New HIPAA Workforce Security Policy Now Posted on Premium Member Section: HIPAA & HITECH Act Blog by Jonathan P. Tomes


I am so grateful to my HIPAA seminar attendees, consulting clients, and Hands-on HIPAA Workshop participants for always helping me figure out what to write next. Last month, one of our Hands-on HIPAA Workshop participants asked whether I had a volunteer policy after I had explained that HIPAA no longer applied to just covered entities or even business associates now but also now to “other individuals.” That request for a volunteer policy prompted me to write a workforce security policy. Now under HIPAA, workforce includes not only employees but also volunteers and students, such as interns, whether they receive payment for their services or not.

As always, after you have adapted to your situation the sample HIPAA workforce security policy now available on our Premium Member section of the Veterans Press website, you will need to make sure that everyone in your workforce (1) has read the policy, (2) understands the policy, (3) knows what the sanctions may be for violating the policy, and (4) has been trained on the policy. And again, as always, you must keep written (may be electronic) documentation of those four items mentioned in the previous sentence for at least 6 years as evidence of HIPAA compliance. You may want to keep that documentation in Your Happy HIPAA Book, also available at

As an aside, we are currently looking into various locations for our next two-day Hands-on HIPAA Workshop. If you would like to join us and have a particular place in mind, please let us know.

Also, again, as a reminder, if you bought the HIPAA Compliance Library that includes my 5th edition of the Compliance Guide to HIPAA and the DHHS Regulations, you received with it a one-year free subscription to the Premium Member section. If you need help setting up your account to access the Premium Member section, please call our marketing director, Patrick R. Head II, toll-free at 855-341-8783 or email him at

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