If college WF staff becomes aware of a client's sensitive/confidential information how do we communicate it to the DSHS case manager?

Question con't: Is it appropriate for college WF staff to enter the information into eJAS notes by selecting one of the “Special Records” note types?


Answer:
This issue has come up on various occasions and has primarily been addressed locally. There is not specific policy related to how the college (or other contractors) should communicate confidential/sensitive information. There also is no policy about what is the extent of college WF staff's obligation to do so.

We would suggest caution when developing your local process, because the DSHS policy manual advises: "The department is responsible for ensuring that confidential information is not released to clients or third parties inappropriately or illegally. Confidential information can be disclosed only under the specific criteria in chapter 388-01 WAC".

In the past, it had been our understanding that confidential/sensitive information can be flagged and moved into the confidential “??” section. Once it is placed in the “??” section, it is no longer visible to contractors outside DSHS. We do not recommend this approach based on Chapter 388-01 WAC.

If college staff should become aware of confidential/sensitive information, we suggest notifying the case manager and encouraging the case manager to investigate further. If we attempt to facilitate that role, we may inadvertently be violating law or policy with respect to client rights.

Clarifying information can be reviewed in the DSHS A-Z manual located at:
http://www.dshs.wa.gov/manuals/eaz/sections/ConfidentialityA.shtml