This webinar will review documentation best practices for EAP providers. The webinar will pay special attention to EAPA Standards and Guidelines for program records. We will also review protocols for preserving confidentiality and discuss processes for releasing information with and without consent. The webinar will present the challenges of documenting electronic communications in EAP services and provide strategies to overcome these challenges.
Learning objectives:
1. Understanding documentation and records management, including electronic documents.
2. Understanding EAPA Standards and Guidelines for program records.
3. Understanding and communicating protocols for confidentiality and release of information.
For additional handouts please email the author chris at hylton dot ca
Sustainability: Balancing the Environment, Equity & Economy
Documentation Best Practices for EAPs
1. PRESENTED BY
CHRIS HYLTON, MA
EAPA WEBINAR
MAY 10, 2016
EAP Documentation:
Tips for Successful Best Practices
2. Description of Webinar
2
This webinar will review documentation best practices for EAP
providers and pay special attention to EAPA Standards. We will also
review protocols for preserving confidentiality and discuss processes
for releasing information with and without consent. The webinar will
present the challenges of documenting electronic communications in
EAP services and provide strategies to overcome these challenges.
Learning objectives:
Understanding documentation and records management, including
electronic documents.
Understanding EAPA Standards and Guidelines for program
records.
Understanding and communicating protocols for confidentiality and
release of information.
3. Introduction
3
Background:
Effective processes for documentation and records management have
evolved dramatically over the past few decades thanks to the proliferation
of technology in the workplace. In this age where so much communication
happens electronically, EAP practitioners need to know how to document
and manage both traditional paper files and electronic files. This webinar
will give you the tools you need to meet EAPA standards for record keeping
and ideas on how to effectively manage documentation. We will also
discuss how records management processes can be designed to maintain
privacy and exceptions to maintaining confidentiality.
Polling questions:
Are any of the webinar attendees currently using electronic communication
to deliver services? If so, what are some of the challenges you have faced
while transitioning to online service delivery?
Do you think EAP service documentation will ever be captured exclusively
electronically? What, if any, might some of the challenges be with this type
of records management?
4. About our Speaker
4
Chris Hylton runs an EAP serving Canadian
employers, and US EAPs for their Canadian
population.
He is also a benefits and HR consultant.
A frequent speaker at EAPA and EASNA events,
Chris brings a unique multi-disciplinary perspective
to the EAP field.
Chris has seen the value of EAP first hand and is one
of the field’s strongest advocates.
5. Disclaimer
5
The information presented to you today is considered
to be general best practices only. The information is
not intended to provide legal counsel or legal advice.
6. Did you know?
6
A dog’s sense of smell is said to be a thousand times
more sensitive than that of humans! They can smell
one week’s history with their incredible noses.
