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The policies discussed in this section apply to all SCU clinical students participating in all clinical settings. Programs and/or sites may have stricter and/or additional requirements, as detailed in Section III and Section IV of the SCU Clinical Handbook.
- Melissa Nagare, DC, L.AC, CCSP® - Chief Clinical Officer and Vice President for SCU Health
https://www.scuhs.edu/team/melissa-nagare/
MelissaNagare@scuhs.edu
- Joseph Eggleston, MPH, CEFP, CASP - Assistant Vice President of Auxiliary Operations, Privacy Officer, and Insurance Liaison
JosephEggleston@scuhs.edu
Prior to participating in clinical education, clinical students must complete HIPAA (Health Insurance Portability and Accountability Act) and FERPA (Family Educational Rights and Privacy Act) training annually through mySCU, the University’s intranet. Clinical students are not allowed to participate in any form of clinical education without proof that HIPAA and FERPA training has been completed, submitted to the program through EXXAT, and is current. (Note that throughout this Handbook, EXXAT refers to EXXAT/PRISM.)
Clinical students may be required to complete additional clinical site or program specific training.
For more information about HIPAA, visit www.hhs.gov/hipaa. For more information about FERPA, visit https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
Patient records are legal documents and must be kept confidential. All aspects of patient care are confidential. Clinical students must adhere to the following as it relates to patient confidentiality:
- Clinical students may not share patient information with any other person or entity unless required in the course of care or for educational purposes, and then only as approved and directed by the clinical supervisor or as instructed by the program of study.
- Clinical students must keep conversations to secure areas: a patient’s condition must not be discussed in the reception area, while escorting a patient through the facility, or anywhere that jeopardizes patient privacy.
- Clinical students should speak quietly when in University Health Center designated Collaboration Spaces or similar spaces in other locations.
- Clinical students should document patient information utilizing only the documentation system authorized by the clinical site.
- Clinical students are responsible for monitoring and securing medical records from public view and must make every effort to keep patient Protected Health Information (PHI) secure.
- Clinical students should not save patient information directly onto electronic device hard drives.
- Clinical students should not share or transmit patient information via non-secure methods.
- No copies or pictures of records may leave the clinic (including with the patient) without a signed release from the patient.
Patient privacy notices will be explained to the patient or patient’s authorized representative strictly by appropriate staff.
SCU’s privacy officer is Joseph Eggleston, MPH, CEFP, CASP, Assistant Vice-President of Auxiliary Operations (josepheggleston@scuhs.edu). In the event of a breach of protected health information (PHI), clinical students should inform their clinical supervisor who in turn must inform the Privacy Officer. In addition to SCU’s Privacy Officer, clinical sites may also have their own Privacy Officers who must also be informed according to site requirements. Programs may have additional requirements.
Clean and safe facilities are a key component of providing quality healthcare. Clinical students are expected to adhere to and support clinical hygiene requirements, including inter-treatment, daily, and weekly cleaning protocols. Clinical students should at a minimum always sanitize hands prior to any care and as necessary during care to maintain clinical hygiene.
The following minimum clinical hygiene procedures apply across all clinical care in all clinical locations and programs and should be completed after each patient visit:
- Throw away used medical exam paper and face paper
- Wipe the table and any adjunct equipment surfaces used with disinfectant Sani-cloths; wet the surface completely and use clean, intact gloves when handling the wipes
- Allow 2-5 mins for the disinfectant to air dry
- Dispose of gloves and cloths and wash/sanitize hands
Clinical students may be required to comply with additional clinical site or program specific clinical hygiene requirements.
