This program purpose is to acculturate IMGs to American medical practices and help prepare them for residency, the observer can rotate among several preceptors to create a longer experience.
Learning objectives:
Eligibility of physician preceptors:
Responsibilities of physician preceptors:
Eligibility of observers:
Responsibilities of observers:
Organizational model
Program director—a physician who volunteers to lead the Observership Program and the Observership Program committee.
Observership Program committee—comprises three to four physicians or medical educators who oversee activities of the program and assure that the objectives of the program are being met. This committee may:
The Observership Program committee may also provide:
Overview
The HIPAA Privacy Rule generally permits covered physicians to use and disclose protected health information (PHI) for treatment, payment and health care operations, including training activities. Specifically, the term “health care operations” involves “reviewing the competence or qualifications of health care professionals, evaluating provider and health plan performance, training health care and non-health care professionals, accreditation, certification, licensing, or credentialing activities.”
Notice of Privacy Practices
The HIPAA Privacy Rule states that an individual has a right to adequate notice of how a covered entity may use and disclose PHI about the individual. Physicians who are covered by the rule are required to develop a Notice of Privacy Practices that describes, in plain language, how the physician may use and disclose PHI about an individual. If a particular use and/or disclosure of PHI is not listed in a physician’s Notice of Privacy Practices, the physician cannot use or disclose PHI for that purpose without a patient’s authorization.
Authorization
A covered physician must obtain written authorization that complies with the requirements of the HIPAA Privacy Rule before he/she uses or discloses PHI, if the use or disclosure is not otherwise permitted or required under the rule without authorization, and if it is not described in the Notice of Privacy Practices
Conclusion
The HIPAA Privacy Rule permits the use and disclosure of PHI for training purposes (such as an IMG Observership Program), as long as: (1) the patient is notified of this use and disclosure in the sponsoring physician’s Notice of Privacy Practices, or (2) the patient signs a HIPAA-compliant authorization permitting this type of use and/or disclosure.
Note: Even if education and training is listed as a purpose in the sponsoring physician’s Notice of Privacy Practices, it is still a good idea to explain the presence of the observer when visiting with a patient and to note the patient’s willingness to have the observer present in the medical record. This extra step is suggested to avoid misunderstandings, as most patients do not read the Notice of Privacy Practices.
Download Observer application form, fill and send the submitted file to observershipprogram@ummc.care.