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By: Juan Corona, Vice President
Executive Summary
As healthcare organizations continue to navigate the complexities of employee health compliance, a recurring question among HR, IT, and Employee Health leaders is: "Why can't we use our patient-facing EHR (i.e. Epic, Cerner, Meditech, etc) or ERP system (i.e. WorkDay, Infor, Oracle, etc) to track employee health data?" While these IT systems are critical for patient care and enterprise management, they were never designed to handle the regulatory, security, and compliance requirements specific to employee health. This blog will explore why organizations should consider purpose-built Employee Health EHRs to maintain compliance with regulations such as OSHA, NHSN reporting, and the Americans with Disabilities Act (ADA), and why using patient-facing EHRs or ERP systems can lead to compliance risks, inefficiencies, and unneeded legal risk.
Note: Occupational Health is a separate beast where the EHRs mentioned above make sense because they were designed with a patient-first workflow.
Introduction
Employee health is a crucial aspect of healthcare organizations, yet many still struggle to manage it effectively. There are various regulatory and safety governing bodies that enforce strict compliance within our healthcare world. Just to name a few, CMS, Joint Commission, DNV, and Occupational Safety and Health Administration (OSHA). All of these regulatory bodies have unique requirements yet all revolve around ensuring the health and safety of employees (and patients), requiring proper record-keeping and compliance measures (vaccines, testing, forms, consents, waivers, fit testing, and more).
While patient-facing EHRs and ERP systems play essential roles in healthcare organizations, they are not equipped or designed to manage the unique requirements of employee health data. Furthermore, organizations must recognize the importance of maintaining a separate, dedicated Employee Health EHR that is built specifically for workplace safety, compliance, and regulatory reporting. Below, we explore why using a specialized Employee Health EHR is a highly suggested approach and highlight the risks of using patient-facing EHRs or ERP systems for employee health data.
The Importance of Data Separation
One of the most critical reasons for using a dedicated Employee Health EHR is the need to maintain strict data separation between personnel files and employee health records.
Key Reasons for Data Separation:
Privacy and Confidentiality – Employee health records contain sensitive medical information that must remain confidential. Mixing these records with general HR data or patient health records increases the risk of unauthorized access and potential discrimination.
Legal Compliance – Regulatory bodies, including OSHA and the ADA, require strict separation of personnel and employee health records. Failure to do so can result in non-compliance penalties.
Avoiding Data Breaches – Healthcare organizations are prime targets for cyber threats. Keeping employee health data within patient-facing EHRs increases the risk of a data breach affecting both patient and employee information.
The Risks of Using Patient-Facing EHRs or ERP Systems for Employee Health Data
While patient-facing EHRs and ERP systems are excellent for their intended purposes, they lack the functionality required for employee health compliance. Here’s why they should not be used for managing employee health records:
1. Lack of Purpose Built Functionality To Meet OSHA, NHSN, and Regulatory Requirements
Patient EHRs are designed for patient care clinical workflows, not employee health tracking.
They do not include built-in reporting features for OSHA, NHSN, or regulatory audits.
Employee health compliance requires tracking symptoms and exposures, immunization status, fit testing, and workforce safety metrics - functions not supported by patient EHRs or ERP systems.
2. ADA Compliance and Separation of Records
The ADA requires that employee health records be maintained separately from personnel records to protect employees' privacy and prevent discrimination.
EHR and ERP systems are not designed to store confidential employment medical files securely and separately from general personnel data.
Employee health records must be isolated from payroll, performance reviews, and HR records to ensure compliance with federal regulations and bias does not occur.
3. Regulatory and Financial Risks of Non-Compliance
Using the wrong system for employee health data can lead to unnecessary legal risks, and at times citations from regulatory bodies. Here are couple that we have come across in working with healthcare organizations:
Legal Penalties: OSHA violations can result in significant fines for non-compliance.
Employee Lawsuits: Data breaks occurred and personnel/health files were comingled
Reputation Damage: Data mismanagement can erode employee trust and damage an organization's credibility.
Lawsuits: Employees may sue for mishandling health data, leading to costly litigation.
Reduction in CMS payment Update via NHSN: Some healthcare organizations rely on CMS funding that requires NHSN compliance—non-compliance or erroneous data can result in funding loss.
Why Employee Health EHRs Are the Right Choice
Purpose-built Employee Health EHRs are designed to handle the unique challenges of employee health compliance. Here’s why organizations should leverage them:
1. Purpose-Built Workflows
Employee Health EHRs are designed with OSHA, NHSN, and regulatory reporting in mind.
They track immunizations, fit testing, compliance notifications, exposure tracking, and workplace safety audits.
These systems ensure accurate and automated compliance reporting, eliminating manual errors and inefficiencies.
2. Secure and Compliant Data Management
Employee Health EHRs store health data separately from personnel records to meet OSHA and ADA requirements.
They provide role-based access to ensure only authorized personnel can view confidential medical records.
They include audit trails and security protocols to protect against data breaches.
3. Simplified Compliance and Reporting
Employee Health EHRs offer automated notifications built on your organizations compliance needs
NHSN reporting, ensuring organizations stay compliant with regulatory requirements.
They provide pre-built templates for workplace safety audits, exposure tracking, and regulatory compliance tracking.
Unlike patient-facing EHRs, these systems are tailored to employee health workflows, reducing administrative burden and compliance risk.
Best Practices for Compliance
To ensure compliance and protect employee health data, healthcare organizations should consider adopting the following best practices:
Implement a Dedicated Employee Health EHR – Maintain a separate system designed specifically for managing employee health records.
Train HR and Employee Health Leaders – Educate teams on the importance of data separation and compliance requirements.
Use Role-Based Access Controls – Limit access to employee health data to authorized personnel only.
Ensure Data Encryption and Security Measures – Protect employee health records from cyber threats.
Regularly Audit Compliance Practices – Conduct periodic audits to ensure adherence to OSHA, NHSN, and ADA regulations.
Conclusion
The decision to invest in an Employee Health EHR is not just about price and fancy buttons, it’s about protecting employee privacy, ensuring workplace safety, and maintaining regulatory adherence. Using patient-facing EHRs or ERP systems for employee health data creates unnecessary risks, inefficiencies, and potential legal liabilities.
By implementing a purpose-built Employee Health EHR, organizations can streamline compliance, enhance data security, and foster a healthier, safer work environment.
If you have any questions or would like to explore Employee Health EHR options, feel free to connect with our Vice President - Juan Corona - at - Juan@trackmysolutions.us
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