health and i document librar… · "health and safety code sec-tion 1280.15 {b)(2), a clinic,...

4
PRINTEC: 02114/2012 FORM APPROVED Calirornia Ue artment of Public Health ( XJ\ DA. TE SUI.VEY StArEMENT OF 01:.FI CIENCIES (X1, PROVIOE,R!SUPPUEP/CLIA 1X21 MUl TiPLE CONSTRUCTI ON COMPL.::TED AUD PtAN CF COll.HECt,or~ IDENTIFICATION NUMBER A BUILDING C B Wi~IG _________ CA230000367 10120/2011 STREET AODRESS, CITY, ST .ATE ZIP CODE 1035 PLACER STREET NM: F. Of Pll0V1DER o n SUPPLIER SHASTA COMMUNITY HEALTH CENTER REDDING, CA 96001 (X4J IO SUMMARY STATEMENT OF DEFIClENCIES 10 Pl1.EJ'I)( /EACH DEFICIENCY MUST BE PRECEDED BY FULL PREFIX tAG REGULATORY 0P. LSC IDENTIFYING INFORM;nO"ll TAG A 001 lntormec Medical Breach A 001 " Health and Safety Code Sec-tion 1280.15 {b)(2), A clinic, health facility, agency, or hospice . shall I also report any unlawful or unauthorized access to, or use er dlsc!csure of, a patient's medical ! , information to the affected patient or the patient's representative at the last known address. no later than five business days after the unlawful or unauthorizled access, use, or disclosure has been I detected by the clinic. health facili ty , agency, or hospice" The CDPH vedfied that the facility informed the affected patient(s) or the patient's representalive(s) of the unlawful or unau!honzed access. use or disclosure of the patient's medical , informabon. A oai Initial Comment A coo j The following rertects the findings of the California Depanment of Public Health during the invest1gat on of an entity reporte-;1 Incident Entity reported incident: 286832 The inspection ws limited to the specific entity 1 reponed incident investigated and does not represent the findings of a full 1nso-ect1on of the facility Representing the Department: 22705. HFEN A deficiency was written for entity reported incident 286832 at A017. A 017 1280 15/a) Health & Safety Code 1280 A 011 PROVI DER'S PL.Ml OF CORRECTION (Jl.5) (EACri CORRECTIVE ACTION StlOUL.0 Bl= CROSS-REFEPENOED TO THE I\P?l'\OP"!IATE COMPLETE OATC O EFICtENCY) Repeat submission for further details. With regard to your letter dated Febrl ary 14, 2012, please refer to the Plan of Correction below: On 10/10/11. I was advised by ou r CHief Operations Officer that there had been an employee breach of PHI which had been reported by the patient. After investigation it became clear that the employee had gone into the patient's record and accessed it in such a way that it was apparent he had been able to obtain PHI. He also went to the patient, who was aiso his friend, and told her that her physician had been telling her the truth and treating her well. The patient felt violated and reported this incident to her clinician, who then reported it to the COO. Investigation: Alter an investigation by the patient's clinician, the l>rivacy Officer, as well as the COO, the patient was notified that her claim had been validated and 1 action would be taken. The decision was made to terrninate the offending emoloyee effective 10/12/11. Organizational Corrective Action Plan: Corrective Action: When I initially replied to this corrective action request I stated that we were in f he process of obta i ning family members names and asking for voluntary cooperation to Utensm ga fJ H ,/ J1 1I ) . TIVE'S SIGNMURE f/L_ t, d..{_1., , r tJJ,1.- .. - l

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Page 1: Health and I Document Librar… · "Health and Safety Code Sec-tion 1280.15 {b)(2), A clinic, health facility, ... use of Fair Warning as well as ramping up department meeting in-services

PRINTEC 021142012 FORM APPROVED

Calirornia Ue artment of Public Health

(XJ DATE SUIVEY StArEMENT OF 01FICIENCIES (X1 PROVIOERSUPPUEPCLIA 1X21 MUl TiPLE CONSTRUCTION COMPLTEDAUD PtAN CF COllHECtor~ IDENTIFICATION NUMBER

