HIPPA Training Now Required Yearly

This memo is written to clarify APD’s HIPAA training requirements for all provider staff. Please share this memo with all providers in your area.

While the Federal HIPAA regulations do not specify requirements for refresher training, Center for Medicare and Medicaid Services’ audit looks to see whether Covered Entities and Business Associates conduct it "on a regular basis." Therefore, effective immediately APD is requiring staff of all business associates (providers) to complete a HIPAA course on an annual basis. Because of the previous confusion surrounding the frequency of this training, APD is granting a grace period for all persons to comply with this requirement. Beginning June 1, staff will be cited if they have not re-taken HIPAA training within the past year. However, there is no change in the requirement to take this course initially prior to providing services.

The course APD consistently recommends for compliance of both the initial and refresher course requirements is free and available from the Department of Children and Families. A link to their website follows: http://www.dcf.state.fl.us/admin/training.shtml. DCF does update this course periodically and removes the old course when they create a newer version. By bookmarking this link, staff will automatically find the most current, acceptable HIPAA course.

After the person completes the DCF course, a certificate is generated automatically and needs to be printed and retained evidencing completion of the course. The certificate will be dated automatically to verify compliance, as well. Not only should a current certificate be maintained by all staff, but also their previous certificate so that timely compliance can be determined.

Anyone wishing to use training materials other than DCF’s must receive written approval from APD central office.

I hope this clarifies the timeframes and requirements for HIPAA initial and annual follow-up as required by APD. Please let Melinda Coulter know if you have any questions or if she can be of further assistance. Her telephone number is 850.488.9546.