Clinical students should be familiar with SCU’s Exposure Control Plan. Exposure control plans include training in, and supplies for, decreasing the risk of exposure to blood borne pathogens. The University’s exposure control plan is located on mySCU, the University’s intranet, under Environmental Health and Safety. https://my.scuhs.edu/ICS/Portlets/ICS/Handoutportlet/viewhandler.ashx?handout_id=5d993c49-d3ee-43c3-8efd-fddbb2880a5d
The following steps should be completed after contained/limited contamination of a surface with blood or other potentially infectious materials (OPIM):
- As soon as practical, spray the surface with a 1:10 bleach solution that was made fresh that day
- Wash hands and forearms briskly with warm water and soap for 15 seconds and dry
- Inspect utility gloves for cracks, holes or tears before donning
- After 20 minutes wipe off solution with paper towels
- Dispose of paper towels in a hazardous waste container, using proper glove doffing procedure
- Repeat hand washing
Clinical students may be required to comply with additional clinical site or program specific pre, post, and intertreatment exposure control protocols.
SCU maintains a reporting process to track, and when needed, investigate and address the following types of incidents:
- Accidents & injuries: An alleged or actual injury to a clinical student or a patient not involving care. Examples: needle stick, tripping and falling while walking in the clinic.
- A subset of this category is alleged or actual (claimed, real, or possible) breach of patient information or other incident that places or could place a student or patient in jeopardy, without attribution of cause.
- Adverse events: An alleged or actual injury to a patient because of the care they received. Examples: burn by a modality such as moxa or hydrocollator pack; rib fracture or injury from thoracic adjustment.
- Sentinel events: An event that did not involve perceived or actual harm to a patient, but had a potential to result in harm or could have the potential to result in harm if a similar event were to happen in the future or if the event were not properly handled. Example: 911 called for a patient, but security not informed to meet the ambulance. The ambulance was delayed, but no harm came to patient.
- Patient grievances/complaints: Complaints about the quality of care or service performed or provided by the clinical student, supervising clinician, or other SCU employee. Patient grievances do not involve alleged or actual injury to the patient. Examples: patient states that a clinical student was rude to them; patient states that a clinical student touched them inappropriately.
Clinical students are expected to report these types of incidents to their supervising clinician. The following reporting processes apply:
- If at an SCU owned- and operated-clinic, the supervising clinician will initiate an Incident Report through this link, as soon as reasonably possible, and ensure all necessary information is relayed:
Incident Report Fillable Form (requires separate submission)
Incident Report Online Form
If the supervising clinician is the subject of a patient grievance or complaint, the clinical student may report the incident to the Privacy Officer, the Chief Clinical Officer, the Program Director, or the Quality Assurance (QA) Coordinator. Accidents, injuries, and adverse events must also be reported by the supervising clinician to the Insurance Liaison who notifies SCU’s insurance carrier(s). Reported incidents are investigated by the QA Coordinator, Chief Clinical Officer, or other member of the Quality Assurance Committee. At the conclusion of the investigation, a summary of findings, recommendations, and actions are documented.
- If at another clinical location, follow site and program requirements for reporting. The clinical student or program officer should also inform the named University parties above, consistent with University, site, and program practices.
If there are any questions or concerns, the clinical student should contact the Clinical Supervisor and program Clinical Director/Director of Clinical Education for clarification.
Clinical students should report any activity or incident of which they are uncertain whether or not it should be reported. If there is any doubt about whether to report the accident, incident, or injury: report it.
Incident Report Fillable Form (requires separate submission)
Incident Report Online Form
Clinical students may be required to comply with additional clinical site or program specific incident report requirements.
Note: The Master of Science: Physician Assistant Program initiates reporting differently; see the Physician Assistant Reporting Accidents and Injuries policy in the Physician Assistant Clinical Handbook Section
SCU encourages clinical students to comply with public health guidelines and recommendations related to immunization; however, SCU does not have University-wide immunization requirement for clinical students.
Clinical students may be required to comply with clinical site or program specific immunization requirements. Failure to comply with immunization requirements may delay graduation or preclude participation in clinical rotations.
Prior to participating in clinical education, clinical students are required to obtain TB clearance by providing proof of a negative TB screening test in EXXAT, the University’s clinical management system.
