Section 8: Other Clinic Policies

8.1 Confidentiality and Medical Records

Each student must hold all information regarding the business of NUNM Health Centers, medical records information, patient interactions and clinical consultations as confidential. In the course of the student’s medical education at any NUNM health center, all information concerning patients, students, staff, employees and physicians should be treated with the same sense of confidentiality. All staff, faculty and students working at the clinics are required to sign a confidentiality statement.

Confidentiality and HIPAA

The Health Information Portability and Accountability Act (HIPAA) was established to protect patients by preventing the inappropriate use or transmission of patient healthcare information. Special consideration was given to the technological advancements developing within healthcare professions, and the level of confidentiality associated with ever-changing methods of communication. Students will receive training about HIPAA and NUNM’s confidentiality policies before beginning as clinicians at NUNM Health Centers. As an additional prerequisite to clinical work, students will be provided with NUNM’s confidentiality policy and must agree to uphold the conditions of the policy.

Confidentiality and the Rule of “Need to Know”

In order to provide patient services, clinic employees and clinicians have a need to know some patient health information. Those affiliated with the clinic in providing patient services only access the patient information that they need to know, and only to the extent that they need to know it, for provision of patient services. This information is then maintained in strict confidence and is only shared with others who, like them, have a need to know in order to provide services to the patient. In order to further protect our patients’ confidentiality, discussion of patient information must be avoided in public areas.

Please refer to NUNM’s confidentiality policy for more information about confidentiality, HIPAA and protected health information.

Breach of confidentiality is an extremely serious violation and may result in immediate termination of a student’s educational agreement and/or other sanctions as appropriate.

Medical Records

All individuals engaged in the collection, handling or dissemination of patient health information shall be specifically informed of their responsibility to protect patient data and of the penalty for violation of this trust. Proven violation of confidentiality of patient information shall be cause for immediate termination of access to further data, and immediate termination of any student. This policy shall be made known to all students at the time clinical training begins, and each student shall indicate their understanding and willingness to comply with the policy through a signed statement at the time of clinic orientation. The statement shall be kept with students’ clinical record (see “Confidentiality Agreement” form).

NUNM Health Centers use the Epic electronic health record system. This system includes patient management (scheduling and billing) and electronic medical record components. In order to maintain a high standard of protection, clinical faculty, students and clinic employees are the only people with access to this secured system.

Regarding medical records:

  • The patient owns their chart information and may access any of its content at any time. NUNM is the custodian of the chart.
  • Confidentiality of all patient health information is legally protected.
  • Requests for patient charts not accessible in Epic, on paper and electronic archives, are submitted in writing on chart pull-slips to the clinic services representatives and medical records personnel. Chart pull-slips are used with out-cards to track the paper chart’s location in the clinic, and the person responsible for the chart, until it is refiled on medical records shelves.
  • Paper charts and any patient documentation are not to be left unattended or in unsecured areas including clinic conference tables.
  • Paper charts and any patient documentation must be kept on clinic premises at all times.
  • Students may request copies of patient charts to be used for educational purposes, such as case presentations and theses, by submitting a “Student Chart Copy Request” form to medical records.
  • All other chart copies require patient authorization for release of information and must be submitted on a HIPAA-compliant “Authorization for Release of Medical Records” form by the patient. Please ask for these forms through the medical records department.
  • Unauthorized chart copying is illegal and will be handled through the campus judicial process. Sanction may include suspension from the clinic and/or NUNM.
  • In order to further protect the confidentiality of our NUNM community, students must obtain the authorization of their supervising faculty member (on the chart pull-slip) to pull any of the following patient charts: 1) their own chart; 2) another student’s chart; or 3) an employee’s chart.

8.2 Professional Attire at NUNM Health Centers

The intent of NUNM guidelines for attire and hygiene is to present a safe and professional appearance to patients and their families; it is not to inhibit personal freedom or style. Medical students have an important and unique role in the clinical encounter, and appearance has an impact on that role.

At NUNM we strive to provide excellent patient care. A large part of developing an effective rapport is to make the patient as comfortable as possible. Many studies have shown the impact the appearance of a physician has on a patient. Additionally, adherence to NUNM policy on professional attire is a reflection of respect for the faculty.

