Education and Training
Who do I contact if I have questions about the training?
Please contact the Office of Healthcare Compliance & Privacy at 860-679-4177 or ohcp@uchc.edu if you have questions about the training. For technical issues, please contact the IT Service Desk at 860-679-4400. For general Saba assistance, please contact Chris Desjardins at 860-679-7577.
Am I required to complete the training? Why?
Yes, the annual UConn Health Compliance and Privacy trainings are mandatory for all workforce members. UConn Health policy aligns with the Centers for Medicare and Medicaid Services (CMS) and the Deficit Reduction Act of 2005 requirements that entities receiving federal funds educate all employees, contractors, and agents (regardless of clinical involvement or tenure) about fraud, waste, and abuse, the False Claims Act, and other related compliance laws and protections.
What happens if I don’t complete the training by the deadline?
Failure to complete mandatory trainings results in a referral to Human Resources with possible sanction recommendations from the Office of Healthcare Compliance & Privacy for policy violation.
I am on approved leave. Do I need to take the compliance training?
No, but you will be required to complete the trainings upon return from leave, and you’ll be given a unique deadline related to your return date. Saba does not calculate due date extensions for employees on leave, so please note that employees on leave and their supervisors may continue to receive reminders even though a different completion deadline may apply.
I took the training. How can I verify it is marked completed?
Verify training completion status by viewing your Saba transcript or emailing ohcp@uchc.edu. Please note, for Saba to record that you completed a training course, you must complete the entire module including the attestation page.
I am a manager/supervisor. What is my role in monitoring my staffs’ completion of the Compliance and Privacy trainings? How can I see who has completed the trainings?
Managers and supervisors are accountable for monitoring employees’ timely completion of mandatory trainings. Use the Team Dashboard in Saba to verify individual employees’ training status. Please reference the Saba User Guide for Supervisors and Managers for step-by-step instructions on managing your team’s assignments.
Exclusions Checking
What is exclusion checking?
A1. “Exclusion checking” is UConn Health’s process of verifying that a current or potential employee, contractor, vendor, student, resident, fellow or volunteer is not classified as excluded, suspended or debarred by any Federal agency and certain state agencies.
What does it mean to be excluded, suspended or debarred?
Exclusion - An excluded person is someone listed on the Office of Inspector General (OIG) List of Excluded Individuals and Entities. This list identifies individuals whom the OIG has excluded from participating in Federal healthcare programs like Medicare and Medicaid. The OIG excludes individuals from participating in Federal healthcare programs for a number of reasons, including (but not limited to) criminal convictions related to fraud, patient abuse/neglect or controlled substances.
Many states maintain similar lists that identify individuals whom the state has excluded (i.e., prohibited) from participating in government-funded programs in the state.
Suspension and Debarment - A suspended or debarred person is someone listed on the General Services Administration’s System for Award Management (SAM) Exclusions List. The SAM list identifies individuals who are ineligible to participate in Federal programs or contracts, typically because of fraud, tax evasion or similar improprieties.
Why does UConn Health conduct exclusion checks?
UConn Health conducts exclusion checks on its employees, contractors, vendors, students, residents, fellows, and volunteers to ensure compliance with Federal law.
Federal law prohibits excluded persons from furnishing items or services that are payable by Federal healthcare programs. Healthcare providers like UConn Health that participate in Federal healthcare programs are prohibited from employing or contracting with excluded persons to provide items or services that are payable by a Federal healthcare program. Organizations and individuals that violate these provisions may be subject to civil money penalties and/or civil or criminal prosecution.
Exclusion checks also ensure that UConn Health does not engage individuals:
- Whom the U.S. government has suspended or debarred from Federal programs, or
- Whom a state has excluded from a government program in the state, when UConn Health participates in that state program (for example, a neighboring state’s Medicaid program).
My role at UConn Health is not related to patient care or any other item or service that is separately payable by a Federal health care program. Why am I subject to an exclusion check?
The prohibition against employing or contracting with excluded persons extends beyond direct patient care and applies regardless of whether the items or services furnished by the person are separately billable to a Federal healthcare program.
