What are the consequences, if any, if a student violates the policy while on fieldwork?
If a student violates HIPAA guidelines while on fieldwork, the school and fieldwork site should develop an action plan to address the issue. While up to the site and/or school, possible steps to take could range anywhere from a review of HIPAA policy to removal of the student from fieldwork – depending upon the severity of the violation. Schools should work with fieldwork sites so that the action taken with a student violation is similar or no greater than an action that would be taken with an employee. Guidance on language regarding Business Associate status provided by Susan Levy Wayne and and Nancy Cribbs, LLB, Cleveland State University Resources: Myths and Facts about the HIPAA Privacy Rule: http://www.healthprivacy.org/info-url_nocat2303/info-url_nocat_show.htm?
