Page 41

Tennessee Housing Development Agency 2025 LIHEAP Policy Manual for Regular and Crisis Assistance 40

3.1 Documentation and Record-Keeping Processes Each client must have an individual client file, and all documentation that supports client eligibility and services provided must be retained in that file. Failure to provide or locate required documentation is considered non-compliance. Client records will be retained for a minimum of five (5) years after the final invoice for the program year has been submitted. These records must be stored in a secure location accessible only to authorized personnel. For digital files that are not uploaded into SmartSimple, a secured system must be in place, with access controlled and monitored by management. The process for uploading and securing scanned program records into a secure database must be outlined in the Agency Specific Operational Plan. Digital applicant files must contain all the same information required in hard copy files. Additionally, Continuity of Operations Plans should include protocols for the preservation of electronic records following any emergency or disaster.

3.2 Confidentiality of Client Information Maintaining the confidentiality of client information is essential. The LIHEAP grant contract between each agency and THDA specifically addresses this responsibility, and agencies must adhere to the terms outlined in the contract. Refer to the current LIHEAP grant contract for specific language regarding confidentiality. Agencies must comply with all relevant laws and regulations concerning privacy, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health (HITECH) Act, and other applicable privacy rules (collectively referred to as the “Privacy Rules”). • All employees must undergo training on client confidentiality, code of ethics and conduct, electronic communications, customer relations, and release of information. This training must be documented and included in the Employee Handbook or Agency Policy Manual.

3.3 Conflict of Interest Contract agencies must ensure that all employees involved with LIHEAP programs sign a Conflict-of-Interest statement. A blank copy of the agency’s Conflict of Interest Policy must