The Privacy and Security of Non-Traditional Occupational Health Services

The AHIMA Practice Brief The Privacy and Security of Occupational Health Records focuses on the privacy and security related responsibilities of a healthcare provider that offers occupational health services for other employers in its community. While many healthcare providers have diversified their offerings and now offer occupational health services (OHS), this article supplements that practice brief and focuses on those entities that are not healthcare providers, in the traditional sense of the term.

The following is an excerpt from an article by Rose Dunn, MBA, RHIA, CPA FACHE, FAHIMA, and Godwin Odia, PhD, RHIA, NHA, that follows up on this Practice Brief, taking a closer look at the privacy and security responsibilities of non-traditional occupational health services. To read the full article, visit AHIMA’s HIM Body of Knowledge here.



Non-healthcare provider-owned or operated occupational health services are independent. They may be free-standing, employer owned, or part of a regional or national services network. They focus solely on occupational health assessment and treatment services. In essence, they compete directly with hospitals and physician provider groups that have established occupational health services.

Similar to hospital and physician group-based OHS, these organizations may be contracted by employers to provide assessments and treatment for the employees of their businesses. The occupational health service may employ medical personnel and may, if indicated, refer employees to other healthcare providers for serious conditions or conditions that cannot be effectively treated by the occupational health service.


Defining the Occupational Health Record

The definition of the Occupational Health Record (OHR) remains the same regardless of the ownership or structure of the OHS. The Occupational Safety and Health Administration (OSHA) defines an “occupational medical record” as an occupation-related, chronological, cumulative record, regardless of the form or process by which it is maintained (i.e., paper document, microfiche, microfilm, or automatic data processing media). The occupational medical record includes information about health status documented on an employee, including personal and occupational health histories as well as the opinions and written evaluations generated in the course of diagnosis, employment-related treatment, and examination by healthcare professionals and technicians. The definition includes employee exposure records, occupational illness, and accident or injury records.2 OHR will be used throughout this article to encompass both an occupational health record and occupational medical record.


Governing Regulations for Occupational Health Services

The Occupational Safety and Health Administration (OSHA) serves as the primary governing authority of occupational health services, including those that are not owned by a hospital or physician group. Charged with assuring safe and healthy working conditions for employees, OSHA has established standards for not only safe and healthy working conditions but also the monitoring of compliance with those standards. Encompassed within these standards are the responsibilities of those OHS that assess and/or treat workers.


OSHA standards cover most employees in all 50 states, US territories, and Washington, DC directly through federal OSHA plans or indirectly through OSHA approved state plans.

There are currently 22 States and jurisdictions operating complete state plans, covering both private and public sector employees:

  • Alaska
  • Arizona
  • California
  • Hawaii
  • Indiana
  • Iowa
  • Kentucky
  • Maryland
  • Michigan
  • Minnesota
  • Nevada
  • New Mexico
  • North Carolina
  • Oregon
  • Puerto Rico
  • South Carolina
  • Tennessee
  • Utah
  • Vermont
  • Virginia
  • Washington
  • Wyoming


Rose Dunn ( is chief operating officer at First Class Solutions. Godwin Odia ( is senior health insurance specialist with the Centers for Medicare and Medicaid Services.

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