4.4.C HIPAA/Privacy: Other Requirements - Sanctions Policy


    LIt is LHCC’s policy to discipline employees who fail to comply with LHCC policies and procedures regarding HIPAA/Privacy.


    • When a concern arises regarding a possible violation of HIPAA or LHCC’s policies or procedures related to HIPAA/Privacy, LHCC’s Compliance Officer shall begin an investigation promptly.
    • If, at the conclusion of said investigation, it is found that a violation of LHCC’s policy or procedure has occurred, the employee involved shall be disciplined in accordance with the severity of the violation.  Violations can be classified according to intent, such as:
      • Level I violations are those made accidentally or due to lack of education.
      • Level II violations are serious violations that are found to show purposeful disregard of LHCC policy.
    • The Compliance Officer shall review the circumstances surrounding any substantiated violation and take appropriate action to mitigate, to the extent possible, any harmful effects of the violation.
    • Documentation from the investigation shall be given to the Compliance Officer to be maintained as a part of LHCC’s HIPAA/Privacy documentation.
    • The disciplinary action report documenting the employee’s violation shall be placed in the employee’s personnel file as well as a copy provided to the Compliance Officer.
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