A BUILDING CB Wi~IG _________

CA230000367 101202011 STREET AODRESS CITY ST ATE ZIP CODE

1035 PLACER STREET

NMF Of Pll0V1DER o n SUPPLIER

SHASTA COMMUNITY HEALTH CENTER REDDING CA 96001

(X4J IO SUMMARY STATEMENT OF DEFIClENCIES 10 Pl1EJI)( EACH DEFICIENCY MUST BE PRECEDED BY FULL PREFIX

tAG REGULATORY 0P LSC IDENTIFYING INFORMnOll TAG

A 001 lntormec Medical Breach A 001

Health and Safety Code Sec-tion 128015 b)(2) A clinic health facility agency or hospice shall

I also report any unlawful or unauthorized access to or use er dlsccsure of a patients medical

information to the affected patient or the patientsrepresentative at the last known address no later than five business days after the unlawful or unauthorizled access use or disclosure has been

I detected by the clinic health facility agency or hospice

The CDPH vedfied that the facility informed the affected patient(s) or the patients representalive(s) of the unlawful or unauhonzed access use or disclosure of the patients medical

informabon

A oai Initial Comment A coo

j The following rertects the findings of the California Depanment of Public Health during the invest1gat on of an entity reporte-1 Incident

Entity reported incident 286832

The inspection ws limited to the specific entity

1 reponed incident investigated and does not represent the findings of a full 1nso-ect1on of the facility

Representing the Department 22705 HFEN

A deficiency was written for entity reported incident 286832 at A017

A 017 1280 15a) Health amp Safety Code 1280 A 011

PROVIDERS PLMl OF CORRECTION (Jl5) (EACri CORRECTIVE ACTION StlOUL0 Bl=

CROSS-REFEPENOED TO THE IPlOPIATE COMPLETE

OATC OEFICtENCY)

Repeat submission for further details With regard to your letter dated Febrl ary 14 2012 please refer to the Plan of Correction below

On 101011 I was advised by our CHief Operations Officer that there had been an

employee breach of PHI which had been reported by the patient After investigation

it became clear that the employee had gone

into the patients record and accessed it in

such a way that it was apparent he had been able to obtain PHI

He also went to the patient who was aiso

his friend and told her that her physician had been telling her the truth and treating her well The patient felt violated and

reported this incident to her clinician who then reported it to the COO

Investigation Alter an investigation by the patients clinician the lgtrivacy Officer as

well as the COO the patient was notified that her claim had been validated and

1 action would be taken The decision was made to terrninate the offending emoloyee

effective 101211

Organizational Corrective Action Plan Corrective Action When I initially replied to this corrective

action request I stated that we were in f he process of obtaining family members names and asking for voluntary cooperation to

Ut ensmga fJ HJ11I )

TIVES SIGNMURE fL_ t d_1 r tJJ1shy

- l

Celifornia Deoartment of Public Health

STATEMEtH OF DEFICIENCIES (X1) PROVlDERISUPPLIERCLIA AND PlAN OF CORRECTION IDENTIFICATION NUMBER

CA230000367

(X2) MULTIPLE CONSTRUCTION

A BUILDING B WING __________

STREET ADDRESS CITY STATE ZIP CODE NAME OF PROVIDFR OR SUPPLIER

1035 PLACER STREET SHASTA COMMUNITY HEALTH CENTER REDDING CA 96001

SUMMARY STATEMENT OF DEFICIENCIES

PREFIX (EACH DEFICIENCY MUST BE PRECEDED BY FULL

TAG REGULATORY OR LSC IDENTIFYNG INFORMATION)

(X4) ID

A 017 Continued From page 1

(a) A clinic health facility home health agency or hospice licensed pursuant to Section 1204 1250 1725 or 1745 shall prevent unlawful or unauthorized access to and use or disclosure of patients medical information as defined in

middot subdivision (g) of Section 5605 of the Civil Code and consistent with Section 130203 The department after investigation may assess an administrative penalty for a violation of this section of up to twenty-five thousand dollars ($25000) per patient whose medical information was unlawfully or without authorization accessed used or disclosed and up to seventeen thousand five hundred dollars ($17500) per

subsequent occurrence of unlawful or unauthorized access use or disclosure of that patients medical information For purposes of the investigation the department shall consider the clinics health facilitys agencys or hospices history of compliance with this section and other related state and federal statutes and regulations the extent to which the facility detected violations

i and took preventative action to immediately correct and prevent past violations from recurring and factors outside its control that restricted the facilitys ability to comply with this section The department shall have full discretion to consider all factors when determining the amount of an administrative penalty pursuant to this section

