Regarding Multi-lingual Training
True
simpler is better, but in most cases the professional staff are not the
problem. This generally is a unique problem for awareness training for
non-professional/non-administrative staff, who by definition may have lower
education levels. Also, the rag states that is must be in Plain Language
without a further definition. Clearly anyone who does not make
multi-lingual training available for lower level staff is going to face the
question at some time.
So I
do think that it should be the recommendation of this body that Awareness
training be made available in: English, Spanish, Creole, Korean, Mandarin
Chinese.
Additionally, I also think this question applies to policies and
procedures as well. I think that for larger organizations, there will be a
process breakdown unless both training and P&P are provided in multiple
languages. We have seen this clearly in local and state government,
as well as in the private sector. There may also be an element of
discrimination if training materials are not provided in multiple
languages. I raise these points not to make our lives more difficult, but
from discussions with Liability Litigators. Ultimately, risk is the
issue.
I
would suggest a work group be formed to produce white papers for both privacy,
and policies and procedures to directly address the issues of language.
Best practices and minimum requirements in healthcare in general, and in other
industries should be examined. Additionally, there may very well be other
statutes that apply or influence this discussion, including: OSHA, Dept.
Of Labor, State Law, etc. Perhaps our friends in OCR have an opinion as
well?
Tim
McGuinness, Ph.D.
HIPAA
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