7. Learning Objectives
Understanding documentation and record
management
EAPA Standards and Guidelines
How to manage electronic documents
Protocols for preserving confidentiality and
releasing information
7
10. Definition of Document
10
Any piece of written, printed, or electronic matter
that provides evidence or that serves as an official
record
Forms
Letters
Transcriptions
Emails
Website content
Instant messaging
Social media posts
11. File Management vs. Record Management
11
File management is a series of tools, procedures, and
policies designed to organize and file documents so
information can be easily located and retrieved when
required
Organizations have more
flexibility with file management
systems than record management
protocols
12. File Management vs. Record Management
12
Record management involves identifying, classifying,
prioritizing, storing, securing, archiving, preserving,
tracking, and destroying records
Records must be created and received in compliance
with legal obligations
This can include tangible documents like a driver’s license or
digital information such as data, website content, and
electronic mail
Source: http://en.wikipedia.org/wiki/Records_management
13. Internal Records Management
13
Requires a dedicated staff member or department,
depending on the size of the organization
Standardized across the organization with one point of
contact who can easily obtain requested records
Abide by clear and well documented records
management policies
Can be a combination of physical and digital records
management
Be able to meet all applicable audit standards
Should be audited on a regular basis
Practices, systems, technologies, and facilities
14. Why Documentation Matters
14
Creates an objective historical document
Can help to create and implement new policies and
procedures
Provides objective evidence of services provided to
the organization and clients
15. Why Documentation Matters
15
Provides accurate records to assist with metrics,
certifications, and audits
Helps to protect the service provider in the event of
an accusation of negligence or malpractice
Helps to protect against accusations of professional
misconduct
16. This is not the way to do it!
16
Image: http://www.patrina.com/wp-content/uploads/2012/08/data-compliance-carl-cartoon.jpg
18. EA Program Records
18
All EA program records should comply with EAPA
Standards and Professional Guidelines
All EA Programs should comply with the EAPA
Standard for Record Keeping
The EA program should create and maintain client records
that are consistent with the employee assistance program
service delivery system, organization policies, program
procedures, and applicable legal requirements
There may be variance based on the laws and requirements in
different geographical areas
19. EAPA Standard for Record Keeping
19
1. The EAP must maintain retrievable documentation
of all direct services and recommendations.
2. EAP records must be maintained in accordance
with all applicable laws and regulations.
3. EAP records must be maintained for the minimum
period of time required by law or organization
policy.
20. EAPA Standard for Record Keeping
20
4. The storage, transfer and destruction of records must
be handled in a manner to assure confidentiality.
5. Every effort must be made by the EAP to prevent the
involvement of EAP records in arbitration, litigation, or
any other dispute. EAPs are not in place to help solve
workplace disputes!
6. EAP client records must be kept in a secure location
and be available only to authorized EAP personnel.
Client records and rooms where client records are
stored must be locked, and computerized records must
be maintained in a secure environment and separated
from other data systems and all other records.
21. EAPA Standard for Record Keeping
21
7. The EAP must make every effort to assure the
confidentiality of information sent by mail, fax,
modem, E-mail, or other electronic communication
technology. A limit of disclosure statement must
be included in all communications.
8. Ownership of EAP records must be clearly
delineated through policy or contract language.
9. The content of EAP records must be consistent
with the scope of the service delivery system.
23. Types of Electronic Documents
23
Emails
Text messages
Instant messages
Social media
Image from https://www.koernercpa.com/portals/0/images/electronic-documents.png
25. Email
25
Print email correspondence and place in paper file
Import emails into Customer Relationship
Management programs
Emails should be added to files at regular intervals
Check with your organization about their email management
standards and guidelines
26. Text Messages
26
Texting with clients and co-workers should only be
done from a work issued phone and should be
limited to work related matters
Texts should be printed and placed in the
appropriate file, then deleted
Texts can be transcribed and placed in the
appropriate file, then deleted
Complete text exactly as it was received
Time and date text was received
Phone number the text was sent from
27. Instant Messages
27
Instant messaging with clients and co-workers
should only be done from work approved
programs/apps and should be limited to work
related matters
Instant messages can be printed and placed in the
appropriate file, then deleted
Instant messages can be imported into Customer
Relationship Management programs
28. Social Media
28
Interaction on social media should be limited to
general information sharing designed to enhance
knowledge of services available and how to access
them
Image from http://www.artsalliance.com/wp-content/uploads/2015/02/social-media.jpg
31. Potential Exceptions
31
Provincial or State mandated reporting
Legal subpoena
Labor agreements
Danger to self or others
Company policies
Drug testing regulations
32. Keeping Records Confidential
32
Limited access
Records should be kept in a secured location
Trackable access
There should be a written record of who has access to the documents
Written consent
Some information can be shared with the employer upon receipt of
written consent from the employee
Professional due diligence
33. Keeping Electronic Records Confidential
33
Encryption
Back up systems
Password
protection
Firewalls
Virus Protection
Hardware
Software
Third-party services
34. Release of Information
34
As required, information from an individual case file
is released only after the client has provided written
consent
Written consent is not required in instances where
the law permits the release of information from the
file
35. Written Consent
35
Name of agency or individual to whom the information is
being released
A summary of the specific information being released
Date the consent became
effective
The date the consent expires
The client’s signature
40. Let’s get social!
40
Facebook facebook.com/pages/cghylton
Twitter @HyltonYYC
Google + plus.google.com/u/0/109237546846077340442/posts
YouTube youtube.com/user/CGHylton
LinkedIn ca.linkedin.com/in/cghylton
Editor's Notes
Did you know that a dog’s sense of smell is said to be a thousand times more sensitive than that of humans? They can smell one week’s history with their incredible noses. Unfortunately, humans don’t have that same capability which is why we need meticulous records to keep track of what’s happened!
You can use this image to talk a bit about the evolution of documentation practices over the last few decades.
