HIPAA Compliance for Dementia APCM Programs Checklist

Confirm signed HIPAA authorizations are on file for all family caregivers participating in APCM calls.

Document Power of Attorney (POA) or legal guardianship for patients with advanced cognitive decline.

Maintain current lists of authorized caregivers to prevent unauthorized disclosure during automated outreach.

Implement protocols for AI systems to verify caregiver identity before sharing medication or behavioral updates.

Ensure the Notice of Privacy Practices specifically addresses remote monitoring and caregiver communication.

Establish clear procedures for when a caregiver's authorization to access memory care data is rescinded.

Ensure all AI call logs and recordings containing dementia care discussions are encrypted at rest and in transit.

Confirm Business Associate Agreements are in place with all AI call center and software providers.

Maintain detailed logs of who accessed behavioral health notes or medication adjustment logs via the APCM platform.

Configure AI to use the minimum necessary PHI when performing routine check-ins on wandering or safety.

Set strict limits on the types of clinical information left on caregiver answering machines or non-secure lines.

Ensure all tablets or devices used for memory care assessments at the bedside are password-protected and encrypted.

Document that the APCM care plan includes specific caregiver burden assessments and safety planning.

Record all interventions for cholinesterase inhibitors or memantine adjustments within the HIPAA-secure portal.

Ensure advance care planning documents are digitized and accessible to authorized providers during crisis calls.

Securely document episodes of agitation or sun-downing as part of the monthly 20-minute APCM requirement.

Log all communications with respite care providers or neurologists to ensure a continuous audit trail.

Use secure, automated systems to track the time spent on dementia-specific care management for billing audits.

Securely store safety assessment data regarding elopement risk and home environment modifications.

Maintain HIPAA-compliant workflows for escalating behavioral crises to the clinical team via secure messaging.

Document respite care referrals and caregiver support group recommendations within the patient's secure file.

Regularly update HIPAA-protected records on the patient's ability to perform Activities of Daily Living (ADLs).

Record findings from home safety assessments, including fall risks and medication storage security.

Ensure MoCA or MMSE scores are stored in encrypted fields within the APCM management software.