Policies & Procedures

Eastern Florida State College is dedicated to providing a nondiscriminatory environment which promotes equal access, equal educational opportunity, and equal employment opportunity to all persons regardless of age, race, national origin, color, ethnicity, genetic information, religion, sex, gender, sexual orientation, pregnancy, disability, marital status, veteran status, ancestry, or political affiliation in its programs, activities, or employment.

EFSC recognizes the rights of students and applicants with disabilities, including those with hepatitis B, under the protections of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.

1. Definitions. The following definitions apply to this Agreement:

• Disclosure means, with respect to Protected Health Information, the release, transfer, provision of access to, or divulging in any other manner such information outside the entity that maintains the information.

• Protected Health Information or PHI means any individually identifiable health information in any form, including information related to payment for health services provided by Facility.

• Use means, with respect to Protected Health Information, the sharing, employment, application, utilization, examination or analysis of such information within the entity that maintains the information.

2. Nature of Agreement. The College performs and will perform the services or functions listed under Specific Responsibilities of Eastern Florida State College set forth above. Subject to the terms and conditions of this Agreement and the HIPAA Privacy Standards, College  may use Protected Health Information:

• as reasonably necessary for the purposes set forth above;

• for the proper management and administration of the College training program; and

• to carry out College's legal responsibilities.

3. Duties of College. College will comply in all material respects with the HIPAA Privacy Standards when using or disclosing Protected Health Information College receives directly or indirectly from Facility or in College's performance of its duties under this Agreement. In furtherance of the foregoing, College agrees to the following:

• College will only use PHI to the extent necessary to perform its duties pursuant to this Agreement.

• College will use and disclose the minimum PHI necessary to perform its duties to this Agreement.

• College will reasonably safeguard the PHI from being used or disclosed except as permitted above.

• College will promptly notify Facility when it uses or discloses the PHI other than as allowed above.

• If College discloses PHI to any agents or subcontractor, College must ensure that such agents and subcontractors agree to comply with the restrictions, conditions and duties that apply to College in this Agreement. Within five (5) business days of request by Facility, College will make available to College certifications that each College's agents and subcontractors have agreed to so comply with the restrictions, conditions and duties that apply to College in this Agreement.

• Within five (5) business days of request by Facility, College will make available to Facility all of the PHI College maintains.

• If requested, College will make available its policies and procedures and books and records relating to its uses and disclosures of the PHI to the Secretary of the Department of Health and Human Services so that the Secretary may determine whether Facility has complied with the HIPAA Privacy Standards.

• When notified by Facility, College will make amendments or corrections to any of the PHI which College maintains.

• When requested by Facility or upon termination of this Agreement, College will return to Facility all of the PHI, including copies in any form or alternatively, if requested by Facility, destroy such PHI and all copies (and certify such destruction to Facility). If it is not feasible to return or destroy the PHI, College will follow the restrictions of this Agreement regarding the PHI retained and will limit further uses and disclosures to those purposes that make return or destruction infeasible.

• Within fifteen (15) days of Facility's request, College will provide to Facility an accounting of all College's disclosures College will maintain a process to provide this accounting of disclosures for as long as College maintains the PHI.

4. Remedies Upon Breach or Facility's Suspicion of Breach. Upon a breach or a suspected breach by College of a material term of this Agreement, Facility, at its option, may require College to:

• Furnish to Facility copies of its practices and procedures and books and records to facilitate Facility's mitigation of damages arising from an improper use or disclosure of the PHI by College;

• Exercise all reasonable efforts to retrieve improperly used or disclosed PHI;

• Establish and adopt new practices, policies and procedures to ensure that the PHI is not used or disclosed in the future in violation of this Agreement or the HIPAA Privacy Standards;

• Comply with all auditing or reporting requests by Facility to demonstrate College's compliance with the HIPAA Privacy Standards; and/or

• Take such other actions as Facility may reasonably require.

5. Change of Law; Applicable Law. If any state or federal laws or regulations, now existing or enacted or promulgated after the effective date of this Agreement, are amended or interpreted by judicial decision, a regulatory agency or legal counsel to a party to indicate that any provision of this Agreement may be in violation of such laws or regulations, the parties will in good faith negotiate to amend this Agreement to ensure compliance with such laws or regulations. This Agreement and its validity, construction, and performance shall be governed in all respects by the laws of the state in which the Facility is located and by the HIPAA Privacy Standards.

6. Cooperation. College will fully cooperate with Facility and render such assistance as may be reasonably required in the event of litigation or administrative proceedings with respect to any violation or claimed violation of the HIPAA Privacy Standards or related laws.

COMPANY COMPLIANCE PROGRAM AND CODE OF CONDUCT

1. Facility's Compliance Program and Code of Conduct. College acknowledges that it has received a copy of the Facility's Code of Conduct. To the extent that the College is aware of any violation the College and its Representatives (e.g., employees/agents) shall immediately notify the Facility of any violations or suspected violations of the Code of Conduct, including violations of laws governing Medicare, Medicaid and other federal healthcare programs, by notifying the Company's Compliance Hotline as set forth in the Code of Conduct.

2. College's Eligibility to Participate in Federal Health Care Programs. To the extent that the College is aware of the status of its representatives who will provide services pursuant to this Agreement, it will allow only such representatives and students who are fully eligible to participate. College represents and warrants to Facility that: (a) neither it nor any of its representatives, who will provide services pursuant to this Agreement, are currently excluded, suspended, debarred or otherwise ineligible to participate in federal health care programs, including the Medicare and Medicaid programs; and (b) neither it nor any of its representatives who will provide services pursuant to this Agreement, have been convicted of a criminal offense related to the provision of health care items or services that would lead to mandatory exclusion from federal health care programs, but have not yet been excluded.

DRESS CODE FOR CLASS/CLINIC

Students must dress in a neat, professional and appropriate manner as prescribed in your Learning Resource Guide (LRG) when participating in Clinical Education Courses and Clinical Observations.

Please remember that you are representing the medical profession and Eastern Florida State College when you are in class/clinic. Your conduct and appearance is expected to demonstrate that at all times. Failure to adhere to the class/clinic dress code will result in a written warning from the Instructor. If this warning is not heeded, removal from clinic will result, with a grade of "F" may be given.

STUDENT IDENTIFICATION BADGES

Student photo identification badges are required to be worn at all times. Details about the distribution will be announced during enrollment. This badge is required to gain entry into Eastern Florida State College, Health Sciences Campus buildings and approved clinical facilities.

Distance education students (those in web-based and outreach site programs) may request a photo identification badge by contacting your program coordinator.

Students admitted to any Health Sciences Institute program that requires immunizations will be required to provide official documentation of required immunizations as part of their conditional acceptance. Students must provide this documentation by the deadline set for their specific program start date.

Specific vaccination requirements can vary by program, with details provided at the program-level web page and/or through the accepted student information sent to each student during the program intake process.