This Statute is not met as evidenced by Based on interview and document review the facility failed to prevent unlawful or unauthorized accessdisclosure of medical information by failing to safeguard confidential health information for one patient when Licensed Nurse (LN) C who was unauthorized to access the information viewed a portion of her medical record (Patient

IDPREFIX

TAG

A 017

PRINTED 021142012 FORM APPROVED

(X3) DATE SURVEY COMPLETED

C 10202011

I PROVIDERS PLAN OF CORRECTION (l5) EACH CORRECTIVE ACTION SHOULD BE COMPLETE

CROSS-REFERENCED TO THE APPROPRIATE DATE DEFICIENCY)

block employees from their family and

friends records Since that time we have

received over 100 block requests (some of

them one employee with multiple

familyfriPnd members) and they continue to come in

How other patients having the potential to be affected by the same deficient practice will be identified and what corrective action will be taken

Multiple in-services have been held to

reinforce the importance of the minim1um

necessary element of the HfPAA Privacy

Law Additionally our organization has

purchased add-on software called Fair

Warning which enables the building of Ad

I Hoc investigative reports These report

options are attached in a screen print We

also have the ability to build reports based

on any aberrant behavior by an employee in

addition to the automatic random reports

We have had no suspicious viewing since

this incident

What immediate measure and systemic changes will be put into place to ensure that the deficient practice does not recur

The immediate changes were as noted

above

l Quarterly training for every

department (Employee sign in

records are available on request)

2 E-mail reminders

Licensing and Cert1ficat1on Division STATE FORM CIYE11 If conlirua~cn sheet 2 of 4

PRINTED 021412012 FORM APPROVED

California Deoartment of Pubhc Health

ST ATlMENT Of 01cFl(l~NCllS (X1 PROVIDERISUPP~lfPjCLIA (X) tbullUl lJPLE CONSrRUC rlUN ANO PlAN or CORHlCTION IOENTlrlCATION NUMBER

XJ) OATE SURVEY COMPLETED

BUILOfNG B Vi~IG _________ C

CA230000367 10202011 NIME OF PROVIDER OR SUPPLIER ST~ET AOORESS cm STr~ ZJP COOeuro

1035 PLACER STREET SHASTA COMMUNITY HEALTH CENTER REDDING CA 96001

tX4) II) SUIVIIVARY STATEMENT OF DEFICIENCIES ID PREFIX (EACI I DEFICIENCY MUST Beuro PRECEDED BY FULL PREFIX

TAG REGULA T CRt OR LSC IDENTIFYING INiORMATOI~ TAG

A 017 Continued From page 2 A017

1)

Findings

1 On 1011411 the California Depanment oi Public Health CDPH) was notified by fax that on 10110111 the facility had discovered that an employee (LN C) had accessed Patient 1 s medical record without authorization

During an interview on 102011 at 810 am Adm1nistratve Staff (Adm1n) A stated that Licensed Nurse (LN) C had been tenninated after it was determined 1at he had 1nappropriateiy accessed Patient 1middots record and violated the

I facilitys policy Admin A stated that Patient 1 complained that LN C had viewed her record Admin A explained that they have a tool that shows who accessed a record and when This toot showed that LN C did access Patient 1s

1record She confirmed that LN Chad no reason to access Patient 1s record because ne had never cared for her as a patient and worked 1n a different department

On 102011 at 915 am the facilitys access log

was vieweu by Health Information Staff B who

Iconfirmed that on 72711 LN Chad accessed

lPatient 1s demographic information which included name address social security number phone number insurance information as well as notes from all visits wlich included vital signs nurses riotes and physician notes She stated that the record showed that Patient 1 complalneo about LN C accessing her records during her appointment on 101111