A student who is not in compliance with the below listed policies will be asked to leave the shift, and will lose credit hours as appropriate as an unexcused absence from the shift. The student may return to the shift once the violation has been corrected.

Dress Code Policy

It is the responsibility of all students, faculty and staff to maintain personal dress and cleanliness consistent with patient care and OSHA regulations. Enforcement of these regulations is the responsibility of all faculty, staff and students. Students must follow the established dress code for all NUNM Health Centers:

  • An NUNM identification badge in a visible location is required AT ALL TIMES.
  • Students must wear clean, neat, unwrinkled and appropriate professional attire, which includes pressed dress shirt with a tie, dress pants or slacks, dresses, skirts, and close-toed dress shoes.
  • Skirts or dresses should touch the top of the knee or longer when seated.
  • Shirts and blouses must have sleeves. Tank tops or other sleeveless tops are not allowed unless a white coat is worn over the shirt.
  • NUNM has a scent-free (natural and synthetic) policy that must be observed by students (refer to the NUNM university policy for details). Offensive odors, including body odor and strong smelling breath, will be addressed.
  • Earrings are limited to no more than two per ear, and must be studs or short dangling earrings. Dangling earrings more than one inch long are not appropriate. Holes in ears should be limited to 2mm in diameter. A student who has matriculated at NUNM with large ear holes may seek an exception to this rule. Ear piercing and single nose piercings with small studs on a single side are permitted. No other visible body piercing, including, but not limited to, tongue piercing and eyebrow rings/bars are permitted.
  • Hair must be clean, well groomed, and worn in a manner that will not interfere with patient care or comfort. Hair past shoulder length should not be able to touch patients. This may mean that it be required to be tied back or kept under a head wrap if necessary. Facial hair must be kept clean and trimmed to no longer than one inch, or put into a clip.
  • Hats, with the exception of religious head coverings, are not appropriate.
  • Makeup may be worn in moderation.
  • Fingernails must be kept short, clean, neatly manicured, and not extend more than one-quarter inch past the fingertips. Artificial nails and nail jewelry are prohibited per health department regulations in any patient care role. Artificial nails are defined as any application of a product to the nail to include, but not limited to, acrylic, overlay and tips of silk wraps (does not refer to nail polish). Chipped nail polish is not permitted.
  • Shoes must be closed-toe and non-skid and of low or moderate heel (2 ½ inch maximum). Clean athletic shoes may only be worn with scrub attire.
  • Any visible tattoos with nudity or expletives must be covered. Other tattoos, that may be considered offensive by patients, may be requested to be covered.
  • Clothing should not expose the chest, abdomen or back.
  • Supervising faculty may have additional dress requirements as appropriate to their specific shifts.

Naturopathic Medical Students (in addition to the above)

  • At NUNM Health Centers, all ND students will wear an NUNM-logo white coat identifying them as part of the provider team.
  • Solid blue or green scrubs may be worn by hydrotherapy students.

8.3 Probation and Disciplinary Policy

In the event that a student’s conduct in clinic is inappropriate, the clinic supervising faculty may document the incident by submitting an incident report. A copy may be forwarded to the student and other administrators, such as the chief medical officer and program dean. Doctors may, at their discretion, report the following issues and behaviors of any students who they believe have violated any NUNM rule or policy including, but not limited to, the following:

  • Arrival to shift unprepared for treatment plan/assignment
  • Missing/late for patient appointment by more than five (5) minutes
  • Missing/late to case preview/review by more than five (5) minutes
  • Not following the clinic absence/substitute policy
  • Being unavailable while on a scheduled clinic shift
  • Acting without the attending physician’s permission
  • Not following the clinic protocols/standards
  • Not following the physician instructions
  • Inappropriate dress
  • Unprofessional behavior or conduct such as the following:
    • Inappropriate remarks
    • Improper draping
    • Breach of patient confidentiality
    • Diagnosing/treating a patient without supervising faculty approval
    • Not following supervising faculty’s recommendations
    • Other professional misconduct
  • Violation of, or failure to comply with, any other rules or policies of NUNM

Note: Any incident that may violate NUNM’s discrimination and/or harassment policies must be immediately reported as provided in the Gender Discrimination and Sexual Misconduct policy, addressed in Section 13, of the student handbook.

