4.4 - Clinic Affiliate Requirements for Student Participation

Clinics require that students submit certain documents for hospital/ clinic compliance to work with patients.  The documentation is submitted through a tracking system used by the College of Allied Health.  These documents may include; CPR certification, medical insurance coverage, complete immunization records, drug test results, criminal background check, completion of OUHSC online HIPAA (Privacy and Security) training, and completion of OUHSC online Environmental Health and Safety (Blood Borne Pathogens, Tuberculosis, Fire Safety, and General Safety/Hazard Communication) trainings. Students will be asked to submit proof of renewal as outlined below; 
 
CPR certification must be obtained through the American Heart Association or the American Red Cross Basic Life Support for the Healthcare Professional course.  Students must be recertified prior to expiration of their current card and provide proof of updated certification through the electronic tracking system. 

Medical insurance coverage must be current and maintained throughout the entire program.  Students not enrolled in the University Academic Health Plan must submit a request for a waiver prior to each semester demonstrating alternative coverage.   

Students are required to keep their immunizations, CPR certification, drug screen, and background check current throughout the enrolled semesters. Students will receive a reminder through the electronic tracking system of items expiring, but students are responsible for meeting these requirements whether they receive this reminder or not. 

To accommodate time constraints, up to 2 hours of clinic time per semester may be used for the purpose of fulfilling these immunization compliance requirements. If additional time is required, it must be made up before the end of the semester by following proper procedure for make-up time. 

Students will receive a Zerograde and be suspended from clinic activities if the required immunizations or other Complio requirements are not completed and submitted before the deadline. There will also be a hold placed on enrollment per College of Allied Health policy.  

Students should use the tracking system to retrieve and print additional copies of the uploaded items. Students must take their immunization records, CPR card, medical insurance card, drug test, background check report, Environmental Health and Safety training and HIPAA training documentation with them to clinic for review by the clinic affiliate. The Complio system uses the ‘passport’ button to allow users to review, save, and print their records. 
 

The University requires annual criminal background checks of students as a condition of admission and enrollment.  In addition, several clinic affiliates associated with the College of Allied Health require such checks. This policy is intended for all University of Oklahoma Health (“University”) conditionally accepted applicants and enrolled HSC students. A national Criminal Background Check (“CBC”) is required of each conditionally accepted applicant prior to full admission and at least annually thereafter by national CBC or written attestation, as specified pursuant to the provisions of this policy for every continuing student. Applicants waiting for confirmation of conditional acceptance should check with the college/program to which they are applying for specific CBC requirements and timelines. Enrolled students should check with their college/program for specific CBC requirements. 

The clinic affiliates have the ultimate right to accept or refuse a student based on results of a background check. Should a clinic refuse a student based on the results, the student may be unable to complete the required clinic rotation for that semester. This may prevent a passing grade in that course, thus delaying or preventing graduation.
 
Clinic affiliates may ask the student for results of the background check before rotations begin or on the first day of the rotation. Clinical coordinators will provide additional information prior to the start of clinic rotations to assist students in complying with the needed documentation.    

The full OUHSC criminal background check policy can be found in the Faculty Handbook in Appendix C.4, Page 12 – 24

Additional information can be found at: 
CAH Student Handbook (select the applicable year): 11.8 Clinical Requirements

Healthcare providers are entrusted with patients’ health, safety, and welfare; have access to confidential and sensitive information; and operate in settings that require good judgment and ethical behavior. Thus, assessing a student’s or accepted applicant’s suitability to function in a clinical environment is imperative to promote the highest level of integrity in health care services.
Clinical Experiences are an essential element in specific degree programs’ curricula. Patient safety concerns have led many healthcare institutions and clinical facilities to require drug screening of healthcare providers. In addition to the University of Oklahoma’s (OU) belief that this is an appropriate patient safety decision, drug screening is now a prerequisite for many facilities to accept student assignments. This policy allows OU to balance the needs of students while protecting the interests of its patients and any affiliated healthcare facilities. This policy also will enable OU to (a) meet the contractual obligations contained in affiliation agreements between the University of Oklahoma Health and the various healthcare facilities; (b) perform due diligence and competency assessment of all individuals who may have contact with patients (including research participants); (c) ensure uniform compliance with accreditation standards and agency regulations pertaining to human resource management; and (d) meet the public demands of greater diligence in light of the national reports on deaths resulting from medical malpractice and medical errors.
This policy applies to all OUHSC-accepted applicants and students admitted to designated degree programs that include or may include a Clinical Experience at a healthcare facility that requires drug screening as a condition of its affiliation with OU. Students should check with their college and/or degree program for specific requirements.

The full OUHSC drug testing policy can be found here. 

Additional information can be found at:
CAH Student Handbook (select the applicable year): 11.8 Clinical Requirements

OUHSC Student Handbook: 3.8 Drug Screening
 

All enrolled students must complete the online HIPAA Privacy and Security training annually. Students should retain a copy of this certificate for their records and submit as required. The HIPAA training must be completed within thirty (30) days from the first day of classes unless the department or college requires earlier completion, and annually thereafter. 

The HIPAA Privacy Regulations established national standards regarding uses and disclosures of all patient-related information and place stringent requirements on practitioners, trainees, and researchers to protect the privacy of patients and research participants and selected others. Additional information about HIPAA, including the University’s HIPAA policies and forms, is available at http://www.ouhsc.edu/hipaa/. 

When completing assignments that include patient-related information, students must follow these guidelines: 

1. Maintain confidentiality concerning all protected health information (PHI); 
2. Restrict the use and/or disclosure of protected health information, even though permitted, to the minimum necessary to accomplish the intended educational purpose.
3. To the extent consistent with the minimum necessary standard, de-identify patient images and other documentation by removing identifying information such as the following, before leaving the clinic setting or before using for teaching or research purposes: 
   • Names (including patient, physician an institution)
   •  
   • All geographic subdivisions smaller than a state, including street address, city, county, precinct, ZIP code, and their equivalent geocodes.
   • All elements of dates (except year) for dates that are directly related to an individual, including birth date, admission date, discharge date, death date, and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older
   • Telephone numbers
   • Vehicle identifiers and serial numbers, including license plate numbers
   • Fax numbers
   • Device identifiers and serial numbers
   • Email addresses
   • Web Universal Resource Locators (URLs)
   • Social security numbers
   • Internet Protocol (IP) addresses
   • Medical record numbers
   • Biometric identifiers, including finger and voice prints
   • Health plan beneficiary numbers
   • Full-face photographs and any comparable images
   • Account numbers
   • Any other unique identifying number, characteristic, or code
   • Certificate/license numbers
4. Maintain confidentiality by refraining from discussions about patients seen during clinic rotations when outside of the classes, and on any social media site, including closed, private, or secret groups on social media sites.

Any breach in HIPAA compliance must be reported as soon as identified to the appropriate University Privacy Official. Talk to your clinic coordinator or program director to help with reporting a HIPAA breach.   Additional information about HIPAA, including the University’s HIPAA policies and forms, is available at https://hipaa.ouhsc.edu/.

For questions regarding HIPAA, contact the University Privacy Official at 271-2033; for questions regarding compliance in general, contact the department or the Office of Compliance at 405-271-2511.