- Clinical students who fail to obtain TB clearance before their first clinical shift will not be permitted to participate in clinical activities until clearance is obtained.
- Clinical students must repeat TB screening at least every one year.
- Clinical students may need to repeat TB screening when medically indicated due to exposure.
- Clinical students who test positive for TB will be precluded from participating in clinical activities until they receive clearance. If a clinical student tests positive for TB because of the BCG vaccine, they may submit a blood test, Interferon Gamma Release Assay (IGRA) or chest X-ray to obtain clearance.
Clinical students may be required to comply with additional clinical site or program specific TB testing requirements
Failure to comply with TB screening requirements may delay graduation or preclude participation in clinical rotations.
Informed consent must be obtained before examining and treating patients. In addition to informed consent, SCU teaches and utilizes a shared decision-making approach to help ensure each patient’s goals, desires, and values are incorporated into their treatment plan. Patients should consent to having an examination before the examination occurs. After the examination has been completed and treatment options have been approved by the supervising clinician, the patient should be given a report of findings including their diagnosis, nature of treatment(s) being recommended, possible risks, and other possible treatments. Consent can only be provided by patients capable of understanding the nature of the consent and who are not under duress.
Before treatment begins, the supervising clinician assures that the following questions are answered to each patient’s satisfaction:
- What is my diagnosis?
- Why do you think I have this diagnosis?
- What caused this diagnosis?
- What will happen if I do not get any treatment?
- What is the name of the proposed treatment?
- How is this treatment performed?
- What are the specific goals of this treatment?
- How much does each treatment cost, how many will I need, and how much will I need to pay out of pocket?
- Which aspects of my health will this treatment improve?
- How much of an improvement is expected and how long will it last?
- How will we measure this improvement?
- What are the factors that can help predict outcomes with this treatment?
- What could go wrong with this treatment?
- How often does something go wrong with this treatment?
- What are the consequences if something goes wrong?
- When should this treatment not be performed?
- What are some of the other treatment options available?
- What are the advantages of other treatment options?
- What are the disadvantages of other treatment options?
- When would you consider referring me to someone else?
Before treating a patient under the age of 18:
- Consent must be obtained from the patient’s parent or legal guardian.
- If the minor is in the custody of a legal guardian, proof of guardianship should be obtained before treating.
- A parent or legal guardian must accompany a minor patient to the first appointment.
- If a parent/guardian will not accompany the minor to subsequent appointments, the parent/guardian must sign an authorization to treat the minor without the parent/guardian being present.
Situations not requiring parental consent
- Court-ordered emancipation
- Situational emancipation (>=15 years of age AND living apart from parents AND managing own financial affairs)
- Emergency situations when a parent or guardian is not available to give consent and a delay in treatment would be life-threatening or cause the patient serious harm
Minors may also consent for the following in the state of California
- Contraception (no age minimum); Pregnancy testing, HPV vaccine, HIV testing, STD testing, Hepatitis B vaccination and Intimate partner violence* (12 years or older)
- The health care provider is not permitted to inform a parent or legal guardian without minor’s consent; the provider can only share the minor’s medical records with a signed authorization from the minor.
- *For the purposes of minor consent health care alone, “‘intimate partner violence’ means an intentional or reckless infliction of bodily harm that is perpetrated by a person with whom the minor has or has had a sexual, dating, or spousal relationship.” If the minor is seeking services as a result of a rape or sexual assault, minor consent services should be provided under the “sexual assault” or “rape” minor consent laws rather than this law. (Cal. Family Code § 6930(b))
- Sexual assault services and rape services for minors under 12 years - patients presenting to SCU for such services should be directed to a hospital setting because SCU’s clinics are not equipped with the kits for collecting medical evidence.
California Health & Safety Code §§ 123110(a), 123115(a)(1); California Civil Code §§ 56.10, 56.11
Clinical students may be required to comply with additional clinical site or program specific informed consent requirements.
