HIPAA and Location App For Home Visits?

[Karahrn]

I have a question regarding HIPAA and would like some feedback please.  I have not worked in this situation for a several years. 

References of where you found the answer would be fantastic, but not necessary. 

Can a healthcare provider (of any kind...nurse, therapist, PT, OT, ST, etc) use a location app, or another way to provide family a way of knowing where they are for, say a home health visit?   I know it's a HIPAA violation to share a patient name, address, medical information, etc.  A family location app, ex Life360 or a Find My Device app or something else.  Some locations are in sketchy areas or, even if not, the world is crazy these days.  I think it would be a smart idea to have an idea where the healthcare worker is in case they don't show up when expected from a visit   

I know newer vehicles can come equipped with OnStar which I'm assuming would provide that information.  

Ideas are appreciated. 

TIA

[NRSKarenRN, BSN, RN]

HIPAA is release of PATIENT information. Location tracking app is for YOUR = staff location information. Our home health aides have tracking software built into agency software to confirm they are at patients home during visit to avoid fraudulent visit documentation/payment and staff safety check in urban area.  

[JKL33]

beachynurse said:

I don't know what to tell you then.... 

The poster was asking whether it would be considered a HIPAA violation if her location shows that she is at 123 ABC street (when 123 ABC street = address of a patient) and her location is shared automatically with her own loved ones via an app that has the ability to share one's location.

There was nothing about the question that had anything to do with sharing her daily whereabouts with patients.

[JKL33]

NRSKarenRN said:

HIPAA is release of PATIENT information. Location tracking app is for YOUR = staff location information.

See above.

NRSKarenRN said:

Our home health aides have tracking software built into agency software to confirm they are at patients home during visit to avoid fraudulent visit documentation/payment and staff safety check in urban area.  

Now that makes sense. As long as all the devices involved are company owned and provided to the employee by the company, that is.

[Karahrn]

beachynurse said:

I would not want to give my patients that much power over me. What if you tell them they will be third and an emergency comes up and they get bumped to 5th? They will be able to see that you made 2 stops prior to theirs. You are setting yourself up for complaints...

I do not understand what this has to do with my original question of using a location app. I would not be sharing my location with the patient. It would be with my family so know where to send the police of I don't come home. Thank you for you time though. 

[kbrn2002, ADN, RN]

beachynurse said:

I would not want to give my patients that much power over me. What if you tell them they will be third and an emergency comes up and they get bumped to 5th? They will be able to see that you made 2 stops prior to theirs. You are setting yourself up for complaints...

Karahrn said:

I do not understand what this has to do with my original question of using a location app.  

To beachynurse's defense I also read the question as you [OP] wanting to potentially use a location app to allow the family of the patient to track your whereabouts instead of your own family.  My first thought was why on earth would you want to let your patient's know where you are at all times?

Then I read the comments and realized my mistake, LOL

[Karahrn]

I am so sorry I did not make my question clear enough.  I totally meant for a member of my family to be aware if I don't return home at a reasonable time. 

There are some times we are needed in an area which is very sketchy and I would feel better knowing someone at home (a family member) was aware of my location. My original question mentioned several different disciplines as examples, I.e.  RN/LPN, CNT, PT, RT, ST, counselor/therapist, clergy, case manager. Basically anyone who has been called in to help or work with a patient and/or a family.  I tried to make that clearer by being more inclusive of other disciplines above.

I personally worked as an RN Case Manager years ago.  Currently, my adult son is employed as a counselor working with families. Many times he has to work later in the evenings and occasionally on a weekend in order for all family members to be present. His supervisor whom is aware of his appointments does not work those hours. Therefore, it would be especially comforting to know someone in his family is aware of his location. My son is especially leary of making his location available to a family member due to HIPAA.  He enjoys his job, has worked very hard to get his master's degree, and spent a lot of money in doing so.  He doesn't want to take any chances.   However, when he messages me and asks me to send him that link to the the location app (Life360), I know he is pretty uncomfortable because there was "no way I'm going to use a location app" when I mentioned previously. ?. He's VERY independent and feels confident most of the time.  He never did use the app that time because he was THAT concerned about HIPAA regulations.  I personally feel he needs to do what he needs to in order to feel some level of comfort.

During normal business hours his supervisor is working with many other employees, as well as his/her other responsibilities. 

When I worked as an RN Case Manager this was the exact same situation I was in.  I am considering returning to this type of work again as enjoyed it with the exception of certain locations which made me quite nervous. 

Perhaps someone is aware of a different app which would be possibly "more secure".  Or other ideas.  Another person answered something about using  "find my device".

I hope my question provides useful information for others working "out in the field" because I was unable to find this answered anywhere.  

[kbrn2002, ADN, RN]

Well some hospitals were putting tracking devices on nurses, which I think is abhorrent by the way.  I haven't heard complaints about that for awhile so I'm not sure if that's still a thing. But the argument could be made that the precedent has been set from a patient privacy point of view  

But then I also feel having somebody, even a trusted family member having the ability to know where I am at all times is a hard pass. There was a time that my old phone company Sprint actually offered family location tracking as an add-on service. It was mostly advertised as a good way to keep track of where your untrustworthy teens were, LOL. 

[Karahrn]

That is a terrible thing for hospitals to do their employees.  I don't believe I'd want to work somewhere like that just for the point of it.  I had Sprint for 20 years myself and knew about that feature. My kids were no longer at home at that time and never had phones when they were young so? I know the app my 36 year old daughter uses and added me to is Life360.  My son downloaded it and between visits tried to research the HIPAA compliance thing. He put it on pause which is how it still shows up on my app. So apparently it can be turned on and off fairly easily.   I personally use it because I rode my horses out where no one can see me by myself. I want someone to know where I am if something happened to me and I was unable to call 911.   It would be challenging to explain where I was on a trail also.  I can't say the app is that accurate but it's better than nothing if I were injured, etc. 

[JKL33]

Karahrn said:

it would be especially comforting to know someone in his family is aware of his location. My son is especially leary of making his location available to a family member due to HIPAA. 

Tell him that his location is not PHI. Period.

What does he say about the examples we discussed previously -- especially something like the fact that Oxygen Company or Visiting Nurses could park in someone's drive way with the words Oxygen Company or Visiting Nurses on their van and this would not be a HIPAA violation even though it effectively lets neighbors and passers-by know that someone there at that address needs oxygen/nursing care?