Dunng an interview on 1012711 at 940 am LN C confirmed that on - 11 or thereabouts ne had looked at Patient results and last two chart 1siab

licensing arld Cert1fica1011 D1vs1o11 $TATE FORM

PROVIDERS PLAN OF CORREC flON ~gt iEACH CORRECTlE ACTION SHOUI O lIE I COlPLETE

CROSS-REFlRENCED TO 1HE PPROPRIATE 01TE DEFICJENCI)

I I 1

I I

3 Fair Warning - Random and I focused investigations

4 Voluntary blocking on employee

friends and family

Description of monitoring process and positions of persons responsible for

monitoring

All department Clinical Directors are

responsible for reporting any need for

investigation these reports are

subsequently given to the Director of

Nursing as well as the Chief OperationsI Officer (also the Compliance Officer) as well

1 as the Chief Information Officer Quality

assurance efforts are reported to the Chief

Operations Officer by the PrivacySecu~ity

Officer on a weekly basis 1Dates when corrective action will be

completed

I

Corrective Action was immediately

implemented and has been ongoing since

the event Official implementation date 022112 Unofficial implementation d~te with development of initial plan began

101411 This began with the intensified use of Fair Warning as well as ramping up

department meeting in-services Requests

for voluntary blocks from famrlyfriends

went out via e-mail to the organization on

101211 the date after the investigation

Respectfully submied

J ( lU l J (_L l 1- 17 ~_

CfYE11 It conunuato srce 3 or 4

(alifornia Oeoartment of Public Health --middot SlATEMENT OF DEFICIENCIES (X1) PROVIDERSUPPLIERCUA AND PLAN OF CORRECTION IDENTIFICATION NUMBER

CA230000367

NAME OF PROVIDER OR SUPPLIER

SHASTA COMMUNITY HEALTH CENTER

(X2) MULTIPLE CONSTRUCTION

A BUILDING B WING __________

STREET ADDRESS CITY STATE ZIP CODE

1035 PLACER STREET REDDING CA 96001

(X4) ID SUMMARY STATEMENT OF DEFICIENCIES ID PREFIX (EACH DEFICIENCY MUST BE PRECEDED BY FULL PREFIX

TAG REGULATORY OR LSC IDENTIFYING INFORMATION) lAG

A 017 Continued From page 3

notes LN C stated that he wanted to make sure that her physician was doing right by her LN C stated that he and Patient 1 knew each other and he told Patient 1 that he had viewed her record

The facilitys policy dated 82411 Ethics Compliance and Code of Conduct read as follows 1I

A 017

PRINTED 02142012 FORM APPROVED

(X3) DATE SURVEY COMPLETED

C 10202011

under the Patient Relationships section 2h on page 8 To that end all facility patients shall be accorded appropriate confidentiality and privacy during the provision of services and in the maintenance of medical and financial records It read as follows under the Patient Privacy section on page 9 Facility employees must never disclose confidential information that violates patients rights to privacy No staff member has a right to any patient information other than that necessary to perform his or her job Patients can expect that their privacy will be protected and that patient specific information will be released only to persons authorized by law or

by the patients written consent LN C had signed middot an acknowledgment of this policy on 8171 O

PROVIDERS PLAN OF CORRECnON lX5) (EACH CORRECTIVE ACTION SHOULD BE COMPLETE

CROSS-REFERENCED TO THE APPROPRIATE DAdegE DEFICIENCY)

Licensing ard Cert1fJcahon Division STATE FORM CIYE11 If contnua11cn sheet 4 of~

Page 2: Health and I Document Librar… · "Health and Safety Code Sec-tion 1280.15 {b)(2), A clinic, health facility, ... use of Fair Warning as well as ramping up department meeting in-services

Celifornia Deoartment of Public Health

STATEMEtH OF DEFICIENCIES (X1) PROVlDERISUPPLIERCLIA AND PlAN OF CORRECTION IDENTIFICATION NUMBER

CA230000367

(X2) MULTIPLE CONSTRUCTION

A BUILDING B WING __________

STREET ADDRESS CITY STATE ZIP CODE NAME OF PROVIDFR OR SUPPLIER

1035 PLACER STREET SHASTA COMMUNITY HEALTH CENTER REDDING CA 96001

SUMMARY STATEMENT OF DEFICIENCIES

PREFIX (EACH DEFICIENCY MUST BE PRECEDED BY FULL

TAG REGULATORY OR LSC IDENTIFYNG INFORMATION)

