Question

Are pre-professional students allowed to observe (“Pre-professional observers”) healthcare providers in clinical and/or procedure areas to learn about the roles of providers and to better understand the healthcare profession?

Answer

Generally speaking, such activity is limited to designated professional students enrolled in or affiliated with University of Chicago Medical Center programs.  However, there are circumstances under which other individuals may observe healthcare providers.  The following guidelines must be met before Pre-professional observers can observe/shadow providers

• Pre-professional observers must be enrolled in an educational institution that has a formal observation/shadowing program as part of its curriculum.  There must be an University of Chicago Medical Center provider who sponsors and accepts responsibility for the observers.

• The University of Chicago Medical Center sponsoring provider must submit (a) materials about the originating institution’s program to the HIPAA Program Manager (4-9716) for review for the purpose of establishing compliance with item A. above, and (b) a schedule of activities to assist the sponsor with planning the visit to maximize patient privacy.

If the HIPAA Program Manager approves the sponsor’s request with respect to compliance with patient privacy and confidentiality, the following guidelines shall apply: 

1. Observers must complete HIPAA privacy training and sign a confidentiality agreement.  The signed    confidentiality agreement should be kept by the sponsoring provider for documentation purposes.
   
   
2. Observation is not allowed in areas involving highly confidential information (HCI).  HCI is defined in regulation as information related to the treatment of any of the following:  Mental Illness or Developmental Disability, HIV/AIDS Testing or Treatment, Communicable Diseases, Venereal Disease(s), Substance (i.e. alcohol, drugs) Abuse, Abuse of an Adult with a Disability, Sexual Assault, Child Abuse and Neglect, Genetic Testing, Artificial Insemination, and Domestic Violence.
   
   
3. Observers must receive a temporary ID that specifies the period of time during which the observer may be present.  The ID must be returned to the sponsor when the shadowing program ends.
   
   
4. If the sponsor wishes to provide observers direct patient contact, then (a) the sponsor shall obtain permission from the patient’s attending physician or designee and (b) the patient’s attending physician or designee shall seek the patient’s approval outside the presence of the sponsor and observers.  The patient’s answer must be respected.
   
   
5. Observers must not interfere with or participate in the provision of health care.
   
   
6. If observers will be in the OR, they are required to follow the UCH Visitors to the OR policy, MSO PC-50.

Please note that this guidance applies only to pre-professional student observers and not vendor representatives.  Issues involving vendor preceptorship programs have been addressed in a Faculty Advisory which can be accessed on the HIPAA website – http://hipaa.bsd.uchicago.edu.

Please call the HIPAA Program Office at 4-9716 if you have any questions.