For example, excluded persons may not perform administrative and management services, such as health information technology services and support, strategic planning, billing and accounting, staff training, and human resources, unless wholly unrelated to Federal healthcare programs. In addition, excluded persons may not serve in executive or leadership roles at a healthcare organization that furnishes items or services that are payable by Federal health care programs.
It is often difficult to determine whether an individual’s role is or is not wholly unrelated to Federal healthcare programs. For that reason, UConn Health conducts exclusion checks on a wide variety of employees, contractors, vendors, students, residents, fellows, and volunteers.
Why is UConn Health asking me for more information, such as my date of birth or middle initial, in connection with exclusion screening?
UConn Health will ask you for more information if the exclusion check shows that someone with the same name as you is on the OIG or SAM list or is otherwise excluded or debarred from a relevant Federal or state program. This additional information is needed to confirm whether or not you are the person listed. We ask for the minimum amount of information necessary to make this determination, which in most cases is date of birth, middle initial or middle name, and/or previous residences.
What if I do not want to provide additional information to UConn Health?
If you are not comfortable providing the additional information needed to confirm that you are not excluded, suspended or debarred, you may submit a signed affidavit to UConn Health confirming that you are not excluded, suspended or debarred.
Who can I contact with additional questions?
If you have additional questions that have not been addressed here, please contact Bridget Richard from the Office of Healthcare Compliance & Privacy. She can be reached at 860-679-4177 or brichard@uchc.edu.
Healthcare Compliance
What should I do if I am approached by a government investigator?
If you are contacted by a government investigator while working at a UConn Health workplace or other approved work location, you should first ask the investigator to see identification, including a business card. Next, notify your supervisor, who should immediately notify the UConn Health Office of the General Counsel (OGC) to announce the investigator is on site. If your supervisor is not available, leave a message and contact the OGC directly. For more information please refer to the Protocol for Responding to Government Investigations.
What is the OIG Work Plan?
The Office of Inspector General (OIG) is continuously assessing, evaluating and prioritizing issues that put Health and Human Services programs (HHS) at risk. The Work Plan is a listing of high-risk focus areas where the OIG will assign resources to conduct audits, reviews or investigations. The Work Plan is updated monthly and items are added and removed as new risk priorities are identified and reviews are completed.
Since UConn Health participates in several HHS Programs such as the Centers for Medicare and Medicaid Services and the National Institutes of Health, we monitor the Work Plan to evaluate our risk related to items on the Work Plan.
How do I report a suspected compliance concern?
You should report compliance concerns to your manager or supervisor, the Office of Healthcare Compliance & Privacy, or UConn’s 24/7 anonymous REPORTLINE.
Privacy
How do I report a privacy concern?
If you believe an individual's privacy rights may have been violated, an information system has been compromised, or require clarification on acceptable privacy practices, please contact us at privacyoffice@uchc.edu or 860-679-7226.
What do I do if I see a fax that was received in error?
Misdirected faxes may expose patient and other confidential information to individuals who are not authorized to see that information.
- Notify the sender and return the fax if requested
- Contact the UConn Health Privacy Office
- Shred the original fax
Can I post about patients on social media?
No. The HIPAA Privacy Rule prohibits the use of PHI on social media without patient Authorization. This includes posts about specific patients, in addition to images or videos that may result in a patient being identified. Some examples of potential HIPAA violations using social media include:
- Sharing workplace frustrations online without the patient’s name, but with enough other details that the patient can easily be identified.
- Disclosing PHI in response to negative comments posted online.
Posting photographs or images taken from inside a healthcare facility where a patient or PHI are visible.
Can I access my own medical record using my work access?
No. UConn Health policy prohibits accessing your own medical records using work-issued EMR access. If you are a UConn Health patient, you may access your medical records in the same manner as all other UConn Health patients do through our online patient portal MyChart or by requesting copies from Health Information Management (HIM).
Can I access a family member's medical record?
You are not permitted to access a family member’s record unless your job requires it.
Is EMR access monitored?
Yes. OHCP monitors access to UConn Health electronic medical record systems using a privacy-monitoring tool to detect and respond to potential impermissible access to patient records.