[MCOH-EH] Flu Vaccine Status Indicators

[Cockrum, MD David S]

I’m not a lawyer, and I haven’t stayed at a Holiday Inn Express recently, but…I tend to agree with Cathy’s legal interpretation. The badge sticker is related to activities required for employment, which is essentially outside the sphere of HIPAA. If HIPAA were applied in its purest form, we couldn’t ask non-immunized employees to wear masks since this would also be an indicator of a personal medical choice.  Additionally flu shots are a vital part of the Infection Control program, which is a standard related to protecting public health – again, beyond the scope of HIPAA.

Just my two devalued cents…

David


DAVIDCOCKRUM, MD
Physician
Faith Regional Physician Services
Occupational Health
(402) 844 8300
2024 Pasewalk Avenue, Suite 2, Norfolk, NE 68701
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From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Reichen, Catherine
Sent: Wednesday, October 9, 2019 3:02 PM
To: MCOH-EH <mcoh-eh at mylist.net>
Subject: Re: [MCOH-EH] Flu Vaccine Status Indicators


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Deb,

That is interesting.  Our HR employee rights lawyer told us that this is not a HIPPA violation.  We use different colored stickers with the year on them to indicate vaccination and declination (without  the wording of “I got my flu shot” on them).  Our policy states that they have to have a sticker by Dec 1 and they must be placed on the front of the badge for identification of compliance.

Cathy

From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of da.sampson via MCOH-EH
Sent: Wednesday, October 09, 2019 3:53 PM
To: MCOH-EH <mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>>
Cc: da.sampson <da.sampson at yahoo.com<mailto:da.sampson at yahoo.com>>
Subject: Re: [MCOH-EH] Flu Vaccine Status Indicators

Hello Anne
Several years ago legal counsel at another medical center in NH indicated that placing a sticker on an ID badge for flu vaccination was not a great idea since this is a public acknowledgment of individual medical information and could be challenged as a HIPAA violation regardless of facility policies.
Just a thought.

Deb Sampson



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-------- Original message --------
From: Anne Mills <amills at crhc.org<mailto:amills at crhc.org>>
Date: 10/9/19 4:23 PM (GMT-04:00)
To: mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>
Subject: [MCOH-EH] Flu Vaccine Status Indicators

Hello,

We recently transitioned to a influenza vaccine policy that requires masking for non-vaccinated health care personnel.  We use badge stickers as status indicators.  I am curious how others have made this work.  We are a regional medical center with multiple, off-site primary care and specialty practices.  We have many non-employed credentialed providers who participate in this program.

Flu vaccine is provided in Employee Health Services and department-based, "Flu Vaccine Ambassadors".  However, there are so many others that vaccinate elsewhere, or are in departments without an Ambassador.

We have not been able to identify an efficient means to deploy stickers. Your experiences are welcomed.

Anne




Anne C. Mills, MSN, RN, COHN-S
Concord Hospital
Director Employee Health Services
| • (603) 230-1962| 7 (603) 227-7126
|  amills at crhc.org<mailto:amills at crhc.org>

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