The HIPAA compliance norms lay stress on the safe transaction and storage of the patient health information, whether on paper or in electronic format. The patient health information stored as electronic file in computer and protected by a system of username and password is much safer than paper documents. As medical documents are being converted into electronic health records, it has become necessary to dispose off the paper records in a safe and secure manner.
The safe disposal of the unneeded patient health documents is crucial because the health service provider is accountable for any breach, during information processing, exchange, storage or disposal. Any paper disposal vendor or recycler who seeks to enter into business alliance with any of the health service provider should employ the right waste paper management techniques that are in line with HIPAA compliance norms.
The covered entity and the vendor should together work in tandem to chalk out a good strategy, which ensure safe disposal of the paper documents. The following points should form the backbone of this joint strategy:
- The health providers should train their staff to generate less paper wastage. The organization should switch to electronic mode of information processing from paper documents. This will greatly reduce the waste paper generation at source. The facility should maintain a list of the staff members who are responsible for generation, storage and safe handing over of the waste paper documents to the vendor. This brings in accountability into the system.
- Paper should be trashed in locked bins and stored in safe areas of the facility, away from the busy areas. If the health providers want they can shred the documents in there own facility but it requires additional labor and capital.
- If a vendor is given the task of shredding or recycling the documents then the covered entity should enter into a binding agreement that ensures that there is no lapse on the part of vendor right from collection of waste to its disposal in shredding machine or a recycling plant, because ultimately health provider is accountable for any safety lapse.
- The vendor can shred the documents on the site or transport them to bulk shredding center. It should provide certificate of disposal so that time, place and proof of safe disposal are available to the covered entity.
Thus a well though out waste disposal scheme protects the covered entity from liability due to any breach in confidentiality of patient health information during its disposal.
Safe disposal of patient health documents protects the covered entity from penalties and criminal prosecution.
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