In the end, just simplify it.
If you would train them to do their job in their native language, it is reasonable to think you would train them on any hipaa related requirements in their native language. Regardless of the media used.
-Beth Kranda
"Christiansen, John (SEA)" wrote:
I've had to address this for a company which provides on-line HIPAA training including courses intended for high-turnover, low education-level healthcare positions such as maintenance/housekeeping, clerical, security, etc. - positions where training is required due to the potential for exposure to PHI but English language competence cannot be assured.As with so much else in HIPAA compliance (sigh), what needs to be done depends on your circumstances. Since the company is seeking to provide training appropriate for e.g. big-city hospitals on one end of the spectrum, and rural clinics on the other, this was and is a genuine issue, and some focus groups and many informal discussions were held with big hospital compliance administrators as well as safety-net provider organizations, and some in between. We also consulted with a healthcare cultural diversity program. On the legal side I conducted a deep review of standards of practice around security training (there is a more developed body of practice there than in privacy training).Our findings were that there definitely are some situations in which translated training is the way to go. In some regions non-English speaking populations make up a very large proportion of the workforce pool, and a failure to provide translated training left the uncomfortable choice between a lack of assurance that some workforce members actually understood it on the one hand, and having to reduce the pool of available workforce members too far by making a certain level of English competence a hiring requirement. (We did have some administrators who said that they required English competence anyway, so for them this was not an issue.)The resolution was to develop a standard Spanish program now, to accompany the English program, since that was the language for which there was clearest need. There is a list of some nine or ten other languages for which content is in development for deployment as demand actually materializes.A couple of other items worth noting: the Spanish translation process provided the additional benefit of making the English coursework more accessible, since the first step to translation was assessment and lowering of the required educational level. Also, we determined that English-only was acceptable and appropriate for clinical personnel, since anyone functioning at that level would have to be competent in it.Hope this helps.From: John R. Christiansen
Preston | Gates | Ellis LLP
701 Fifth Avenue, Seattle, Washington 98104
(Direct: 206.613.7118 - (Cell: 206.799.9388
* [EMAIL PROTECTED]
Reader Beware: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, e-mail content may have been modified or corrupted, and e-mail headers or signatures may incorrectly identify the sender. If you wish to confirm the contents of this message or identity of the sender, or wish to arrange for more secure communication please contact me using a communications channel other than a "reply" to this e-mail. Thank you.-----Original Message-----
From: Shewchuk, Tara [mailto:[EMAIL PROTECTED]]
Sent: Friday, July 26, 2002 9:23 AM
To: '[EMAIL PROTECTED]'
Subject: hipaa workforce training
Good day to all!
Tara R. ShewchukWe are developing our own HIPAA training video to train all members of our workforce on the HIPAA requirements. One of the issues with which we are struggling is language barriers among members of our workforce. We have members of our workforce for whom English is not their primary language. I do not see any specific requirements in the regulations addressing the language of training. Unlike the corporate compliance program guidance, the feds are not real clear in what they expect. The privacy regulation states that we must train our workforce "as necessary and appropriate" so that they understand how the law and the covered entity's policies and procedures affect their job function. (The proposed security regulation does not address it at all.)
Does "appropriate" encompass translations for non-English speakers? However, if your facility makes it a condition of employment that the employee have a working knowledge of English (at least in theory), are we OK to present our training in English only or should we offer it in other languages?
Any thoughts on this issue would be appreciated!
Corporate Compliance Officer
Resurrection Health Care
(773) 792-9775
[EMAIL PROTECTED]
The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board of
Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is
specifically prohibited.
The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board of
Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is
specifically prohibited.
--
M. Beth Kranda
Privacy Director
ACS Healthcare Solutions
t- (317) 614-2139
f- (317) 614-2007
e- [EMAIL PROTECTED]
info- www.acs-inc.com
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments,
is for the sole use of the intended recipient(s) and may contain confidential
and privileged information. Any unauthorized review, use, disclosure
or distribution is prohibited. If you are not the intended recipient,
please contact the sender by reply e-mail and destroy all copies of the
original message.
"I always wanted to be somebody, but I should have been more specific."
--Lily Tomlin
The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board of
Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is
specifically prohibited.
