Purpose:
To ensure that the Clinical Pastoral Education program maintains student records in a manner applicable to the Family Education Rights and Privacy Act (FERPA) which addresses privacy issues, access, and content of student records, and custody of student records should the center be without a supervisor and /or accreditation.

Policy:
VITAS Healthcare Corporation shall maintain records in a manner consistent with the Guidelines for Student Records as they appear in Appendix 7B of the Accreditation Manual (pp 88-90). Those guidelines are given to the students during the orientation phase of their CPE learning experience. We recognize that the student owns the information about them and is permitted to know what is being collected and how it is being used. Student records will not be released without the written consent of the student.

The official records will consist of the application face sheet, the CPE supervisor’s written evaluation report and the student’s own written evaluation report. Material written by students, such as verbatims, case histories and electronic recordings, from which the students’ identity can be recognized, will be destroyed at the conclusion of the unit. This includes hard copies and material sent electronically. The only exception is when written permission has been given by the student for the purposes of pastoral or supervisory research. In those instances, the identifiable information regarding persons other than the particular student will be redacted. HIPAA regulations will be followed regarding any medical information provided. FERPA requires that students be able to review their record within 45 days of the student’s request and cannot be denied based on the student’s inability to come to the site or has outstanding financial obligations. Copies of the file will be made available to the student for pick up. At that time, they will be asked to sign a release form. If a student is truly unable to pick up their records, they may be mailed after consent is given in writing with their legal signature and an appropriate address for mailing is offered.

Supervisory notes are not a part of the official record and are the property of the supervisor. Other Exceptions: Certain exceptions concerning the release of information exist to protect the health or safety of the student or others, and for the purpose of accreditation or complaint review, or as required for legal processes. Before releasing material in any of these circumstances, consult with the ACPE Executive Director or Associate Director.

Directory Information is student information not generally considered harmful or an invasion of privacy if released. Common directory information may include: name, address, email, telephone, date of birth, religious background, previous education and photograph – and can be released without specific consent unless a student “opts out”. Further information regarding the handling of student information can be found in the training agreement 304.9.

Procedure:
VITAS Healthcare Corporation student files will be maintained for a period of ten (10) years. ACPE requires that the CPE Student record include the face sheet with directory information, the CPE supervisor’s evaluation and the student’s evaluation. After that period the file will be thinned and only a face sheet will be held. The student has the responsibility to maintain his/her own evaluations for future use and is informed of this when the final evaluation is signed by both the supervisor and student. A copy is kept in the program’s file and the other copy is handed to the student. No evaluation reports will be released from the file without the written request/consent of the student.
Student files are maintained at the center where the CPE training took place. Access to student records is restricted to the Supervisor/s at the Center and other specified personnel like an administrative assistant and/or the CPE System Director. The information is kept in a locked filing cabinet and/or locked office.
In the event that the Clinical Pastoral Education program closes, student records will be sent to the VITAS CPE System Director’s office at 100 S Biscayne Blvd, Suite 1500, Miami, FL 33131. The CPE System Director will notify the Regional Accreditation Commission Chair of the records’ relocation. When the 10 year limit has expired, all but the face sheet will be destroyed.
Upon successful completion of a unit (or ½ unit) of training, the CPE supervisor will complete a ‘student unit report’ via the National ACPE office that includes students’ names, addresses, faith backgrounds, gender, level of training. This information is required in order for the registration to be successful.
If any exceptions need to be made concerning the release of information (i.e., grievance filed, subpoena) consultation may be sought from the VITAS CPE System Director who may then consult with the ACPE Associate Director or Executive Director in the National ACPE office if necessary.
Annual Notice information will be on the www.cpevitas.com web page and made available to each student during their first week of admission to the program. It will also be updated each year and published in the handbook, as a part of policy “304.4 Maintenance of Student Records”. In addition to the information stated above, the Annual Notice includes:
This ACPE CPE component site guarantees to its students the rights to inspect and review his/her personal education records, to attach amendments if so desired, to specify to whom and when their information is released to others, such as seminaries and ordaining boards. Students have the right to file a complaint with the VITAS CPE System Director or the local Professional Advisory Group if they believe their FERPA rights have been violated. The VITAS CPE System Director will consult with the Chairperson of the National Accreditation Commission at ACPE, Inc., 1549 Clairmont Road, Suite 103, Decatur GA 30033.
Students have the right to object to recorded content. However, some written content is based on the professional assessment of the trained supervisor and may not be negotiated (i.e., evaluations). In such cases, students are permitted to submit an addendum with their comments and it will be attached as an official part of the student’s record and released with all other items in the student’s record upon request. (See evaluation policy 308.8.1.) Grades are exempt from this right.