(X4) ID

A 017 Continued From page 1

(a) A clinic health facility home health agency or hospice licensed pursuant to Section 1204 1250 1725 or 1745 shall prevent unlawful or unauthorized access to and use or disclosure of patients medical information as defined in

middot subdivision (g) of Section 5605 of the Civil Code and consistent with Section 130203 The department after investigation may assess an administrative penalty for a violation of this section of up to twenty-five thousand dollars ($25000) per patient whose medical information was unlawfully or without authorization accessed used or disclosed and up to seventeen thousand five hundred dollars ($17500) per

subsequent occurrence of unlawful or unauthorized access use or disclosure of that patients medical information For purposes of the investigation the department shall consider the clinics health facilitys agencys or hospices history of compliance with this section and other related state and federal statutes and regulations the extent to which the facility detected violations

i and took preventative action to immediately correct and prevent past violations from recurring and factors outside its control that restricted the facilitys ability to comply with this section The department shall have full discretion to consider all factors when determining the amount of an administrative penalty pursuant to this section

This Statute is not met as evidenced by Based on interview and document review the facility failed to prevent unlawful or unauthorized accessdisclosure of medical information by failing to safeguard confidential health information for one patient when Licensed Nurse (LN) C who was unauthorized to access the information viewed a portion of her medical record (Patient

IDPREFIX

TAG

A 017

PRINTED 021142012 FORM APPROVED

(X3) DATE SURVEY COMPLETED

C 10202011

I PROVIDERS PLAN OF CORRECTION (l5) EACH CORRECTIVE ACTION SHOULD BE COMPLETE

CROSS-REFERENCED TO THE APPROPRIATE DATE DEFICIENCY)

block employees from their family and

friends records Since that time we have

received over 100 block requests (some of

them one employee with multiple

familyfriPnd members) and they continue to come in

How other patients having the potential to be affected by the same deficient practice will be identified and what corrective action will be taken

Multiple in-services have been held to

reinforce the importance of the minim1um

necessary element of the HfPAA Privacy

Law Additionally our organization has

purchased add-on software called Fair

Warning which enables the building of Ad

I Hoc investigative reports These report

options are attached in a screen print We

also have the ability to build reports based

on any aberrant behavior by an employee in

addition to the automatic random reports

We have had no suspicious viewing since

this incident

What immediate measure and systemic changes will be put into place to ensure that the deficient practice does not recur

The immediate changes were as noted

above

l Quarterly training for every

department (Employee sign in

records are available on request)

2 E-mail reminders

Licensing and Cert1ficat1on Division STATE FORM CIYE11 If conlirua~cn sheet 2 of 4

PRINTED 021412012 FORM APPROVED

California Deoartment of Pubhc Health

ST ATlMENT Of 01cFl(l~NCllS (X1 PROVIDERISUPP~lfPjCLIA (X) tbullUl lJPLE CONSrRUC rlUN ANO PlAN or CORHlCTION IOENTlrlCATION NUMBER

XJ) OATE SURVEY COMPLETED

BUILOfNG B Vi~IG _________ C

CA230000367 10202011 NIME OF PROVIDER OR SUPPLIER ST~ET AOORESS cm STr~ ZJP COOeuro

1035 PLACER STREET SHASTA COMMUNITY HEALTH CENTER REDDING CA 96001

tX4) II) SUIVIIVARY STATEMENT OF DEFICIENCIES ID PREFIX (EACI I DEFICIENCY MUST Beuro PRECEDED BY FULL PREFIX

TAG REGULA T CRt OR LSC IDENTIFYING INiORMATOI~ TAG

A 017 Continued From page 2 A017

1)

Findings

1 On 1011411 the California Depanment oi Public Health CDPH) was notified by fax that on 10110111 the facility had discovered that an employee (LN C) had accessed Patient 1 s medical record without authorization

