The Family Education Rights and Privacy Act (FERPA) applies to all ACPE CPE programs. FERPA addresses privacy not confidentiality issues. This means students own the information about them and must know what is being collected and how it is being used. Their information cannot be shared without their written permission. This Annual Notice describes the protocols for the proper handling of student records. Additional information about this program’s management of student records can be found in the CPE Student Handbook, Maintenance of Student Record Policy.
Students’ Right to Privacy
This ACPE CPE center/program guarantees to its students the rights to inspect and review education records, to seek to amend them, to specified control over release of record information, and to file a complaint against the program for alleged violations of these Family Education and Privacy Act (FERPA) rights.
“Directory Information” is student information not generally considered harmful or an invasion of privacy if released. At MedStar Washington Hospital Center, the directory information that is distributed to peers and members of the Spiritual Services department includes: name, address, phone number, and email address. Restrictions will be honored even after the student’s departure. Former students cannot initiate new restrictions after departure. At the start of the CPE unit, MedStar Washington Hospital Center publishes a poster with the names and photographs of the CPE students and is posted in the clinical units. Current students may “opt out” or restrict published directory information and/or record access at any time during attendance. If a student wishes to “opt out” of inclusion in the directory or on the poster, the student needs to contact the CPE Manager at least one week prior to the start of the CPE Unit.
A “Student Record” is any record (paper, electronic, video, audio, biometric etc.) directly related to the student from which the student’s identity can be recognized; and maintained by the education program/institution or a person acting for the institution. While the student is enrolled at MedStar Washington Hospital Center, the student’s record consists of a file folder in CPE Certified Educator’s Office containing:
- ACPE application face sheet, with directory information, and essays
- Materials applicant submitted with the application
- Materials submitted by the student during the CPE unit
- Evaluations of each unit completed
“Working files” are notes, student work materials submitted during the unit, evaluations, recommendation forms, and other materials collected by the student’s supervisor for the purpose of assisting in the supervision, education, and evaluation of the student’s learning and work. Working files are not part of the student record. Student material in the “working file” will be destroyed following the presentation of the CPE Certified Educator’s evaluation report to the student.
“Education Officials” are persons who hold a legitimate educational interest and may have access to student records without student consent. At MedStar Washington Hospital Center, “education officials” are: CPE Manager, CPE Certified Educators and members of the Spiritual Care Advisory Board (the Professional Advisory Group). Other persons who may have access to some of the content of the student’s record are: the Spiritual Care Administrative Assistant, associates within Spiritual Care, Human Resources, Occupational Health, and Recruiting departments who process the student’s background check and related forms, and the Information Services personnel who process requests for computer access.
All other information is released only with the student’s written, signed, dated consent specifying which records are being disclosed, for what purpose, and to whom. To obtain a copy of their student record, the student submits a request in writing and pays a duplication fee of $5.00.
Other Details About MedStar Washington Hospital Center’s Record Maintenance Protocols:
A copy of the CPE Certified Educator’s evaluation report will be available to the student within 21 days of the end of the unit. At the completion of each unit of CPE, the student’s name, address, denomination and unit of CPE successfully completed will be sent to the ACPE office using the Student Unit Report to register the unit. The registering of units requires no specific student consent for the use of this information.
Students are responsible for maintaining their own files for future use. Students will be informed at the time copies are given to them that it is their responsibility to keep copies for future use.
An official Student Record file is maintained by MedStar Washington Hospital Center for ten years on each student after the student has completed his/her time of enrollment. The official Student Record will include:
- ACPE application face sheet with directory information
- Educator’s evaluation report.
- The student’s final self-evaluations.
- Additional pertinent documentation
- Letters of Agreement (if applicable)
- Letter of postponement, withdrawal or termination
- Requests for copies of evaluations
After ten years the center will maintain only a face sheet indicating last known directory information and dates of attendance. All other materials will be securely discarded.
A student is able to review his/her record within 21 days of the written request submitted to the CPE Manager. If a student has outstanding financial obligations or cannot come to the site, the center will note on the copy of the records “not available for official use.” When a student’s record contains identifiers of another student, those will be redacted. A student has the right to object to record content. If not negotiable, the written objection will be kept with and released with the record. Grades are exempted from this right.
Regarding research: If information in student records or in a CPE Certified Educator’s records is considered of research value, and a CPE center or ACPE desires to collect and use such material for research, the student’s ACPE “Use of Clinical Materials Consent Form” that student’s sign in the CPE admissions interview is the student’s permission for the CPE Center to use the documents.
Violations of these protocols may be reported to: ACPE Accreditation Commission, Attn: Accreditation Chair, 55 Ivan Allen Jr. Boulevard, Suite 835, Atlanta, GA 30308