COMMUNICATION MANAGEMENT STRATEGIES
POLICY MEMORANDUM 2003-20
COMMUNICATION PLAN
How are you planning to communicate? What are you going to communicate? With whom are you planning to communicate? When do you plan to communicate? • • • • • • •
Do you need to modify contracts with your business associates and trading partners? Do you need to coordinate/share interpretation of regulations or law? Do you need to communicate with your staff members regarding the availability of the privacy policies and procedures manual? Do you have a fact sheet or newsletter? Do you have a web site? Are you required to provide privacy training? Are you required to provide your customers with a Notice of Privacy Practices?
Open, ongoing communication between HIPAA stakeholders is paramount to the success of implementing HIPAA. A Communication Plan provides a framework for planning for and documenting the exchange of information both within and outside your project team. The tools offered provide generic templates for the development of your HIPAA Communication Plan. CalOHI Policy Memoranda 2002-08, 2002-09 and 2002-11 require HIPAA impacted departments to develop a communication plan in order to ensure that communications are clear, timely and consistent, both internally and externally. Although it is recognized that there are both formal and informal communications, the scope of a plan should be to address the formal communication channels. Communication plans should be living documents and therefore should be reviewed and revised at least quarterly.
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A Communication plan should address the following four categories: 1. Identification of Stakeholders—The identification of all your stakeholders impacted by HIPAA including your internal department counterparts should be maintained and updated as necessary. Appendix A will facilitate your accomplishing: • •
Task 5A of the Privacy Implementation Schedule, which requires the identification of Business Associates. Task 3A of the Transaction and Code Set Implementation Schedule, which requires the identification of Trading Partners.
2. Internal Communication—A process for internal communications with impacted programs and functions and executive sponsors should be established as well as a standing weekly or monthly meeting for all team members scheduled. A formal procedure for review of documents or other work products should be agreed upon. 3. External Communication—Methods for external communications should be determined and an internal review process to ensure message consistency should be well documented. 4. Other Communications—A procedure for outside communications with the news and print media, as well as the public, should be documented. What process will be used to ensure that your project speaks with one voice? CalOHI Policy Memorandum 2002-09 further defines department’s and CalOHI’s role in different forums. CalOHI should be included in all communication with the federal government and control agencies. Tracking of both internal and external communications is key to a successful plan. The attached templates provide tools for planning and tracking both internal and external communications. Appendix A – Identify your stakeholders, as well as what, when, where and how you will communicate with them. Appendix B - Your department’s organization chart documents internal programs and functions that must be communicated with. Appendix C - The Stakeholder Communication Matrix provides an overview of the department’s stakeholders and a method for tracking what information is communicated and the method of communication. 10/14/08 20:24 A10/P10
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Appendix A
Identification Of Stakeholders Stakeholder Name & Organization Example Jane Doe Yolo County
Example
Example
Program Contact Person Example
(916)555-1212
Jdoe@yolo. co
Ken McKin DMH/IT
Phone
Email
Phone Example (916) 5551313
Frequency of Contact Example Weekly
Internal Communication Who
Frequency
Example Project Manager/Sr. Manager
Example Weekly/ Tuesdays
All Staff Meeting
Monthly (Date)
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Responsible party Example Director
Director
Purpose Example Communicate project specific information, completed milestones, new effort starting, or other important issues, etc.
Method of communication Example Oral presentation questions and answer.
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External Communication Who
Frequency
Example
Example
Responsible Party Example
Department of Finance (DOF) Briefings
As needed (Date)
Senior Manager
Purpose Example
Method of communication Example
Discuss project progress and issues.
Oral presentations, discussion.
Other Communications Who
Frequency (Date)
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Responsible party
Purpose
Method of communication
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Appendix B - Organization Chart Intentionally Blank
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Appendix C – Matrix of Stakeholders Name stakeholders across the top and the event on the left column. Stakeholders:
Weekly: Example: Exec Staff Briefing
Bi-Weekly:
Monthly:
Bi-Monthly:
Quarterly:
Semi-Annual:
Annual:
As Needed:
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