The ethical obligations of the health information management (HI) professional include the safeguarding of privacy and security of health information; appropriate disclosure of health information; development, use, and maintenance of health information systems and health information; and ensuring the accessibility and integrity of health information.
Healthcare consumers are increasingly concerned about security and the potential loss of privacy and the inability to control how their personal health information is used and disclosed. Core health information issues include what information should be collected, how the information should be managed, who should have access to the information, under what conditions the information should be disclosed, how the information is retained, when it is no longer needed, and how is it disposed of in a confidential manner. All of the core health information issues are addressed in compliance with state and federal regulations, and employer policies and procedures.
Ethical obligations are central to the professional's responsibility, regardless of the employment site or the method of collection, storage, and security of health information. In addition, sensitive information (e.g., genetic, adoption, substance use, sexual health, and behavioral information) requires special attention to prevent misuse. In the world of business and interactions with consumers, expertise in the protection of information is required.
The HIM professional has an obligation to demonstrate actions that reflect values. The American Health Information Management Association (AHIMA) Code of Ethics sets forth these principles. (See also AHIMA Mission, Vision, Values) The code is relevant to all AHIMA members, non-members with the Commission on Certification for Health Informatics and Information Management (CCHIIM) certifications, and students enrolled in a formal certificate or degree granting program directly relevant to the AHIMA Purpose regardless of their professional functions, the settings in which they work, or the populations they serve. These purposes strengthen the HIM professional’s efforts to improve overall quality of healthcare.
The AHIMA Code of Ethics serves six purposes:
The code includes principles that are enforceable and aspirational. The extent to which each principle is enforceable is a matter of professional judgment to be exercised by those responsible for reviewing alleged violations of ethical principles.
The following principles are based on the core values of the American Health Information Management Association and apply to all AHIMA members, non-members CCHIIM certifications, and students.
Violation of principles in the Code of Ethics does not automatically imply legal liability or violation of the law. Such determination can only be made in the context of legal and judicial proceedings. Alleged violations of the code are subject to a peer review process. Such processes are generally separate from legal or administrative procedures and insulated from legal review or proceedings to allow the profession to counsel and discipline its own members. Although in some situations, violations of the code would constitute unlawful conduct subject to legal process.
Guidelines for ethical and unethical behavior are provided to assist with the interpretation of the American Health Information Management Association (AHIMA) Code of Ethics. The terms "shall” and “shall not" are used as a basis for setting high standards for behavior. This does not imply that everyone "shall” or “shall not" do everything that is listed. This concept is true for the entire code. If someone engages in the stated activities, ethical behavior is the standard. The guidelines are not a comprehensive list. For example, the statement "safeguard all confidential consumer information to include, but not limited to, personal, health, financial, genetic and outcome information" can also be interpreted as "shall not fail to safeguard all confidential consumer information to include personal, health, financial, genetic, and outcome information."
A code of ethics cannot guarantee ethical behavior. Moreover, a code of ethics cannot resolve all ethical issues or disputes or capture the richness and complexity involved in striving to make responsible choices within a moral community. Rather, a code of ethics sets forth values and ethical principles to which a Health Information Management (HIM) professional can aspire and by which actions can be judged. Ethical behaviors result from a personal commitment to engage in ethical practice.
Professional responsibilities often require an individual to move beyond personal values. For example, an individual might demonstrate behaviors that are based on the values of honesty, providing service to others, or demonstrating loyalty. In addition, professional values may require promoting confidentiality, facilitating interdisciplinary collaboration, and refusing to participate or conceal unethical practices. Professional values could require a more comprehensive set of values than an individual’s need to be an ethical agent in one’s own personal life.
The AHIMA Code of Ethics is to be used by AHIMA members, non-members with the Commission on Certification for Health Informatics and Information Management (CCHIIM) certifications, students enrolled in a formal certificate or degree granting program directly relevant to the AHIMA Purposes, and consumers, agencies, organizations, and bodies (such as licensing and regulatory boards, insurance providers, courts of law, government agencies, and other professional groups) that choose to adopt it or use it as a frame of reference. The AHIMA Code of Ethics reflects the commitment of all to uphold the profession's values and to act ethically. Individuals of good character who discern moral questions and, in good faith, seek to make reliable ethical judgments, must apply ethical principles.
The code does not provide a set of rules that prescribe how to act in all situations. Specific applications of the code must consider the context in which it is being considered and the possibility of conflicts among the values and principles.
The following ethical principles are based on the core values of the American Health Information Management Association and apply to all AHIMA members, non-members with CCHIIM certifications, and students enrolled in a formal certificate or degree granting program directly relevant to the AHIMA Purposes. Guidelines included for each ethical principle are a non-inclusive list of behaviors and situations that can help to clarify the principle. They are not meant to be a comprehensive list of all situations that can occur.
A health information management professional shall:
1.1. Safeguard all confidential consumer information to include, but not limited to, personal, health, financial, genetic, and outcome information.
1.2. Engage in social and political action that supports the protection of privacy and confidentiality and be aware of the impact of the political arena on the health information issues for the healthcare industry and the public.
