First Healthcare Compliance CONNECT October 2022
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need to say. But all of this behavior is something you<br />
can expressly prohibit.<br />
What you can’t prohibit and what a lot of social<br />
media policies say is that you may not post anything<br />
online that criticizes the company or its customers,<br />
clients, patients, etc. That is a type of policy that the<br />
NLRB has been extremely suspicious of, and this is<br />
a good time to pare back those sorts of nebulous<br />
requirements. But, of course, in the healthcare<br />
context, we have some additional overlays. Most<br />
employees have HIPAA obligations, right. And you<br />
can absolutely say you may not post anything online<br />
that violates your duty of confidentiality under HIPAA.<br />
It’s when we’re talking more broadly, in the vein<br />
of “if you don’t have anything nice to say, don’t say<br />
anything at all” that the NLRB will become more<br />
critical.<br />
Risk Management Considerations for<br />
the <strong>Healthcare</strong> <strong>Compliance</strong> Officer:<br />
Training, Incident Management,<br />
Governing Boards, and<br />
Measures Unique to COVID-19<br />
It’s no secret that healthcare is one of America’s<br />
most heavily regulated industries with substantial<br />
fines and penalties for non-compliance. Complex<br />
regulations and mandates make compliance<br />
management a necessity.<br />
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