There has been a significant growth in recent years in companies offering web-based HIPAA training courses. While these courses can provide valuable information about HIPAA and the reasons why policies and procedures exist to safeguard Protected Health Information (PHI), not all courses necessarily fulfil the HIPAA training requirements.
The significant growth in web-based training courses is not exclusive to HIPAA. Many organizations have adopted digital learning due to the cost-effectiveness, convenience, and scalability of web-based training. In addition, some studies suggest web-based training can boost knowledge retention due to students being able to learn at their own pace and revisit course material on demand.
In addition, web-based training is considered a safer option than classroom-based training during the COVID-19 pandemic. Furthermore, for many organizations, the option to provide training remotely has released personnel to fill gaps in the provision of healthcare attributable to illness, self-isolation, and burnout – further accelerating the adoption of web-based HIPAA training.
Web-Based HIPAA Training and the Initial HIPAA Training Requirements
Although the adoption of web-based HIPAA training has increased significantly, it is important to be aware that not every online training course fulfils the initial HIPAA training requirements – that Covered Entities train new members of the workforce on “policies and procedures with respect to PHI […] as necessary and appropriate for members of the workforce to carry out their functions”.
This is because Covered Entities´ policies and procedures should be determined by risk analyses. Risk analyses can have different outcomes depending on the nature of each Covered Entity´s operations and its propensity to risk, and therefore it is impossible for companies offering web-based HIPAA training courses to develop a “one-size-fits-all” course that is appropriate for all workforces.
Nonetheless, Web-Based HIPAA Training Can Still be Beneficial
Nonetheless, some content of outsourced training courses will be sufficient for some new members of the workforce to carry out their functions. However, there will be cases in which other new members of the workforce require in-house training as well as outsourced training in order to have all the information they need to carry out their functions in compliance with HIPAA.
For these other members of the workforce, web-based HIPAA training can still be beneficial as an introduction to HIPAA and HIPAA compliance. This foundation in HIPAA makes it easier for Covered Entities to prepare subsequent in-house “policy and procedure” training as it will not be necessary to explain to new members of the workforce why certain policies and procedures exist.
Material Change and Refresher HIPAA Training
Beyond the initial HIPAA training requirements for new members of the workforce, Covered Entities are required to provide further training when “functions are affected by a material change in policies and procedures”, or when a risk analysis identifies a need for additional “refresher” training. Changes attributable to revised HIPAA regulations may also result in a need for further training.
In these circumstances – and when refresher training is provided as a “best practice” – web-based HIPAA training courses can again be the most cost-effective, convenient, and scalable option depending on the nature of the material change or refresher training required. Web-based training is certainly far more cost-efficient when small groups of the workforce require refresher training.
The HIPAA Security Rule Training Standard
The HIPAA Security Rule training standard stipulates that both Covered Entities and Business Associates must implement a security and awareness training program for all members of the workforce – including management. This means even members of the workforce with no access to ePHI should receive training on cybersecurity best practices to reduce risks to ePHI.
Web-based HIPAA training is ideal for complying with this standard as it can cover topics such as secure browsing, good password management, and preventing susceptibility to phishing – topics which are important to online security for all organizations (and the individuals who work for them), regardless of the nature of data a cybercriminal is attempting to extract.
Modular is the Best Type of Web-Based Training
As well as there having been a significant growth in web-based HIPAA training courses, there has also been a growth in the types of web-based training. Courses can be self-paced or instructor-led, or take two hours to complete (too little information) or two days to complete (too much information). Some will even issue a certificate just for watching a video.
The ultimate objective of HIPAA training is ultimately to have a HIPAA-compliant workforce; so the best type of web-based training is training that helps achieve this objective. As mentioned above, self-paced training with the option to revisit course material on demand can boost knowledge retention; and modular training with a questionnaire at the end of each module not only enables trainees to do this, but it also helps Covered Entities and Business Associates more easily track and document HIPAA training for each member of its workforce.
Web-Based HIPAA Training FAQs
How frequently should HIPAA refresher training be provided as a best practice?
Most compliance experts agree that workforces´ retention of HIPAA declines over time; and although some members of the workforce will have better knowledge retention than others due to the nature of their functions, it is recommended that HIPAA Privacy Rule refresher training should be provided at least annually – even if there has been a material change in the current year.
Should HIPAA security and awareness refresher training also be provided annually?
No. The standard relating to security and awareness training (45 CFR § 164.308 (5)(i)) states Covered Entities and Business Associates should implement a security and awareness training program – the inclusion of the word “program” implying that security and awareness training should be ongoing rather than a one-off event supported with periodic refresher training.
How might a risk assessment identify a need for further Privacy Rule training?
Although risk assessments are a requirement of the Security Rule, they can identify a need for further Privacy Rule training. If, for example, a Covered Entity identifies an increase in complaints from patients experiencing access request delays, a risk assessment can help determine whether the issue is due to an inefficient process or whether staff involved in the process require more training.
When might web-based HIPAA training be sufficient for new members of the workforce?
Most web-based HIPAA training courses include topics such as the basics of the Privacy Rule, allowable uses and disclosures of PHI, computer safety rules, and how best to prevent HIPAA violations. There are many roles within a Covered Entity for which a knowledge of these common areas of HIPAA will be sufficient to meet the HIPAA training requirements.
Why do members of the workforce with no access to ePHI require security and awareness training?
Data breaches are not always attributable to attacks against individuals with the most access to ePHI because these individuals are often more security-conscious. Sometimes it can be easier for a cybercriminal to obtain login credentials from a less security-aware individual, and then navigate through the system until they identify a vulnerability that can be exploited to extract data. For this reason, it is important all members of the workforce undergo security and awareness training.
Is the documentation of training a requirement of HIPAA?
According to the Administrative Requirements of the Privacy Rule (45 CFR §164.530 (b)(2)), all HIPAA training – whether outsourced or provided in-house – must be documented by Covered Entities. As the purpose of documentation is to establish the burden of proof in the event of a HIPAA inspection, audit, or investigation, it is also recommended Business Associates also document all HIPAA training.