1.3. Advocate for changes in policy and legislation to ensure protection of privacy and confidentiality, compliance, and other issues that surface as advocacy issues and facilitate informed participation by the public on these issues.
1.4. Protect the confidentiality of all information obtained in the course of professional service. Disclose only information that is directly relevant or necessary to achieve the purpose of disclosure. Release information only with valid authorization from a consumer or a person legally authorized to consent on behalf of a consumer or as authorized by federal or state regulations. The minimum necessary standard is essential when releasing health information for disclosure activities.
1.5. Promote the obligation to respect privacy by respecting confidential information shared among colleagues, while responding to requests from the legal profession, the media, or other non-healthcare related individuals, during presentations or teaching and in situations that could cause harm to persons.
1.6. Respond promptly and appropriately to consumer requests to exercise their privacy rights (e.g., access, amendments, restriction, confidential communication, etc.). Answer truthfully all consumers’ questions concerning their rights to review and annotate their personal biomedical data and seek to facilitate consumers’ legitimate right to exercise those rights.
2. Put service and the health and welfare of persons before self-interest and conduct oneself in the practice of the profession so as to bring honor to oneself, peers, and to the health information management profession.
A health information management professional shall:
2.1. Act with integrity, behave in a trustworthy manner, elevate service to others above self-interest, and promote high standards of practice in every setting.
2.2. Be aware of the profession's mission, values, and ethical principles, and practice in a manner consistent with them by acting honestly and responsibly.
2.3. Anticipate, clarify, and avoid any conflict of interest, to all parties concerned, when dealing with consumers, consulting with competitors, in providing services requiring potentially conflicting roles (for example, finding out information about one facility that would help a competitor), or serving the Association in a volunteer capacity. The conflicting roles or responsibilities must be clarified and appropriate action taken to minimize any conflict of interest.
2.4. Ensure that the working environment is consistent and encourages compliance with the AHIMA Code of Ethics, taking reasonable steps to eliminate any conditions in the organizations that violate, interfere with, or discourage compliance with the code.
2.5. Take responsibility and credit, including authorship credit, only for work one actually performs, or to which one contributed. Honestly acknowledge the work of and the contributions made by others verbally or written, such as in publication.
A health information management professional shall not:
2.6. Permit one’s private conduct to interfere with the ability to fulfill one’s professional responsibilities.
2.7. Take unfair advantage of any professional relationship or exploit others to further one’s own personal, religious, political, or business interests.
A health information management professional shall:
3.1. Safeguard the privacy and security of written and electronic health information and other sensitive information. Take reasonable steps to ensure that health information is stored securely and that consumers’ data and information is not available to others who are not authorized to have access. Prevent inappropriate disclosure of individually identifiable information.
3.2. Take precautions to ensure and maintain the confidentiality of information transmitted, transferred, or disposed of in the event of termination, incapacitation, or death of a healthcare provider to other parties through the use of any media.
3.3. Inform recipients of the limitations and risks associated with providing services via electronic or social media (e.g., computer, telephone, fax, radio, and television).
A health information management professional shall:
4.1. Act in a professional and ethical manner at all times.
4.2. Take adequate measures to discourage, prevent, expose, and correct the unethical conduct of colleagues. If needed, utilize the AHIMA Policy and Procedures for Disciplinary Review and Appeal for potential ethics complaints.
4.3. Be knowledgeable about established policies and procedures for handling concerns about colleagues' unethical behavior. These include policies and procedures created by AHIMA, licensing and regulatory bodies, employers, supervisors, agencies, and other professional organizations.
4.4. Seek resolution if there is a belief that a colleague has acted unethically or if there is a belief of incompetence or impairment by discussing one’s concerns with the colleague when feasible and when such discussion is likely to be productive.
4.5. Consult with a colleague when feasible and assist the colleague in taking remedial action when there is direct knowledge of a health information management colleague's incompetence or impairment.
4.6. Take action through appropriate formal channels, such as contacting an accreditation or regulatory body and/or the AHIMA Professional Ethics Committee if needed.
4.7. Cooperate with lawful authorities as appropriate.
A health information management professional shall not:
4.8. Participate in, condone, or be associated with dishonesty, fraud and abuse, or deception. A non-inclusive list of examples includes:
Refer to the AHIMA Standards of Ethical Coding for additional guidance.
4.9. Engage in any relationships with a consumer where there is a risk of exploitation or potential harm to the consumer.
A health information management professional shall:
5.1. Use healthcare employer technology resources within the confines of organizational policies.
5.2. Ensure all data and resulting information accessed and derived from healthcare technology resources are not used outside of the scope of the job.
A health information management professional shall not:
5.3. Compromise the integrity of healthcare data through any intentional acts or acts that are generally known to create risks to data integrity.
A health information management professional shall:
6.1. Verify requests for data and information are based on appropriate, verifiable needs and conditions and fall within the confines of organizational policies, regulations, and laws.
