On Thursday, March 24th, Pam Taylor, PhD, RN-BC, CPHIMS, owner of Total Clinical Placement System, presented a webinar entitled "Using Clinical Placement Tools to Streamline Student Onboarding." Below are the answers to questions posed during the webinar.
Q1: When you discuss the attestation vs. facilities collecting personal data--I'm not sure I understand. We have built in our contracts that personal information such as immunization records are stored at the school but must be made available upon request. For our access to EMR we must have student names, birthday and last 4 of SSN and we also collect emergency contact information from each student--so based on our practices are we a "blended" method for gathering student information? I'm assuming attestation decreases our risk, but we certainly need some of the information or students will not gain access to our EMR.
A1: Access to student data can certainly be outlined by the school affiliation contracts. The key is to make sure that when you do collect the data that it is treated as personal information and stored/discarded appropriately. The personal data needed for EMR access is really no different that is collected on an employee.
Q2: Does FERRPA apply to high school students’ clinical placements?
A2: Yes, FERPA covers all ages of students.
Q3: Does the clinical placement tool support scheduling multiple sites?
A3: Clinical Placement tools should support multiple sites. This is a question to ask the vendor in the selection process. TCPS PlacementPro does support multiple sites.
Q4: Are you able to schedule in and out patient environments?
A4: Clinical Placement tools should support the in- and out-patient environments. This is a question to ask the vendor in the selection process. TCPS PlacementPro supports any healthcare environment.
Q5: Will you elaborate on what components of pre-implementation data to collect?
A5: Pre-implementation data that can be useful to collect prior to implementation for data supported ROI calculations include:
- Number of clinical placements (Be sure and use a standardized definition of a clinical placement! I traditionally use a single shift, single day, and single unit during an academic term or portion thereof for a single school as the definition.)
- Time spent approving/denying clinical placements by all involved employees
- Time spent creating reports related to clinical placements.
- Time spent on development, preparation and delivery of Student orientation by all involved employees
- Time spent on development, preparation and delivery of Faculty orientation by all involved employees
Additional data needs could be identified based upon your target goals for implementing student onboarding tools.
Q6: Will you cover cost? Do organizations tend to pass this cost onto the school or students? What has been the response from schools? Does this impact the # of schools requesting placement?
A6: I’ve seen the cost of related to clinical onboarding tools absorbed by the facility as a community engagement/marketing/employment pipeline support line item. I’ve also seen it passed back to the school either as a specific charge for providing clinical opportunities, or by requiring them to join a collaborative to share the cost. How the implementation of the onboarding tools is approached (as a process to streamline placement requests and subsequent orientation requirements) with the schools can go a long way in their acceptance of the fees related to the use of technology.
Q7: What about the CMS Inpatient Quality requirement that student's flu vaccines are required to be submitted to the facility for reporting? Would this be PHI covered by FERPA?
A7: CMS does not require any specific student data – only the number of students (trainees) in the facility between October 1 and March 31 that had a flu vaccine, the number that had a medical waiver, and the number who declined. Healthcare organizations collecting more information about the immunization (date, provider, lot number, etc.) pushes the data in over into the “employee record” category that must be protected under Federal guidelines for storage and disposal.
Q8: Can requests from schools be staggered based on priority schools? Such as BSN schools scheduling,
A8: Clinical Onboarding tools should not set policy. It is up to the facility to respond to placement requests based upon their own goals and policies. In TCPS PlacementPro, DEUs may be identified, specific patient care areas may be designated for BSN only, etc.
Q9: Can you clarify what data needs to be collected for standard regulatory bodies?
A9: Students in the healthcare environment present a challenge in data management since they are technically NOT employees, but are in the healthcare organization and often providing hands on patient care. Regulatory agencies only mandate that student screening qualifications match what is done for employees. This does not mandate data collection that is held by the healthcare organization. Proof that the screening was done and that the data met organization criteria is sufficient for regulatory surveys. Affiliation agreements should mandate what screenings and pre-requisites are needed that can include criminal background checks, urine drug screens, immunization records/waivers, and current CPR training. Remember that if your affiliation agreement requires certain data to be on file with the school, then an attestation statement from the school that all data requirements are met on each student is sufficient. If this data is transferred to the healthcare organization, remember that it must be treated as employee data, and protected/discarded appropriately since it contains sensitive information. Student Onboarding tools can store the attestation data which is a huge time saver for the school. Having access online to this data when The Joint Commission or State visits provides immediate access rather than waiting for the school to respond with to an audit request related to the visit.
Q10: Can you give an example of a collaborative arrangement?
A10: Collaboratives are generally formed between a group of facilities and schools (or it could one facility and the schools that send students to the facility) that come together to use a common set of clinical onboarding tools and work together to standardize related processes. I have worked with both types of collaboratives to implement onboarding tools.
Q11: How can you implement an onboarding system like this for students when you are also required to provide staff education programs and new hire orientation?
Q11: One of the goals for implementing clinical onboarding tools is to streamline this work so you can meet those other responsibilities. While you may need to phase in the various tools based upon your own needs, the outcome should be decreased time spent once the system is in place.
Q12: Does the scheduling tool keep requests private from the other school requests?
A12: Our placement scheduling tool readily shows if another request is in the system for a given placement to alert additional schools requesting the same placement that a decision between schools will have to be made if they submit the placement request. This feature often saves time for the school and minimizes multiple requests for the same learning opportunity.