Clinical students must cooperate with QA activities as requested by their clinical site, program of study, or clinical supervisor. For example, students may be asked to participate in educational chart audits, reviewing charts for completeness and legal compliance. Students may also be interviewed if involved in a QA-related incident.
SCU maintains malpractice insurance coverage for its clinical activities. These activities include Ayurveda, Chinese medicine/acupuncture, chiropractic, occupational therapy, physician assistant, herbal/pharmaceutical dispensary, and diagnostic imaging. Coverage is also maintained for special events, the Sports Medicine residency, student clubs, and community events.
This coverage may not apply if a clinical student examines or treats a patient without the approval of a clinical supervisor or practices procedures or skills outside of the supervision of SCU faculty (including associated faculty at clinical affiliates).
In the event any incident occurs where there is a chance SCU’s malpractice insurance will be needed, the carrier must be immediately notified. To ensure the carrier is notified, first report the incident to the supervising clinician and then make sure the supervising clinician notifies the Insurance Liaison and the QA Coordinator.
This summary is not intended to replace the actual policy language.
Clinical preceptors (all clinical supervisors) demonstrate proof of malpractice coverage before clinical students may participate in training at their sites.
In addition to the Academic Integrity Code and Student Code of Conduct, clinical students are expected to adhere to the Clinical Code of Conduct, an extension of the Student Code of Conduct. Programs may have additional requirements. A failure to comply with any element will lead to removal from the site. If the clinical student is authorized to return to the site, it will only be after the clinical student is in compliance with the Clinical Code of Conduct (in addition to any other University-, program-, and/or site-stipulated requirements).
Clinical students are expected to maintain the highest level of professional behavior. The hallmarks of professional behavior include but are not limited to honesty and integrity; treating individuals with courtesy and dignity; working collaboratively and cooperatively with all providers, supervisors, staff, and students; punctuality and dependability; and complying with all SCU, program, and site policies and procedures. Each program assesses and supports professionalism in clinical rotations.
In addition to respecting professional boundaries by honoring the privacy, confidentiality, dignity, and autonomy of patients, clinical students must avoid all behaviors that may be construed as crossing sexual boundaries in clinical care at any site. Clinical students cannot ask to date patients or staff. Clinical students are not allowed to utilize inappropriate examination or treatment procedures, inappropriate physical contact, and inappropriate comments. Boundary violations will be addressed with all due seriousness by the site, program, and/or University.
Clinical students are expected to abide by SCU’s Title IX/SB 493 policies published in SCU’s University Catalog; see the Campus Safety Manual .
Depending on the patient’s clinical presentation and consistent with site and program requirements, patients may need to undress and donn a gown for a physical examination. When an examination or treatment involves accessing part of the body that is not normally exposed in a public setting, gowning can help patients feel more comfortable and less exposed and protects clinical students and supervising clinicians from accusations of impropriety. The process of gowning entails the patient removing their street clothes and donning the gown over their undergarments. Shorts and draped towels may also be used to improve access to the lower extremities while protecting patient privacy.
When consistent with program scope and training, breast, pelvic, and rectal examinations for patients of any gender - and preparticipation examinations of minors - may only be conducted 1) consistent with site policies; 2) with the express, documented permission of the patient (or patient’s parent or legal guardian when legally permitted and/or required); 3) with the express, documented permission of the supervising clinician; and 4) in the presence of a chaperone when a chaperone is legally permitted and/or required. Where minors have the legal right to determine whether or not their parent or guardian serves as a chaperone, they must be permitted to make that determination.
Clinical students are expected to be sensitive to each patient’s cultural values, life circumstances, and personal boundaries, and exhibit sensitivity in communications and actions with patients.
Clinical students are not to give treatment advice to patients via phone, texts, email, or social media.
Supervising clinicians are hired or affiliated by SCU after evaluating credentials and are reviewed on a recurring basis by programs. Students may not participate in patient care except under the supervision of a supervising clinician.
