1. Compliance Strategies for Records Management
Michelle Ryder

2. Agenda Introduction Higher Education Records Management Scenario
Healthcare Records Management
Q&A

3. Introduction BS in Business Administration; UMW
MBA and MS in Healthcare Management; Marymount
Marymount Advancement since 2010
Constituent Management
Gift Processing
Receipts / Tax Compliance
Acknowledgements
Data Maintenance (Ellucian)
Prospect Research
Prospect Reports
Prospect Management
Campaign Research

4. Higher Education Confidentiality Agreements
Employees
Usually held by HR and IT departments
Protect the institution andconstituents of the institution
Students
Usually held by Manager of the student worker
Certain access granted; protects the institution and constituents and the student!
Example for Student Agreement

5. Higher Education Maintenance vs. Inquiry
Marymount = Ellucian
All Databases have some form of Inquiry vs. Maintenance
Inquiry Access
Access to view specific information through the system
Maintenance
Actual maintenance of data; access to change information and run reports
Why does this matter?
You should not give maintenance access to more than one or two individuals in a department
Procedures as to who updates what are needed

6. Higher Education In-Office Information Privacy
Credit Card Numbers
PCI Compliance
DO NOT keep cc numbers in office (black out)
DO NOT send cc through unless secure
Prospect Files
Under lock and key
No medical or health information
Available to prospects at any time

7. Higher Education Pledge Agreements
Verbal vs. Written
Verbal cannot be entered as a technical pledge and cannot be enforced
Written pledge agreements should be kept as you keep your gift files
Should specify exactly what the donor and institution have agreed on (time, contingencies, programs, etc.)
Example of our Gift/Pledge Agreement

8. Higher Education Campaign Planning and Campaigns
Campaign Consultants
Interviews with Potential Donors
Accounting for Pledges vs. Gifts
They effect the bottom line differently
Record keeping outside of the official gift numbers
Excel Spreadsheets
Naming Opportunities
Presentation to Donor
Pledge Releases
Anonymous Donors

9. Higher Education FERPA
Rights of Parents
Prior Consent for disclosure of information
Donor Information
FAFSA Information
Rights of Students
Directory Information
Education Records

10. Higher Education Scenario 1
An alumnus calls in looking for contact information for his college girlfriend. He knows her name and grad year. He would like for you to give him her phone number. What should you do?

11. Higher Education Scenario 2
A donor has generously worked out an agreement to donate $1 million to your Catholic University. It turns out, the donor is also a heavy supporter of Planned Parenthood. Should you continue with the agreement or turn down the gift?

12. Healthcare Physical Records
Universal switch to digital records
Kept under lock and key
Need for more privacy in healthcare; break-ins, stealing, etc.

13. Healthcare Digital Records
Requirements
Now required to switch
Must be on compatible devices that are password protected
Confidentiality
All confidentiality laws still apply to digital record keeping
Patient Access
Patient’s can still request to see their information at any time
Websites are being created for Patient’s to login to their own accounts and access their information and request appointments
Must be encrypted and password protected

14. Healthcare Confidentiality Agreements and Training (Optima Health)
Each employee is required to sign an updated confidentiality agreement annually
Each employee is required to read and sign off on compliance agreements annually
Each employee is required to participate in annual webinars based on confidentiality, compliance and workplace ethics

15. Healthcare Computer Restrictions
Insurance companies should restrict access to all organization computers
Each employee should have a password and be required to logout of their system anytime they are away from their computer
Passwords should be changed regularly
Each employee should have independent access based on their needs
Employees should only have access to individual patient files if needed

16. Healthcare Digital Copies / Scanning
Password Protected Documents
Shared Drives with access granted to individual departments
Network Secure System
Outside s are secured by typing {SECURE} in subject line

17. Healthcare Confidential Shredding
Most companies are switching to electronic record keeping systems
All physical records should be shredded by an organization that specializes in confidential shredding
Ex: IronMountain
Records should never be placed in trashcans

18. Healthcare Governing body is HIPAA
Healthcare HIPAA
Healthcare Governing body is HIPAA
“The HIPAA Privacy Rule provides federal protections for individually identifiable health information held by covered entities and their business associates and gives patients an array of rights with respect to that information. At the same time, the Privacy Rule is balanced so that it permits the disclosure of health information needed for patient care and other important purposes.”
Covers rights of physicians, insurance agencies, patients, patient’s family, etc.
HHS.gov

19. Healthcare Scenario 1
A young woman named Erin is about to attend college. Her stepmother calls your physician’s office to get copies of all needed forms to send to the school. After checking Erin’s record you see that her next of kin are only listed as her mother and father. Her stepmother is persistent. What should you do?

20. Healthcare Scenario 2
You work for a Health Insurance Company. In a staff meeting, someone brings up the need to streamline the process of sending payment information to patients. They want to institute an automated calling system that will notify patients of their upcoming payments. Do you see anything wrong with this? For example, what if you have an incorrect telephone number?

21. QUESTIONS