Minnesota Minnesota

Program HH Policy Manual

Program HH Policy Manual

Confidentiality and record retention

Page posted: 8/5/20

Page reviewed: 8/2/22

Page updated: 8/2/22

Legal authority

Minn. Stat. Ch. 13, Minn. Stat. §138.17, Health Insurance Portability and Accountability Act of 1996 (HIPAA)

Overview

The Ryan White HIV/AIDS Treatment Extension Act of 2009 codifies a variety of core medical and support services provided to eligible people with HIV. The Minnesota Department of Human Services (DHS) directly administers Ryan White program services for eligible people with HIV under Program HH.

Program HH provides access to crucial medications and care services for people with HIV in Minnesota. It includes:

  • · Minnesota AIDS Drug Assistance Program (ADAP) or Drug Benefit.
  • · Insurance Premium Assistance (IPA).
  • · Dental Benefit.
  • · Mental Health Benefit.
  • · Nutritional Supplement Benefit.
  • · Limited Medication Therapy Management Services (MTMS).
  • Program HH follows strict rules to protect data about people who receive services. Staff must complete confidentiality and security training annually and sign a confidentiality statement before they can access Program HH files and data.

    Storing confidential information

    Electronic data

    Program HH electronic data is stored on a secure server. Only authorized staff can access the data with a valid user ID and password.

    Physical files and data

    Program HH stores hardcopy, confidential data about people who receive services on a secure floor to ensure information is safeguarded. Staff scans paper files into an electronic database and stores the paper files in a locked cabinet for three months. Staff access is restricted to certain hours and days. Capitol Security monitors building access.

    Disposal of materials

    Program HH maintains paper and electronic records according to the program’s record disposal schedule. Inactive records are stored confidentially onsite or at the State Record Center for the required time period and then destroyed confidentially.

    Program HH securely shreds all hardcopy, confidential data when it is no longer needed. A specially equipped truck arrives weekly to shred materials onsite. A DHS security guard monitors the shredding.

    Communicating with Program HH staff

    Mail

    Program HH staff sends all Program HH mail in DHS envelopes that do not identify Program HH, ADAP or HIV/AIDS. People receive self-addressed, stamped envelopes (SASE) that also do not identify HIV/AIDS. The return address on the SASE is not identifiable as belonging to Program HH.

    Fax

    People who receive services and their medical case managers may fax Program HH applications and related materials to Program HH. Program HH receives the materials through Rightfax. Rightfax is a program that stores all Program HH faxes electronically. Only Program HH staff have access to the Rightfax account.

    Email

    Minnesota Health Care Program (MHCP) member ID numbers (or Person Master Index [PMI] numbers) are used in email communication between staff members and case workers. Emails do not include people’s names.

    Emails with private data from Program HH staff to case managers are encrypted. For more information, refer to CBSM – How to exchange private and protected information via email with DHS.

    Phone

    Program HH staff frequently communicates with people who receive services via phone. Staff verifies a person’s identity by asking for their MHCP member ID number (or PMI number), Social Security number or full name and date of birth.

    Additional resources

    Program HH Policy Manual – Rights and responsibilities
    CBSM – How to exchange private and protected information via email with DHS

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