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Eligibility of physician preceptors:

1. A licensed, preferably board-certified physician who volunteers to be a preceptor for an agreed upon period of time.
2. Study professional communication and interaction between the physician and all members of the health care delivery team and hospital administration
3. Understand and use American colloquialisms (slang, euphemisms, medical jargon, etc.)
4. Observe the delivery of health care in a private practice, hospital or clinical setting
5. Gain exposure to electronic medical records, and learn how to access and enter data.

Responsibilities of physician preceptors:

1. Effectively communicate to the observer his/her role and responsibilities in the program
2. Assure the observer adheres to the requirements of the program
3. Introduce the observer to patients and obtain their verbal consent to allow observation of the clinical interaction
4. Enter in the patient’s medical record that there was an observer present, and that the patient gave permission for the observer to remain in the room
5. Obtain prior approval from appropriate authority for the observation of surgery or other procedures
6. Provide feedback and complete a formal evaluation for your observer

Eligibility of observers:

1. Completion of graduate program from a medical school listed in the International Medical Education Directory (IMED) (www.faimer.org)
2. Good clinical practice certificate
3. Advanced cardiac life support certification
4. Health Insurance Portability and Accountability Act (HIPAA) training certificate
5. Vaccination record.

Responsibilities of observers:

1. Follow the instructions of the physician preceptor and don’t spend time in the clinic, hospital or private practice unless scheduled and approved by the preceptor
2. Do not conduct physical examinations, treatments or diagnoses of any patient
3. Accept no compensation
4. Must abide by all policies, rules, regulations, and bylaws of United Memorial Medical Center
5. Adhere to Health Insurance Portability and Accountability Act (HIPPA) regulations
6. Participate in any prerequisite training (e.g., HIPAA) at the hospital, clinic or private practice
7. Pay for actual costs of administrative or prerequisite items (ECFMG certification, passport, immunizations, etc.)
8. Participate in activities (clinical tutorials, ward rounds and clinic visits), and observe procedures and operations under the supervision of the preceptor
9. Observe the use of electronic medical information systems, health records, laboratory and  radiology reports, etc., if available, and familiarize yourself with patient data entry and access
10. Research the general structure and organization of the U.S. health care system, as well as private sector and government payers
11. Review clinical articles, posters and publications per the discretion of your preceptor
12. Arrange your own transportation, meals and lodging
13. Observers are expected to dress in a professional manner. T-shirts, jeans, cutoffs, open-toe shoes, and other casual articles of clothing are not permitted.

Organizational model

Program director—a physician who volunteers to lead the Observership Program and the Observership Program committee.

Observership Program committee—comprises three to four physicians or medical educators who oversee activities of the program and assure that the objectives of the program are being met. This committee may:

• Establish the Observership Program guidelines and selection criteria
• Promote the program to interested observers and preceptors
• Review observer and preceptor applications
• Review preceptor evaluations and issue a certificate of completion to the observer

The Observership Program committee may also provide:

• Administrative support
  • Send, process and screen applications for observers and preceptors on behalf of the committee
  • Send introductory letters to observers, preceptors, hospitals and department chairs
  • Prepare schedules and contact lists for observers and preceptors
  • Provide information on the community, transportation options, directions to the hospital or private practice, and lodging information to observers.

HIPPA standards

Overview

The HIPAA Privacy Rule generally permits covered physicians to use and disclose protected health information (PHI) for treatment, payment and health care operations,  including training activities. Specifically, the term “health care operations” involves “reviewing the competence or qualifications of health care professionals, evaluating provider and health plan performance, training health care and non-health care professionals, accreditation, certification, licensing, or credentialing activities.”

Notice of Privacy Practices

The HIPAA Privacy Rule states that an individual has a right to adequate notice of how a covered entity may use and disclose PHI about the individual. Physicians who are covered by the rule are required to develop a Notice of Privacy Practices that describes, in plain language, how the physician may use and disclose PHI about an individual. If a particular use and/or disclosure of PHI is not listed in a physician’s Notice of Privacy Practices, the physician cannot use or disclose PHI for that purpose without a patient’s authorization.

Authorization

A covered physician must obtain written authorization that complies with the requirements of the HIPAA Privacy Rule before he/she uses or discloses PHI, if the use or disclosure is not otherwise permitted or required under the rule without authorization, and if it is not described in the Notice of Privacy Practices

Conclusion

The HIPAA Privacy Rule permits the use and disclosure of PHI for training purposes (such as an IMG Observership Program), as long as: (1) the patient is notified of this use and disclosure in the sponsoring physician’s Notice of Privacy Practices, or (2) the patient signs a HIPAA-compliant authorization permitting this type of use and/or disclosure.

Note: Even if education and training is listed as a purpose in the sponsoring physician’s Notice of Privacy Practices, it is still a good idea to explain the presence of the observer when visiting with a patient and to note the patient’s willingness to have the observer present in the medical record. This extra step is suggested to avoid misunderstandings, as most patients do not read the Notice of Privacy Practices.

Download Observer application form, fill and send the submitted file to observershipprogram@ummc.care.