6.2. Educate stakeholders about the need to maintain data integrity and the potential impacts should data integrity not be maintained.
A health information management professional shall not:
6.3. Manipulate information systems to produce or display data and resulting information that is intentionally misleading
A health information management professional shall:
7.1. Provide directed practice opportunities for students.
7.2. Be a mentor for students, peers, and new health information management professionals to develop and strengthen skills.
7.3. Be responsible for setting clear, appropriate, and culturally sensitive boundaries for students, staff, peers, colleagues, and members within professional organizations.
7.4. Evaluate students' performance in a manner that is fair and respectful when functioning as educators or clinical internship supervisors.
7.5. Evaluate staff's performance in a manner that is fair and respectful when functioning in a supervisory capacity.
7.6. Serve an active role in developing HIM faculty or actively recruiting HIM professionals.
A health information management professional shall not:
7.7. Engage in any relationships with a person (e.g. students, staff, peers, or colleagues) where there is a risk of exploitation or potential harm to that other person.
A health information management professional shall:
8.1. Be an advocate for the profession in all settings and participate in activities that promote and explain the mission, values, and principles of the profession to the public.
A health information management professional shall:
9.1. Develop and enhance continually professional expertise, knowledge, and skills (including appropriate education, research, training, consultation, and supervision). Contribute to the knowledge base of health information management and share one’s knowledge related to practice, research, and ethics.
9.2. Base practice decisions on recognized knowledge, including empirically based knowledge relevant to health information management and health information management ethics.
9.3. Contribute time and professional expertise to activities that promote respect for the value, integrity, and competence of the health information management profession. These activities may include teaching, research, consultation, service, legislative testimony, advocacy, presentations in the community, and participation in professional organizations.
9.4. Engage in evaluation and research that ensures the confidentiality of participants and of the data obtained from them by following guidelines developed for the participants in consultation with appropriate institutional review boards.
9.5. Report evaluation and research findings accurately and take steps to correct any errors later found in published data using standard publication methods.
9.6. Design or conduct evaluation or research that is in conformance with applicable federal or state laws.
9.7. Take reasonable steps to provide or arrange for continuing education and staff development, addressing current knowledge and emerging developments related to health information management practice and ethics.
A health information management professional shall:
10.1. Perform responsibly all duties as assigned by the professional association operating within the bylaws and policies and procedures of the association and any pertinent laws.
10.2. Uphold the decisions made by the association.
10.3. Speak on behalf of the health information management profession and association, only while serving in the role, accurately representing the official and authorized positions of the association.
10.4. Disclose any real or perceived conflicts of interest.
10.5. Relinquish association information upon ending appointed or elected responsibilities.
10.6. Resign from an association position if unable to perform the assigned responsibilities with competence.
10.7. Avoid lending the prestige of the association to advance or appear to advance the private interests of others by endorsing any product or service in return for remuneration. Avoid endorsing products or services of a third party, for-profit entity that competes with AHIMA products and services. Care should also be exercised in endorsing any other products and services.
A health information management professional shall:
11.1. Make clear distinctions between statements made and actions engaged in as a private individual and as a representative of the health information management profession, a professional health information association, or one’s employer.
11.2. Claim and ensure that representation to consumers, agencies, and the public of professional qualifications, credentials, education, competence, affiliations, services provided, training, certification, consultation received, supervised experience, and other relevant professional experience are accurate.
11.3. Claim only those relevant professional credentials actually possessed and correct any inaccuracies occurring regarding credentials.
11.4. Report only those continuing education units actually earned for the recertification cycle and correct any inaccuracies occurring regarding CEUs.
A health information management professional shall:
12.1. Participate in and contribute to decisions that affect the well-being of consumers by drawing on the perspectives, values, and experiences of those involved in decisions related to consumers.
12.2. Establish clearly professional and ethical obligations of the interdisciplinary team as a whole and of its individual members.
12.3. Foster trust among group members and adjust behavior in order to establish relationships with teams.
A health information management professional shall:
13.1. Treat each person in a respectful fashion, being mindful of individual differences and cultural and ethnic diversity.
13.2. Promote the value of self-determination for each individual.
13.3. Value all kinds and classes of people equitably, deal effectively with all races, cultures, disabilities, ages and genders.
13.4. Ensure all voices are listened to and respected.
Acknowledgement
Adapted with permission from the 1999 Code of Ethics of the National Association of Social Workers.
Resources
National Association of Social Workers. Code of Ethics. 2017. Available online on the NASW web site.
AHIMA. Code of Ethics, 1957, 1977, 1988, 1998, and 2004, 2011.
AHIMA. Standards of Ethical Coding. 2016. Available in the AHIMA Body of Knowledge.
Harman L., Cornelius F. Ethical Health Informatics: Challenges and Opportunities (formerly titled Ethical Challenges in the Management of Health Information). 3rd ed. Burlington, Massachusetts: Jones & Bartlett Learning; 2017.
McWay, D.C. Legal and Ethical Aspects of Health Information Management, 4th ed. Clifton Park, NY: Cengage Learning; 2014.