Legislation Details

File #: 9353   
Type: Consent Status: Passed
File created: 12/27/2023 Department: Multijurisdictional Items
On agenda: 1/9/2024 Final action: 1/9/2024
Subject: Updates to County Policy Manual
Attachments: 1. POL-CAO-01-09-24- 07-16 Standards of Dress and Grooming - AMEND, 2. POL-CAO-01-09-24 - 10-01 Signature Legibility - NEW, 3. POL-CAO-01-09-24 - 10-07 Records Management Program - NEW, 4. POL-CAO-01-09-24 - 10-08 Archives Management - NEW, 5. POL-CAO-01-09-24- 14-03 HIPAA Compliance Program - AMEND, 6. Item #60 Executed BAI

REPORT/RECOMMENDATION TO THE BOARD OF SUPERVISORS

OF SAN BERNARDINO COUNTY

BOARD GOVERNED COUNTY SERVICE AREAS

SAN BERNARDINO COUNTY FLOOD CONTROL DISTRICT

AND RECORD OF ACTION

 

REPORT/RECOMMENDATION TO THE BOARD OF DIRECTORS

OF THE BIG BEAR VALLEY RECREATION AND PARK DISTRICT

BLOOMINGTON RECREATION AND PARK DISTRICT

IN-HOME SUPPORTIVE SERVICES PUBLIC AUTHORITY

INLAND COUNTIES EMERGENCY MEDICAL AGENCY

SAN BERNARDINO COUNTY FIRE PROTECTION DISTRICT

AND RECORD OF ACTION

 

                                          January 9, 2024

 

FROM

LUTHER SNOKE, Chief Executive Officer, County Administrative Office 

         

SUBJECT                      

Title                     

Updates to County Policy Manual

End

 

RECOMMENDATION(S)

Recommendation

1.                     Acting as the Board of Supervisors for San Bernardino County, Board Governed County Service Areas, and the San Bernardino County Flood Control District, and as the Board of Directors for the Big Bear Valley Recreation and Park District, the Bloomington Recreation and Park District, In-Home Supportive Services Public Authority, Inland Counties Emergency Medical Agency, and the San Bernardino County Fire Protection District, approve the following updates to the County Policy Manual:

a.                     Amend Policy 07-16: Standards of Dress and Grooming

b.                     Approve and add new Policy 10-01: Signature Legibility

c.                     Approve and add new Policy 10-07: Records Management Program

d.                     Approve and add new Policy 10-08: Archives Management

2.                     Acting as the Board of Supervisors for San Bernardino County, approve amended County Policy Manual, Policy 14-03: Health Insurance Portability and Accountability Act Compliance Program.

3.                     Acting as the Board of Directors for the San Bernardino County Fire Protection District:

a.                     Designate the San Bernardino County Fire Protection District as a Hybrid Entity under the Health Insurance Portability and Accountability Act.

b.                     Adopt amended County Policy Manual, Policy 14-03: Health Insurance Portability and Accountability Act Compliance Program, and all amended Standard Practices associated with Policy 14-03.

 

(Presenter: Luther Snoke, Chief Executive Officer, 387-4811)

Body

 

COUNTY AND CHIEF EXECUTIVE OFFICER GOALS & OBJECTIVES

Promote the Countywide Vision.

Improve County Government Operations.

Operate in a Fiscally-Responsible and Business-Like Manner.

 

FINANCIAL IMPACT

Approval of this item will not result in the use of additional Discretionary General Funding (Net County Cost) as this item is non-financial in nature. 

 

BACKGROUND INFORMATION

The County Policy Manual documents policy direction from the Board of Supervisors and Board of Directors (collectively Board) to departments and Board governed entities on a broad array of topics. Board-approved policies are often implemented through the use of Standard Practices, which are approved by the Chief Executive Officer (CEO) and incorporated into the County Policy Manual.

 

In order to facilitate the review of County policies, the County has established a Policy Review Committee (Committee) to evaluate requests for new policies and conduct ongoing review and update of existing policies. The Committee includes representation from various departments as follows:

 

POLICY REVIEW COMMITTEE

Auditor-Controller/Treasurer/Tax Collector

Clerk of the Board of Supervisors

County Administrative Office

County Counsel

District Attorney/Law & Justice

Finance and Administration

Human Resources

Human Services

Innovation and Technology

Public Works

Purchasing

Real Estate Services

San Bernardino County Fire Protection District

 

 

The Committee, which met on December 11, 2023, has approved and recommends amendments to Section 7, Personnel Matters; Section 10, Records Management, Risk Management; and Section 14, Release of Information, Privacy and Compliance, of the County Policy Manual as follows:

 

Policy

Title

Action

Description of Action

07-16

Standards of Dress and Grooming

Amend

Update to this policy is appropriate to create more flexibility and align with legislative changes.

10-01

Signature Legibility

Add

The addition of this policy is appropriate to implement best practices to comply with applicable laws and generally accepted records management standards regarding required signatures.

10-07

Records Management Program

Add

The addition of this policy is appropriate to develop and administer a Records Management Program in compliance with federal and state law, and pursuant to operational requirements of the County.

10-08

Archives Management

Add

The addition of this policy is appropriate to manage County records and comply with applicable laws and generally accepted archival standards.

14-03

Health Insurance Portability and Accountability Act (HIPAA) Compliance Program

Amend

Update to the policy is appropriate for revision of applicable definitions and clarifying language regarding privacy and information security standards.

 

The proposed amended Policy 14-03 is only applicable to: 1) San Bernardino County because it is specific to HIPAA compliance requirements by identified County departments that use or disclose protected health information; and 2) the San Bernardino County Fire Protection District (SBCFPD) because it is required to comply with HIPAA.

 

The Committee also recommends the CEO approve the addition and/or update of the following Standard Practices to implement and/or update processes for departments:

 

Number

Title

14-03 SP1

Health Care Component Designation

14-03 SP2

Privacy Officer and Security Officer

14-03 SP3

Administrative, Technical and Physical Safeguards

14-03 SP4

Workforce Training

14-03 SP5

Risk Analysis and Management

14-03 SP6

Uses and Disclosures of PHI

14-03 SP7

Patient Privacy Rights

14-03 SP8

Business Associate Agreements

14-03 SP9

Breach Reporting and Notification

14-03 SP10

HIPAA Complaint Process

 

This item also recommends that the SBCFPD Board of Directors designate SBCFPD as a Hybrid Entity. This designation means that SBCFPD is a single legal entity that performs both covered and non-covered functions under HIPAA. As a result, only those divisions or programs that perform covered functions (identified as Health Care Components) are required to comply with HIPAA. Under Policy 14-03, Health Care Components consist of SBCFPD divisions or programs that meet the definition of a Covered Entity or Internal Business Associate. For example, Division 12 - Office of Fire Marshal performs non-covered functions and therefore is not a Health Care Component.

 

PROCUREMENT

Not applicable.

 

REVIEW BY OTHERS

This item has been reviewed by County Counsel (Julie Surber and Scott Runyan, Principals Assistant County Counsel, , and Charles Phan, Deputy County Counsel, 387-5455) on December 20, 2023; Finance (Erika Rodarte, Administrative Analyst, 387-4919) on December 19, 2023; and County Finance and Administration (Matthew Erickson, County Chief Financial Officer, 387-5423) on December 19, 2023.