One of the biggest changes has been the shift from paper documents to electronic documents. This would be a great opportunity to share an anecdote about what record keeping was like when you first opened your business compared to today. Talk a bit about how it has changed and what has improved.
Image obtained from www.processexcellencenetwork.com
For a long time, documents were anything that was on paper: letters, forms, publications, etc.
Now that so much communication happens electronically, the definition of document has expanded to capture the different ways we communicate at work.
EAPA requires that EAPs meet or exceed the minimum regulations in their jurisdiction for maintaining records
Most EAPs in the US follow HIPPA (Health Insurance Portability and Accountability Act) regulations while EAPs in Canada follow provincial guidelines for the maintenance of health information records as well as the rules and regulations set forth by PIPEDA (Personal Information Protection and Electronic Documents Act) and FOIP (Freedom of Information and Protection of Privacy)
Source: www.eapassn.org
There are 9 essential components that make up the EAPA Record Keeping Standard.
For Point 3: this guideline is established by the applicable regulations for maintaining health records and may vary by state, province, and country.
Review each point individually and provide examples or elaboration where applicable.
- Review each point individually and provide examples or elaboration where applicable.
- Review each point individually and provide examples or elaboration where applicable.
- Image from http://www.triplefin.com/technology
- Image from https://www.koernercpa.com/portals/0/images/electronic-documents.png
- All client and work related electronic documentation matters! Everything that you write, regardless of the medium, should be written properly with correct spelling and grammar. Your documentation should always adhere to a professional tone. Never include profanity, inappropriate biases or judgements, or colloquial abbreviations.
Examples of CRM programs currently in use by EAP services include but are not limited to: Penelope Case Management Software, EAP Expert, Medgate, and Daybreak EAP Software
Social media should be used extremely judiciously and should be very closely monitored
Even with safeguards in place, like any form of electronic communication, social media activity can quickly become part of the public domain
Image from http://www.artsalliance.com/wp-content/uploads/2015/02/social-media.jpg
Maintaining confidentiality is the cornerstone of successful EAP services
EAP professionals should clearly and regularly communicate their standards and safeguards for confidentiality to clients
EAP professionals must disclose all conditions that may limit confidentiality
- Image from http://web.jhu.edu/sebin/b/b/data-recovery-confidential.jpg
EAP and the organization’s leadership can reasonably determine the implications and limits of confidentiality for areas such as provincial/state mandated reporting, legal subpoenas, labor agreements, danger to self/others, company policies, and drug testing regulations
BUT the EAP MUST fully disclose conditions that limit confidentiality such as those listed above
- Excerpted from http://www.eapassn.org/Portals/11/Docs/EAPAStandards10.pdf
- Review and provide examples or elaborate on each point
Encryption: EA Professionals understand how to access encrypted services to store records and deliver communication. Record storage can be hosted on a secure server with a third-party, stored on the EA Professionals’ hard drive utilizing encrypted folders or stored on an external drive that is safely backed up.
- Backup Systems: Records and data that are stored on the EA Professionals’ hard drive are backed up either to an external drive or remotely via the Internet.
Password Protection: EA Professionals ensure confidentiality of client communication and other materials by password protecting their computer, drives and stored files or communication websites.
Firewalls: EA Professionals utilize firewall protection at multiple levels: desktop/laptop operating system level, local area network level and additionally utilize firewall resources provided by their Internet service provider.
Virus Protection: EA Professionals assure that their work computers are protected from viruses that can be received from or transmitted to others.
Hardware: EA Professionals understand the basic running platform of the work computer and know whether or not a client’s hardware/platform is compatible with any communication programs the practitioner uses.
Software: EA Professionals know how to download and operate software and assist employees and their families with the same when necessary to the delivery of services.
Third-party services: EA Professionals utilize third-party technology service providers (e.g. for backup, storage, virus protection and communication) that offer an address and phone number so that contact is possible via means other than email.
- From http://www.eapassn.org/TechinEAPs
In cases where written consent is not required to release information:
As previously mentioned, limits to confidentiality must be explained to clients at the onset of services, both verbally and in writing
Clients should sign a Statement of Understanding that outlines the limits to confidentiality
The EAP must inform clients when confidentiality is impacted
Excerpted from http://www.eapassn.org/Portals/11/Docs/EAPAStandards10.pdf