Clinical students must verbally identify themselves as a student and name their program at the beginning of all patient and professional encounters or when representing their profession or program. Clinical students may not reference any other professional title or degree on any signed or written materials.
Clinical students may not identify themselves as a doctor or practitioner, or present themselves in any way as holding a license, whether at a clinical site or away from it.
All treatment, advice, and referrals rendered to patients must be performed with express permission from and under the supervision of a supervising clinician (including preceptors/associated faculty). As unlicensed individuals, students may not diagnose, create a treatment plan, or act with independence from a licensed clinical supervisor.
Patients in any clinical setting are the responsibility of the supervising clinician. Clinical students may not attempt to change any patient’s treatment plan, or give advice to the patient, without approval from the supervising clinician. Clinical students may not attempt to persuade any patient to seek a different clinician or provider. If the patient requests a referral to an outside provider, this will be considered and provided by the supervising clinician. Any concerns that patients have about their treatment or condition must be brought to the attention of the supervising clinician.
Clinical students are exposed to a variety of examination and treatment techniques through their pre-clinical and clinical training. Treatment approaches and techniques with the highest level of evidence and those required for licensure are part of SCU’s standardized care pathways and consistently taught and supervised across clinical supervisors of each discipline; however, clinical supervisors at any location may not approve or supervise clinical student use of treatment techniques in which they themselves as clinical supervisors are not trained.
All student-generated patient records must be created and maintained in a HIPAA- and SCU-policy-compliant manner, and consistent with the privacy practices acknowledgement shared with the patient at the respective facility. Patient documentation should never leave the facility, except as compliant with HIPAA and site policy and the patient acknowledgement.
Accurate, complete progress notes must be recorded each time a patient presents to the clinical facility or is contacted, including by telephone, regardless of whether they were treated, to document precisely what occurred during each patient interaction. Any paper records must use only blue ink. The default format for clinical documentation at SCU is the SOAP format (Subjective, Objective, Assessment, Plan); however, programs and clinical sites may dictate other formats that students are responsible to follow. Regardless of format, all notes must be dated and legible, and signed by the clinical supervisor and consistent with regulatory, standard of care, site, and program requirements. If patient interactions - including advice given and treatment rendered - are not documented, they are viewed legally as not having occurred.
All monies collected through clinical care belong to SCU, the clinical site, or other parties per arrangement. Clinical students do not receive income from treatment of patients and are not employees. Clinical students participate in patient care under clinical supervision as part of their academic training.
Clinical students shall not contradict front office or billing staff regarding clinical site financial policies. Clinical students should direct any questions about payment arrangements, including special payment arrangements, to appropriate staff.
Electronic devices are only allowed in treatment rooms or patient care settings at the discretion of the supervising clinician. Electronic devices, when permitted, are only to be used in support of patient care, consistent with SCU, program, and site policies. No permanent photographs, videos, or audio recordings are to be captured of the patient encounter, unless approved by the patient (or the patient’s parent/legal guardian when necessary); when approved, recordings may only be captured and retained through the authorized EHR application.
Clinical students may share information about the clinic location or events in which they are participating, consistent with SCU, program, and site restrictions and guidelines. This may be done by distributing the supervising clinician(s)’s business cards, sharing the site business website, following the clinical site’s business or event on social media and promoting/sharing posts, forwarding email campaign messages, and more. When sharing information about clinical site or event services, clinical students must refer to themselves as “SCU Clinical Students” or otherwise clearly identify themselves as a student as opposed to a licensed healthcare provider, consistent with site and program requirements.
When posting about the clinical site or events - or clinical education more broadly - on social media, clinical students should not include images of patients or any protected health information (PHI) or sensitive health information.
Social media posts or other forms of promotion may only include basic facts (e.g., services, hours, locations). Posts that include additional information (e.g., clinical advice, descriptions of services, health claims) require authorization from the site, program, and/or SCU Marketing Team Provider Liaison.
