3.18 Patient Confidentiality

3.17 Financial Aid Fraud

Students who are deliberately deceptive in their financial aid applications are subject to disciplinary action. If you purposely give false information in the aid application process and receive aid from federal programs, you may be subject to fine, or imprisonment, or both. 

If, after reviewing an application for financial aid, the School has reason to suspect that an aid applicant may have deliberately misrepresented information resulting in fraud or other criminal misconduct in connection with the aid application, disciplinary action may be taken. Referral in such cases for applicants receiving federal aid may be made to the US Department of Education's Office of Inspector General, or, if more appropriate, to a state or local authority. If evidence of fraud or criminal misconduct is documented, the School will review the matter to determine if the student should be sanctioned or dismissed.

3.18 Patient Confidentiality

In cases where a Master’s student is involved in activities involving patients as part of her/his program of study, the student must abide by the HMS Policy on Patient Confidentiality and the Health Insurance Portability and Accountability Act (“HIPAA”) in addition to any patient confidentiality policies at the clinical site.  Some Master’s students may also be employees or affiliates of a clinical institution or organization, and will also be subject to all relevant policies of that institution or organization. When concern that a student has violated the confidentiality of a patient arises, the Medical School will initiate a fair process to determine the validity of the concern. (Master’s students who are also clinicians at the institution at which the violation occurred also will be subject to the rules and processes of that institution, though HMS may impose separate consequences.)  Students, faculty and administrators are expected to act in good faith while carrying out this process. The Medical School will convene a committee, composed of three student representatives and three faculty members, to evaluate the concern. The faculty members appointed to the committee should have no evaluative responsibility for the student, should not be administrators of a program in which the student participates, and should not be the faculty members who initially raised the concern. The members of the committee, as well as any community members who were involved in alerting the Medical School to the potential violation, should maintain the confidentiality of the committee’s proceedings, including the confidentiality of the student. The committee will make its decisions by majority vote.

The committee first will determine if patient confidentiality has been violated, consulting as necessary with representatives from the clinical site. If patient confidentiality has been violated, the committee then will determine the circumstances of the violation, including, for example, whether or not the student believed he or she was acting in good faith. In making this determination, the committee will take into account that the student's understanding of patient confidentiality may be limited by his or her level of training on the topic. If the committee concludes that the student acted in good faith, then the committee will discuss the matter with the student, help the student learn from the experience, and find an appropriate resolution. The focus of this process is on creating an educational, rather than a disciplinary, experience for the student. If the committee concludes that the student acted in bad faith, then the committee ordinarily will discuss the matter with the student and the student’s Program Director or research mentor. In this case, the committee may consider referring the case to the Academic Progress and Review Board for the Master’s Programs (APRB) for further evaluation and/or disciplinary action.