMR when ordering tests? Is it a concern with regard to what hat you are wearing when you are in the EMR (in other words, you are either Director of OHS, or you are a medical provider within the hospital).
What is the proposed workaround if you cannot order CXR in your EMR? Can you order tests as if you are an external clinic (unaffiliated with the University) referring a patient to your health facility?

Pat

Patrick G. Hartley,  M.B., B.Ch., B.A.O., M.P.H.
Professor (Clinical) of Internal Medicine
Division of Pulmonary Diseases, Critical Care and Occupational Medicine
Medical Director: University Employee Health Clinic & Occupational Medicine Clinic
Carver College of Medicine
University of Iowa
Iowa City, IA 52242-1009
319-353-7072 (Office)
319-356-2115 (Pulmonary / Occ. Med. Clinic)
319-356-3631 (UEHC)
319-353-6406 (Fax)
patrick-hartley at uiowa.edu<mailto:patrick-hartley at uiowa.edu>


From: MCOH-EH [mailto:mcoh-eh-bounces+patrick-hartley=uiowa.edu at mylist.net] On Behalf Of Denece O Kesler
Sent: Monday, November 19, 2018 2:42 PM
To: 'mcoh-eh at mylist.net'
Subject: [MCOH-EH] Employee occupational health clinic medical record confidentiality in an EMR

All,
The topic of employee health medical records/confidentiality is periodically brought to this group-I have a new angle and need your help.  We are within an academic medical center and complete all occupational health clinic functions for the hospital's employee population. We have our own medical record room for some encounter types, but do place our work injury encounters into the hospital's EMR for continuity of care for referral, etc. There is a wall currently in the system so that other employees within the hospital cannot access any of our EMR records without permission.

The problem I have is this--- our IT legal counsel reviewed OSHA requirements and is providing the opinion to our IT department that the occupational health clinic should not have any records viewable to anyone outside of our clinic in the EMR-to the point where she is advising that we can't order x-rays, labs, or anything else under the employees' names. Has anyone experienced this opinion before? I have not and told IT that I would take it to this wise group with a request for comments.

Thank you!
Denece

Denece Kesler, MD, MPH
Medical Director, OHS
Professor, DoIM
Director, COEHP
University of New Mexico

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