All non-academic reports are reviewed by the dean of students, with a possible referral to the Honor Council as outlined in Section 14 of the student university handbook.

8.4 NUNM Campus Clinic Parking Policy

The parking lot at the clinic is for patients only. NUNM students, staff and faculty may not park in the clinic lot unless they are being seen at the clinic as a patient or as a customer of the lab or medicinary.

8.5 Internal/External Referral Policies and Procedures

Policy (Internal Referrals)

In accordance with its mission to provide outstanding medical care to its patients, and because NUNM Health Centers have extraordinary expertise and talent amongst its practitioners, NUNM Health Centers encourages the internal referral of patients for specific treatments.

Procedure (Internal Referrals)

If an NUNM Health Centers location uses an electronic health records system, referrals are made electronically. Hard copy referrals are accepted from community clinics that are not on an electronic health record system.

  • Clinical supervisors fill out the NUNM referral form, hard copy or electronic, for all patients being referred to other internal medical departments (e.g., Chinese medicine, IV shifts, physical medicine, homeopathy shifts, etc.). Referrals use the SBAR (Situation, Background, Assessment and Reason) format for referral or recommendation. Clinicians use this structure to standardize communication.
  • It is required that the treating practitioner communicate findings and treatments to the referring practitioner(s). This is common in private practice and is expected as a basic courtesy by most referring physicians.
  • The physician answers any questions the patient may have regarding the internal referral process.
  • For hard copy referrals, any findings and treatments from the referral physician are to be summarized in one or two paragraphs and forwarded back to the referring physician and primary on a continual basis in a timely manner. A copy of this communication is kept in the patient’s medical record. For electronic referrals the referral physician will document directly into the patient’s electronic health record.

Policy (External Referrals)

If an NUNM Health Center location uses an electronic health records system, referrals are made electronically. Hard copy referrals are accepted from community clinics that are not on an electronic health record system.

Each clinical supervisor will ensure that the appropriate referrals occur for clinic patients as necessary.

Procedure (External Referrals)

NUNM Health Centers’ referral protocol are: The clinic physician recommends a referral doctor and/or location to the patient and sends a referral request to the referral coordinator at NUNM Health Centers–Lair Hill. The clinician documents that the referral was recommended and discussed with the patient in the patient’s chart using the SBAR format (Situation, Background, Assessment, and Reason for Referral). An electronic referral, phone call or standard office form is initiated by the Referral Coordinator using the information obtained from the clinician.

  • In the event of the need for a patient referral, it is the responsibility of the clinical supervisor doing the referral to sign any referral letters or orders regarding the patient’s care.
  • The clinical supervisor will fully explain to the patient in person why a referral is needed or advised, and will address any concerns the patient may have.
  • The clinical supervisor will ensure that all documents required from the patient is communicated to the patient, and that the referral will not be processed without the required documentation.
  • For referrals between NUNM Health Centers, the NUNM fee schedule will be discussed with the patient.
  • In the event that the patient refuses the referral, it is the clinic supervisor’s responsibility to ensure the refusal of referral is documented in the patient’s medical chart.

8.6 Referrals for Diagnostic Imaging

Policy

  • NUNM has negotiated arrangements with diagnostic imaging companies where uninsured patients can get a discount on certain imaging services when referred by NUNM Health Centers. The amount of the discount is subject to change. Currently, the rate is discounted by 20% at Epic Imaging.
  • If a patient has insurance, the patient will be asked to use it for payment and the insurance company’s preferred imaging vendor. Most are contracted with Epic Imaging.
  • To make a diagnostic imaging referral, follow the guidelines below.

Procedure

  • Uninsured: Complete the EPIC Imaging referral form completely and give to the medical records department for faxing to EPIC, or give it to the patient directly (after making a copy). EPIC referral forms can be found in health center conference rooms and the Lair Hill “handout filing cabinet.”
  • Insured: Follow the same procedure as above, but confirm with the patient’s insurance provider that Epic Imaging is acceptable. If not, make the referral to the appropriate imaging center, e.g., Providence requires their plan members to get imaging services at Providence.