In the Headlines
November 2023

Don't Skimp on Sanction Policymaking, Feds Warn


Healthcare attorney Shannon Hartsfield was quoted in the Medicare Compliance & Reimbursement Newsletter discussing the importance of developing fair and applicable sanction policies for Health Insurance Portability and Accountability Act (HIPAA) violations. The article notes that sanction policies should extend beyond merely retrieving records and stopping incidents to include penalties for staffers who cause inappropriate protected health information disclosures. Ms. Hartsfield cautioned that sanctions should be tailored to the nature and circumstances of the violation.  

"Generally, it may not be appropriate to immediately jump to employment termination if someone makes an innocent mistake. If every little HIPAA misstep, no matter how unintentional, results in someone losing their job, no one is going to report problems that could otherwise be resolved or not allowed to fester," she said.

She also added that additional education should be a part of the sanction policy. 

"A sanction could involve re-training the people involved, or even looking at whether an entire department should be retrained to make sure that potentially systemic problems don't continue."

READ: Don’t Skimp on Sanction Policymaking, Feds Warn (copyright AAPC)

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