During an interview on 102011 at 810 am Adm1nistratve Staff (Adm1n) A stated that Licensed Nurse (LN) C had been tenninated after it was determined 1at he had 1nappropriateiy accessed Patient 1middots record and violated the

I facilitys policy Admin A stated that Patient 1 complained that LN C had viewed her record Admin A explained that they have a tool that shows who accessed a record and when This toot showed that LN C did access Patient 1s

1record She confirmed that LN Chad no reason to access Patient 1s record because ne had never cared for her as a patient and worked 1n a different department

On 102011 at 915 am the facilitys access log

was vieweu by Health Information Staff B who

Iconfirmed that on 72711 LN Chad accessed

lPatient 1s demographic information which included name address social security number phone number insurance information as well as notes from all visits wlich included vital signs nurses riotes and physician notes She stated that the record showed that Patient 1 complalneo about LN C accessing her records during her appointment on 101111

Dunng an interview on 1012711 at 940 am LN C confirmed that on - 11 or thereabouts ne had looked at Patient results and last two chart 1siab

licensing arld Cert1fica1011 D1vs1o11 $TATE FORM

PROVIDERS PLAN OF CORREC flON ~gt iEACH CORRECTlE ACTION SHOUI O lIE I COlPLETE

CROSS-REFlRENCED TO 1HE PPROPRIATE 01TE DEFICJENCI)

I I 1

I I

3 Fair Warning - Random and I focused investigations

4 Voluntary blocking on employee

friends and family

Description of monitoring process and positions of persons responsible for

monitoring

All department Clinical Directors are

responsible for reporting any need for

investigation these reports are

subsequently given to the Director of

Nursing as well as the Chief OperationsI Officer (also the Compliance Officer) as well

1 as the Chief Information Officer Quality

assurance efforts are reported to the Chief

Operations Officer by the PrivacySecu~ity

Officer on a weekly basis 1Dates when corrective action will be

completed

I

Corrective Action was immediately

implemented and has been ongoing since

the event Official implementation date 022112 Unofficial implementation d~te with development of initial plan began

101411 This began with the intensified use of Fair Warning as well as ramping up

department meeting in-services Requests

for voluntary blocks from famrlyfriends

went out via e-mail to the organization on

101211 the date after the investigation

Respectfully submied

J ( lU l J (_L l 1- 17 ~_

CfYE11 It conunuato srce 3 or 4

(alifornia Oeoartment of Public Health --middot SlATEMENT OF DEFICIENCIES (X1) PROVIDERSUPPLIERCUA AND PLAN OF CORRECTION IDENTIFICATION NUMBER

CA230000367

NAME OF PROVIDER OR SUPPLIER

SHASTA COMMUNITY HEALTH CENTER

(X2) MULTIPLE CONSTRUCTION

A BUILDING B WING __________

STREET ADDRESS CITY STATE ZIP CODE

1035 PLACER STREET REDDING CA 96001

(X4) ID SUMMARY STATEMENT OF DEFICIENCIES ID PREFIX (EACH DEFICIENCY MUST BE PRECEDED BY FULL PREFIX

TAG REGULATORY OR LSC IDENTIFYING INFORMATION) lAG

A 017 Continued From page 3

notes LN C stated that he wanted to make sure that her physician was doing right by her LN C stated that he and Patient 1 knew each other and he told Patient 1 that he had viewed her record

The facilitys policy dated 82411 Ethics Compliance and Code of Conduct read as follows 1I

A 017

PRINTED 02142012 FORM APPROVED

(X3) DATE SURVEY COMPLETED

C 10202011

under the Patient Relationships section 2h on page 8 To that end all facility patients shall be accorded appropriate confidentiality and privacy during the provision of services and in the maintenance of medical and financial records It read as follows under the Patient Privacy section on page 9 Facility employees must never disclose confidential information that violates patients rights to privacy No staff member has a right to any patient information other than that necessary to perform his or her job Patients can expect that their privacy will be protected and that patient specific information will be released only to persons authorized by law or

by the patients written consent LN C had signed middot an acknowledgment of this policy on 8171 O

