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
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From: MCOH-EH [mailto:mcoh-eh-bounces@mylist.net]
On Behalf Of Reichen, Catherine
Sent: Wednesday, October 9, 2019 3:02 PM
To: MCOH-EH <mcoh-eh@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@mylist.net]
On Behalf Of da.sampson via MCOH-EH
Sent: Wednesday, October 09, 2019 3:53 PM
To: MCOH-EH <mcoh-eh@mylist.net>
Cc: da.sampson <da.sampson@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
Sent from my Verizon, Samsung Galaxy smartphone
-------- Original message --------
From: Anne Mills <amills@crhc.org>
Date: 10/9/19 4:23 PM (GMT-04:00)
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
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