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The University Privacy Office will develop and provide ongoing training and education for members of the designated health care components' workforce, researchers at the University and University students regarding policies, procedures and legal requirements related to privacy of PHI. The Privacy Office will assure that training materials are changed to reflect changes in University policies and procedures and material regulatory changes as necessary.

Privacy Coordinators and their Units' human resources contacts will work with the Privacy Office to identify and compile a list of new workforce members (including transferred employees), researchers and students who require HIPAA training. The Privacy Coordinators and their Units' human resources contacts will identify the training courses that a particular employee will be required to complete.

New workforce members may be required to complete training prior to their employment start date, but shall complete all required HIPAA training no later than 90 days from the date employment begins. The Privacy Officer in collaboration with Privacy Coordinators will identify workforce members, researchers, and students who are affected by material regulatory changes and require additional HIPAA training, and will establish a reasonable timeframe for completing the additional training.

In some instances, Privacy Coordinators are responsible for ensuring that workforce members, researchers and students who are required to complete HIPAA training have completed the training assigned to them. Privacy Coordinators are responsible for documenting training compliance information in a manner and frequency established by the Privacy Officer.