PROVIDERS PLAN OF CORRECnON lX5) (EACH CORRECTIVE ACTION SHOULD BE COMPLETE

CROSS-REFERENCED TO THE APPROPRIATE DAdegE DEFICIENCY)

Licensing ard Cert1fJcahon Division STATE FORM CIYE11 If contnua11cn sheet 4 of~

Page 3: Health and I Document Librar… · "Health and Safety Code Sec-tion 1280.15 {b)(2), A clinic, health facility, ... use of Fair Warning as well as ramping up department meeting in-services

PRINTED 021412012 FORM APPROVED

California Deoartment of Pubhc Health

ST ATlMENT Of 01cFl(l~NCllS (X1 PROVIDERISUPP~lfPjCLIA (X) tbullUl lJPLE CONSrRUC rlUN ANO PlAN or CORHlCTION IOENTlrlCATION NUMBER

XJ) OATE SURVEY COMPLETED

BUILOfNG B Vi~IG _________ C

CA230000367 10202011 NIME OF PROVIDER OR SUPPLIER ST~ET AOORESS cm STr~ ZJP COOeuro

1035 PLACER STREET SHASTA COMMUNITY HEALTH CENTER REDDING CA 96001

tX4) II) SUIVIIVARY STATEMENT OF DEFICIENCIES ID PREFIX (EACI I DEFICIENCY MUST Beuro PRECEDED BY FULL PREFIX

TAG REGULA T CRt OR LSC IDENTIFYING INiORMATOI~ TAG

A 017 Continued From page 2 A017

1)

Findings

1 On 1011411 the California Depanment oi Public Health CDPH) was notified by fax that on 10110111 the facility had discovered that an employee (LN C) had accessed Patient 1 s medical record without authorization

During an interview on 102011 at 810 am Adm1nistratve Staff (Adm1n) A stated that Licensed Nurse (LN) C had been tenninated after it was determined 1at he had 1nappropriateiy accessed Patient 1middots record and violated the

I facilitys policy Admin A stated that Patient 1 complained that LN C had viewed her record Admin A explained that they have a tool that shows who accessed a record and when This toot showed that LN C did access Patient 1s

1record She confirmed that LN Chad no reason to access Patient 1s record because ne had never cared for her as a patient and worked 1n a different department

On 102011 at 915 am the facilitys access log

was vieweu by Health Information Staff B who

Iconfirmed that on 72711 LN Chad accessed

lPatient 1s demographic information which included name address social security number phone number insurance information as well as notes from all visits wlich included vital signs nurses riotes and physician notes She stated that the record showed that Patient 1 complalneo about LN C accessing her records during her appointment on 101111

Dunng an interview on 1012711 at 940 am LN C confirmed that on - 11 or thereabouts ne had looked at Patient results and last two chart 1siab

licensing arld Cert1fica1011 D1vs1o11 $TATE FORM

PROVIDERS PLAN OF CORREC flON ~gt iEACH CORRECTlE ACTION SHOUI O lIE I COlPLETE

CROSS-REFlRENCED TO 1HE PPROPRIATE 01TE DEFICJENCI)

I I 1

I I

3 Fair Warning - Random and I focused investigations

4 Voluntary blocking on employee

friends and family

Description of monitoring process and positions of persons responsible for

monitoring

All department Clinical Directors are

responsible for reporting any need for

investigation these reports are

subsequently given to the Director of

Nursing as well as the Chief OperationsI Officer (also the Compliance Officer) as well

1 as the Chief Information Officer Quality

assurance efforts are reported to the Chief

Operations Officer by the PrivacySecu~ity

Officer on a weekly basis 1Dates when corrective action will be

completed

I

Corrective Action was immediately

implemented and has been ongoing since

the event Official implementation date 022112 Unofficial implementation d~te with development of initial plan began

101411 This began with the intensified use of Fair Warning as well as ramping up

department meeting in-services Requests

for voluntary blocks from famrlyfriends

went out via e-mail to the organization on

101211 the date after the investigation

Respectfully submied

J ( lU l J (_L l 1- 17 ~_

CfYE11 It conunuato srce 3 or 4

(alifornia Oeoartment of Public Health --middot SlATEMENT OF DEFICIENCIES (X1) PROVIDERSUPPLIERCUA AND PLAN OF CORRECTION IDENTIFICATION NUMBER