If a patient would like to give a testimonial, clinical students should refer the patient to the supervising clinician for direction, and if consistent with site and program policies, refer the patient to the Marketing Team Provider Liaison to ensure a release form is obtained and proper procedures followed.
Clinical students may be required to comply with additional clinical site or program specific marketing/advertising requirements.
Clinical students are expected to promote and reflect a professional and safe patient care environment. The following dress, grooming, and personal hygiene guidelines are the minimum standards for all clinical students. Variations of these standards may be acceptable when appropriate for medical or religious reasons.
SCU Health Leadership, program leadership, and site-specific authorities make the final determination in each circumstance regarding appropriate professional appearance, to the extent these are compliant with law and SCU’s non-discrimination policy.
Standards of Professional Appearance, as detailed below, are required for clinical activities and patient encounters unless otherwise specified. Clinical students are also required to wear professional clothing/attire when a standardized or real patient is present. In all instances, work attire must be professional, neat, and clean and must allow patients and visitors to easily identify clinical students. Clinical students must always wear nametags/ID badges while participating in clinical education.
SCU’s Standards of Professional Appearance have been adapted from the Keck School of Medicine MD Student Dress Code Policy, with additional information from Alberta Health Services.
Personal Hygiene/Cleanliness
- Hair is to be clean and groomed so as to not directly interfere with any essential patient care or clinical learning/working function. Faces should be clean-shaven or beards and mustaches clean and neatly trimmed.
- Body hygiene is required so that offensive body and/or breath odor is avoided.
- Cosmetics should be appropriate for a business environment.
- Perfumes, colognes, scented lotions and/or after-shave lotion should not be worn.
- Natural fingernails must be clean, well-manicured, and short; nail polish, if worn, must be freshly applied and not chipped. Artificial nails and/or nail enhancements must not be worn during direct patient care or while performing tasks that require hand hygiene.
Clinical Setting Attire (Professional Dress)
- Appropriate professional attire may include:
- SCU polo and dress slacks of a solid color (black, brown, navy, grey, khaki) that are clean, neat, and in good condition, OR
- Scrubs of a solid color that are clean, free of wrinkles, and appropriately sized.
- Either clothing option must be worn with shoes that are clean, closed-toe and closed-heel, and constructed of material of sufficient strength to protect the foot. Sneakers are permitted to be worn with scrubs if they are solid-colored.
- Clothing must not be tight, sheer, or revealing, and must maintain modesty while standing or sitting and in all typical work positions.
- An official photo identification badge must be worn at all times, with name and picture easily visible. The badge must identify the wearer as a student. Nametags may not contain indication of other professional titles, degrees, or certificates (e.g., RN, EMT, DPT, DC, PA, L.Ac, MD, OT, etc.) while in any clinical setting.
- White coats, when approved by the program and site, must be clean and pressed.
- Jewelry should not interfere with patient care or personal safety.
Clinical students may be required to comply with additional clinical site or program specific standards of professional appearance and/or dress code requirements.
Inappropriate Attire in Clinical Settings
The following attire is not appropriate for clinical settings:
- Jeans, denim, or denim-like fabric; shorts
- Mini-skirts
- Sweatpants or sweat shirts
- Pajamas
- Leggings/spandex pants/yoga pants
- T-shirts or undershirts worn by themselves
- Midriff, off-the-shoulder, spaghetti-strap, or strapless tops
- Hats, caps, or visors indoors
- Operating room/procedure room attire (masks, booties, hair coverings) worn outside of procedure areas
- Open-toe shoes, slingbacks, sandals, and flip-flops
- Torn, wrinkled, and/or unclean clothing or scrubs
- Altered SCU clinic jackets or polos
- Pins, stickers, advertising, or additional patches or embroidery on white coats, SCU polo shirts, or scrubs (except for the required ID, the embroidered student’s name, or patch as permitted or required by programs).
Clinical students may be required to comply with additional clinical site or program specific standards of professional appearance and/or dress code requirements.
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