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ACA has had some questions from both camp
directors and Visitors about privacy issues
related to the HIPAA regulations. How
do Visitors verify compliance with HW-2
or HW-6 without violating privacy concerns?
Although, technically, HIPAA regulations
are not applicable to most camps, we certainly
need to respect camps' health information
privacy concerns. Verifying compliance
with the health form and health exam standards
involves two things—verifying that
the form itself asks for the appropriate
information to meet the requirements of
the standard AND seeing evidence that forms
are being collected from campers and staff
and that they are filled out fairly completely. So,
Visitors should carefully review a blank
form and then ask to see a few randomly
selected forms with names covered or held
up at a distance to check for completeness.
As we have said before, a few forms with
some incomplete areas do not necessarily
mean a "NO" score. The wording
of the standard, which reads "requesting
all of the following information" allows
a "YES" score if a few forms
do not have complete information. If
most or all of the forms are missing critical
information, the standard should be scored "NO" since
there is no evidence that the policy is
being implemented.
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