Treating Employees From My Hospital

[catbox9]

I work at what is essentially a government run prison in a reasonably small town. This facility is by far the largest employer in the city in which I live. For the purposes of this discussion, let's call this my primary employer. I also work part time as a primary care provider at a clinic which one could argue is a rural clinic. My clinic accepts essentially all patients and is a FQHC. I don't work here often so I don't really consider this my major employer or a significant source of my personal income.

Last week my employer informed me that they spoke with "the legal department" and effective immediately I would no longer be able to treat any current employees at my clinic for any condition whatsoever. They didn't give me this in writing but state that they will do so "soon".

I am wondering if this is at all legal. While I understand that there's an ethical gray area treating coworkers, the vast majority of the people who work at my facility are complete strangers to me. It is a 24 hour facility and I have never seen most of them (there are something like 2500) let alone met them. Second of all, I do not routinely ask patients at my clinic where they work. Finally, this seems like a major breach of HIPAA because my employer would have no way of knowing who I see and treat at my clinic because we do not send them a list (obviously).

I can understand how they could argue there is some sort of conflict of interest in me doing this because I can write work notes and such, but I don't think there is really justification for that either. To further prove my point, there is a psych NP where I work who happens to have a side job as the psych comp provider for our facility. If that isn't a conflict of interest, I don't see how what I'm doing is.

Any thoughts?