This page is designed in an FAQ format and is designed to familiarize our clients and potential customers with SSS’s HIPAA compliance effort. Any further questions should be referred directly to Sixth Sense Services.

How does SSS comply with HIPAA standards?

Q. Do your employees understand the privacy and security regulations and their obligations under the business associate agreement?

A. Understanding privacy and security regulations is essential for our employees. They receive training so that they may understand the privacy and security regulations outlined by SSS and by our individual clients. Upon employment, employees are required to sign a confidentiality statement, indicating that they understand the confidential nature of the work that SSS performs and the confidential nature of the documents provided to SSS by its clients. Employees further agree that they will not divulge patient information. The confidentiality statement is renewed annually.

Our Employee Handbook addresses privacy, confidentiality, and security. Employees are required to sign a statement once it is read. Our clients often require statements for employees working with their material. We comply strictly with these client requests and enforce all standards they require.

Regular meetings are held to brief our employees on new policies and requirements. Our HIPAA Task Force reviews new information and provides this to management on a regular basis; ad hoc meetings and bulletins keep our employees up to date.

Q. How do you establish protocol to comply with other covered entities’ privacy policies?

A. MTIA’s HIPAA Compliance Guide has assisted us is preparing protocol and assessing our level of HIPAA compliance. The input from two internal HIPAA specialists is reviewed, ratified, and implemented by the management team. When negotiating/bidding for a contract with a covered entity, the requirements of their privacy policies are reviewed. New criteria are reviewed and implemented.

SSS strives to raise our current standard of excellence by evaluating our future clients’ needs and staying up to date on our HIPAA responsibilities.

Q. Do privacy and security policies and procedures exist?

A. Yes. Current policies and procedures affecting the privacy and security of PHI are reviewed regularly. Revisions to those policies are dated to reflect when the revision became effective.

Q. How have you, as a Business Associate, changed operations to prepare for HIPAA?

A. Our office is secured and locked at all times. No PHI is exposed in public areas. All employees have name badges and all network activity is logged. Our courier service has been redesigned to better protect PHI. A HIPAA Compliance Task Force has been instituted to train employees and review operations. Policy is now to destroy or return all PHI to the responsible Covered Entity at the expiration of a contract.

Q. How do you, as a Business Associate, place limits on use or disclosure of PHI?

A. SSS requires all employees to sign a statement that they will only access PHI when it is required to do their job. Use or discussion of PHI unnecessary to job duties is strictly forbidden. No hard copy of PHI will ever leave our site unless it is via courier service with the agreement of our client. Employee SSS numbers appear on transcribed client documents.

Q. How will you, as a Business Associate, sanction an employee who has violated your privacy policies? What is your company’s policy?

A. Employees who improperly use or disclose confidential information will be subject to disciplinary action, up to and including termination of employment and legal action. SSS will be entitled to seek injunctive relief (i.e., a court order that requires an employee to comply with privacy issues). Furthermore at the time of initial employment each employee signs a statement, agreeing to pay SSS for all reasonable legal expenses it incurs as a result of individual violations.

Q. Do you have an adequate training program reflecting the company’s policies and procedures?

A. The HIPAA training program began at our annual meeting. New information is presented through a variety of means, such as ad hoc bulletins and presentations, regular training sessions, and online tutorials. All new employees are given an Employee Manual containing pertinent information. Confidentiality agreements and statements confirming understanding of the Employee Manual are renewed annually.