CA230000367

NAME OF PROVIDER OR SUPPLIER

SHASTA COMMUNITY HEALTH CENTER

(X2) MULTIPLE CONSTRUCTION

A BUILDING B WING __________

STREET ADDRESS CITY STATE ZIP CODE

1035 PLACER STREET REDDING CA 96001

(X4) ID SUMMARY STATEMENT OF DEFICIENCIES ID PREFIX (EACH DEFICIENCY MUST BE PRECEDED BY FULL PREFIX

TAG REGULATORY OR LSC IDENTIFYING INFORMATION) lAG

A 017 Continued From page 3

notes LN C stated that he wanted to make sure that her physician was doing right by her LN C stated that he and Patient 1 knew each other and he told Patient 1 that he had viewed her record

The facilitys policy dated 82411 Ethics Compliance and Code of Conduct read as follows 1I

A 017

PRINTED 02142012 FORM APPROVED

(X3) DATE SURVEY COMPLETED

C 10202011

under the Patient Relationships section 2h on page 8 To that end all facility patients shall be accorded appropriate confidentiality and privacy during the provision of services and in the maintenance of medical and financial records It read as follows under the Patient Privacy section on page 9 Facility employees must never disclose confidential information that violates patients rights to privacy No staff member has a right to any patient information other than that necessary to perform his or her job Patients can expect that their privacy will be protected and that patient specific information will be released only to persons authorized by law or

by the patients written consent LN C had signed middot an acknowledgment of this policy on 8171 O

PROVIDERS PLAN OF CORRECnON lX5) (EACH CORRECTIVE ACTION SHOULD BE COMPLETE

CROSS-REFERENCED TO THE APPROPRIATE DAdegE DEFICIENCY)

Licensing ard Cert1fJcahon Division STATE FORM CIYE11 If contnua11cn sheet 4 of~

Page 4: Health and I Document Librar… · "Health and Safety Code Sec-tion 1280.15 {b)(2), A clinic, health facility, ... use of Fair Warning as well as ramping up department meeting in-services

(alifornia Oeoartment of Public Health --middot SlATEMENT OF DEFICIENCIES (X1) PROVIDERSUPPLIERCUA AND PLAN OF CORRECTION IDENTIFICATION NUMBER

CA230000367

NAME OF PROVIDER OR SUPPLIER

SHASTA COMMUNITY HEALTH CENTER

(X2) MULTIPLE CONSTRUCTION

A BUILDING B WING __________

STREET ADDRESS CITY STATE ZIP CODE

1035 PLACER STREET REDDING CA 96001

(X4) ID SUMMARY STATEMENT OF DEFICIENCIES ID PREFIX (EACH DEFICIENCY MUST BE PRECEDED BY FULL PREFIX

TAG REGULATORY OR LSC IDENTIFYING INFORMATION) lAG

A 017 Continued From page 3

notes LN C stated that he wanted to make sure that her physician was doing right by her LN C stated that he and Patient 1 knew each other and he told Patient 1 that he had viewed her record

The facilitys policy dated 82411 Ethics Compliance and Code of Conduct read as follows 1I

A 017

PRINTED 02142012 FORM APPROVED

(X3) DATE SURVEY COMPLETED

C 10202011

under the Patient Relationships section 2h on page 8 To that end all facility patients shall be accorded appropriate confidentiality and privacy during the provision of services and in the maintenance of medical and financial records It read as follows under the Patient Privacy section on page 9 Facility employees must never disclose confidential information that violates patients rights to privacy No staff member has a right to any patient information other than that necessary to perform his or her job Patients can expect that their privacy will be protected and that patient specific information will be released only to persons authorized by law or

by the patients written consent LN C had signed middot an acknowledgment of this policy on 8171 O

PROVIDERS PLAN OF CORRECnON lX5) (EACH CORRECTIVE ACTION SHOULD BE COMPLETE

CROSS-REFERENCED TO THE APPROPRIATE DAdegE DEFICIENCY)

Licensing ard Cert1fJcahon Division STATE FORM CIYE11 If contnua11cn sheet 4 of~