Rule 3349-5-75 | Student health initiatives.
(A) Purpose
To ensure that all students participating in student-led health fairs and related events are appropriately trained and supervised such that their activities are properly covered for purposes of liability and are compliant with any state and federal regulations and professional licensure requirements.
(B) Scope
This rule applies to all students in the college of medicine and college of pharmacy who are engaging in university-sponsored student-led health fairs, screenings and other clinical or educational events.
(C) Definitions
(1) "CLIA" refers to the clinical laboratory improvement amendments, which is a document provided by the centers for disease control and prevention for the purpose of setting standards for the accredited laboratories.
(2) "Clinical Activities" refers to the provision of clinical services, such as administration of vaccines at a flu clinic or the review of medications in a medication therapy management consult.
(3) "OSHA" refers to the occupational safety and health administration, which governs workplace safety.
(4) "Screenings" refers to conducting or determining blood glucose levels, blood pressure levels, body fat analysis, body mass index, bone density testing, cholesterol testing and glaucoma screening.
(D) Rule statement
(1) Student health fairs and screenings
(a) The health fair or screening should be designed to meet an identified need within the community or to target an underserved population who is otherwise unable to obtain such services.
(b) Any student(s) or student organization(s) seeking to host a health fair or screening event must contact the office of student affairs in order to obtain an "application to host a student health event." The application must be completed and returned to the office of student affairs no less than fourteen days prior to the event.
(c) Consistent with the student health event application, the student(s) or student group(s) must document the following information about the event for review and approval:
(i) Type of activity being conducted during the event;
(ii) Type and amount of university clinical supervision that will be present at the event, which must provide for supervision of university pharmacy students in a one to two pharmacist to student ratio and university medical students in a one to four clinician to student ratio;
(iii) Whether CLIA and/or OSHA training is required for the screenings being conducted;
(iv) Consent form for participants; and
(v) Educational materials for participants.
(d) The dean of the college(s) in which the student(s) are enrolled or which has authority over the student organization(s) involved must review and approve of the event in order for the event to be considered an educational experience sanctioned by the university and therefore falling within the scope of the applicable professional liability coverage in place for students.
(e) The student(s) or student organization(s) are responsible for obtaining the requisite supplies necessary to conduct any testing or screening at the event. Student(s) can apply to one of the university's student organizations or university student council for funding to cover the supply costs for the event.
(f) The student(s) or student organization(s) are responsible for obtaining the requisite equipment necessary to conduct any testing or screening at the event. Student(s) can obtain blood pressure cuffs, bone density testing equipment, or glucometers for use at the event from the Wasson center.
(g) The office of student affairs shall maintain a calendar of events authorized under this rule.
(h) All students and clinical faculty participating in the event must have completed blood-borne pathogen and CLIA waiver training as indicated on the student health event application.
(i) Students must have a documented plan to address event participants who are identified as presenting with significant risk of an impending health event (e.g., extreme results related to blood pressure or blood sugar levels).
(j) No pediatric screening, risk assessment, or other pediatric services will be conducted at any university health fair. Any activities geared toward those under the age of eighteen must be designed solely for the purpose of entertainment or education; they cannot include any pediatric screening or assessment.
(k) Under no circumstances do the screenings or education materials provided by student(s) and student organization(s) at events governed under this section establish a doctor-patient relationship. Student(s) and student organization(s) must make this evident to all participants through their written materials and statements to participants.
(2) Other clinical events
(a) Any students or student organizations who engage in the provision of clinical services such as hosting a flu clinic, conducting a "brown-bag" medication review, or providing medication therapy management in a no-cost manner must complete a "student health event application" to ensure that they are adequately trained and supervised in providing the foregoing services.
(b) Under no circumstances do the clinical services provided by student(s) and student organization(s) at events governed under this paragraph establish a doctor-patient relationship. Student(s) and student organization(s) must make this evident to all participants through their written materials and statements to participants.
(3) Educational events
Students or student organizations who present health education and prevention information to the general public or a targeted audiences need to have their educational materials reviewed by their faculty advisor or course instruction before engaging in such activities. Faculty advisors should engage the assistance of library copyright staff to make determinations of appropriate use of materials.
(4) Volunteer activities
Students may participate in a wide array of volunteer activities that occur off campus and outside of the curricular requirements of their degree program. When students engage in such independent volunteer activities that fall outside of any approved event that is sponsored through and sanctioned by the university, they do so at their own risk. In these instances, the student will not be covered under the university's professional liability insurance for any situations that arise out of these volunteer activities.
(5) Research
Any data collected in conjunction with the events approved under this rule must be for evaluation purposes only, and not for purposes of research. Students wishing to utilize data from event participants for research purpose must first seek approval of their protocol from the university's institutional review board.
Supplemental Information