HIPAA

Biohazard Waste Company

  • 1.  Biohazard Waste Company

    Posted 11 days ago

    Asking for your opinion please!

    Based on Wedi's Business Associate Decision tree, Stericycle, our Biohazardous Waste/Sharps Management Company, is a business associate and should sign a business associate agreement.  The biohazard bags they dispose of contain waste that has protected health information on it, such as patient labels with names, birthdates, etc.  Stericycle then transports the bags for disposal.

    Wedi's question "Will the other person or entity be able to access PHI on a routine basis AND/OR is there a possibility that the PHI in the person or entity's custody or control could be compromised (e.g., data storage vendor, document shredding company, or other, etc.)?" helped me make this decision.  What do you think, am I on the right track?

    Thank you!

    Cinda

     

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  • 2.  RE: Biohazard Waste Company

    Posted 11 days ago

    Cinda,

    I think you're right on! If there is patient information on the waste items, and they have possession of it...you don't know what could happen. So they need to be contractually obligated to protect the patient data.

     

    Best Regards,

    Scot Lovejoy  CFP_XSLogo_BlBk 

    Scot Lovejoy RPh. CFP CHC

    Chief Pharmacy Officer

    Compliance Officer

    Agadia_itself (625x184) (625x184) (100x29)

    9 Campus Drive, 2nd Floor East

    Parisippany, N.J. 07054

    (O) 973-540-8400  x227

    (C) 973-570-3803

    (F) 973-540-8440

     

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  • 3.  RE: Biohazard Waste Company

    Posted 11 days ago
    ​CInda,
    We had many a discussion with Stericycle over this. They absolutely refuse(d) to sign a BAA, but our clinics were insistent that they needed their services, so the compromise was that we "scrub" the labels etc. before disposal to Stericycle.

    ------------------------------
    David Rothery, CHC
    Compliance Officer
    Marin County, CA


    These are my personal opinions and not those of the County of Marin
    ------------------------------



  • 4.  RE: Biohazard Waste Company

    Posted 11 days ago

    Hi Cinda, yes I would consider them a BA and initiate a BAA with them.

     

    Erin M. Jack, RHIA, CHC, CHPC

    Privacy & Data Ethics Official

    Data Ethics, Policy, and Privacy Department

    Forbes Hospital - Office: 412-858-2534

    Allegheny Valley Hospital - Office: 724-389-6520

    Highmark Health

    Fax: 412-544-4320

     






  • 5.  RE: Biohazard Waste Company

    Posted 11 days ago
      |   view attached
    Found the attached post on an older HCCA post from 2013 regarding the same question. I wasn't able to access the link she posted but thought this might be helpful and makes sense.

    ------------------------------
    Savannah Knuettel CHC
    Compliance Coordinator
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    ------------------------------



  • 6.  RE: Biohazard Waste Company

    Posted 10 days ago

    Thank you everyone for your feedback!

    Cinda

     

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